Justia Pennsylvania Supreme Court Opinion Summaries

A defendant was arrested on drug charges and initially held on high bail, which was later reduced. A bail bondsman posted the reduced bail, agreeing to be liable if the defendant failed to appear in court. The court scheduled a pretrial conference, but due to administrative errors, the defendant and his counsel were misinformed about the date. As a result, they missed the proceeding, leading the trial court to issue a bench warrant and revoke bail. Days later, when the defendant appeared for what he believed was the correct date, the court vacated the bench warrant and reinstated bail, relying on the defense counsel’s oral representation that the bondsman consented to continue as surety, but did not obtain written consent.Months later, the defendant failed to appear for trial, resulting in another bail revocation and notice of intent to forfeit the bond. The bondsman, after being notified of the impending forfeiture, filed a petition to strike or set aside the forfeiture, arguing that the court had failed to obtain his written consent when bail was previously reinstated. The Cumberland County Court of Common Pleas denied the petition. The Superior Court of Pennsylvania affirmed, reasoning that written consent was not required because the initial bail revocation was due to court error, not the defendant’s fault.The Supreme Court of Pennsylvania reviewed the case to determine whether the statutory requirement for written consent from a bail bondsman applies when bail is reinstated after a revocation caused by court error. The court held that the statute requires written consent from the bail bondsman whenever bail is reinstated after a defendant’s failure to appear, regardless of whether the failure was due to a breakdown in court administration. However, the court found that the bondsman was not entitled to relief because he failed to timely appeal the order reinstating bail. The Supreme Court affirmed the Superior Court’s result, but on different grounds. View "Commonwealth v. Rondon" on Justia Law

A woman, identified as the victim, lived with her mother and infant sister. The mother’s boyfriend, the appellant, would babysit the children at night. The victim testified that, starting at age 10, the appellant repeatedly entered her bedroom and sexually assaulted her. She disclosed the abuse to family members and a doctor, and later to a teacher, which led to police involvement. The appellant was charged with multiple sexual offenses, including rape of a child and related crimes.Before trial in the Court of Common Pleas of Allegheny County, the Commonwealth proposed a voir dire question to potential jurors, asking if they could follow the legal principle that the testimony of an alleged victim alone, if believed, is sufficient to convict in a sexual assault case. The appellant objected, arguing the question was improper and misstated the law. The trial court denied the objection, and the jury convicted the appellant on all charges, resulting in a lengthy prison sentence. The appellant’s post-sentence motion was denied, and he appealed to the Superior Court of Pennsylvania, arguing, among other things, that the voir dire question was improper. The Superior Court affirmed the judgment, finding the question proper and consistent with Pennsylvania law and jury instructions.The Supreme Court of Pennsylvania reviewed whether the trial court erred in allowing the voir dire question. The Court held that the trial court did not abuse its discretion. It found the question was designed to ensure jurors could follow the law that a victim’s uncorroborated testimony, if believed, can be sufficient for conviction in sexual assault cases. The Court concluded that such a question is permissible to identify jurors with fixed beliefs contrary to this legal principle. The judgment of sentence was affirmed. View "Commonwealth v. Walker" on Justia Law

A high school in a Pennsylvania school district displayed approximately 70 books in its library, some of which addressed LGBTQ+ issues in anticipation of Pride Month. A third-party contractor photographed the display and posted it on Facebook. Two school board members, David Valesky and Luigi DeFrancesco, shared the post on their personal Facebook accounts, with Valesky adding commentary critical of the display. This sparked public debate, including a newspaper article and discussions at subsequent school board meetings. Thomas Cagle, a local resident, submitted a request under Pennsylvania’s Right-to-Know Law (RTKL) seeking, among other things, all Facebook posts and comments by the two board members related to homosexuality and the school district.The school district partially denied the request, providing some emails but refusing to disclose any social media content, arguing that the posts were on personal accounts and not within the district’s possession. Cagle appealed to the Pennsylvania Office of Open Records (OOR), which ordered disclosure, reasoning that the content, not the ownership of the account, determined whether the posts were public records. The district sought judicial review in the Court of Common Pleas of Crawford County, which agreed with the OOR and ordered disclosure, finding that the posts documented district business and were thus subject to the RTKL.On appeal, the Commonwealth Court vacated the trial court’s order and remanded for further proceedings, instructing the lower court to consider additional factors to determine whether the posts were “of the agency” under the RTKL. The Supreme Court of Pennsylvania reviewed the case and held that the RTKL’s two-part test—whether the information documents a transaction or activity of an agency and was created, received, or retained in connection with agency business—applies to all forms of communication, including social media. The Court affirmed the Commonwealth Court’s order to remand for further fact-finding, clarifying that no special test applies to social media, but relevant facts must be considered in each case. View "Penncrest SD v. Cagle" on Justia Law

A mother and her son owned real property together in Pennsylvania as joint tenants with the right of survivorship, meaning that if one died, the other would automatically inherit the entire property. After their relationship deteriorated, the mother sought to sever this joint tenancy so that her share would not pass automatically to her son upon her death. She executed a quitclaim deed transferring her interest in the property from herself as grantor to herself as grantee, explicitly stating her intent to sever the joint tenancy and create a tenancy in common. The mother died while litigation over the property was ongoing, and her estate, represented by her executrix, continued the dispute.The Court of Common Pleas of Westmoreland County determined that the mother’s quitclaim deed did not sever the joint tenancy because it did not destroy any of the four unities (title, time, interest, or possession) that define a joint tenancy. The court held that, since the joint tenancy was not severed, the property passed entirely to the son upon the mother’s death by right of survivorship. The court quieted title in favor of the son. The Superior Court of Pennsylvania affirmed this decision, reasoning that a joint tenant’s act must be of such manifestation that the actor cannot retreat from severance, and that a self-conveyance does not meet this standard.The Supreme Court of Pennsylvania reviewed the case to determine whether a quitclaim deed transferring a joint tenant’s interest to herself is sufficient to sever a joint tenancy. The court held that such a self-conveyance is insufficient to sever a joint tenancy because it does not destroy any of the four unities. The court affirmed the Superior Court’s judgment, holding that the joint tenancy remained intact and the property passed to the son by survivorship. View "Grant v. Grant" on Justia Law

A police officer observed a vehicle committing multiple traffic violations and initiated a stop. The officer discovered the vehicle was registered to someone other than the driver, George Anderson, and that Anderson's license was suspended. During the stop, the officer smelled marijuana and observed Anderson acting nervously. A protective search revealed a firearm and marijuana in the vehicle. Anderson was arrested and charged with various offenses, including firearm and drug possession.The Delaware County Court of Common Pleas denied Anderson's motion to suppress the evidence found in the vehicle, ruling that Anderson did not have a reasonable expectation of privacy in the car because it was not registered to him. Anderson was convicted of carrying a firearm without a license and sentenced to 42 to 84 months in prison. The Superior Court affirmed the trial court's decision, agreeing that Anderson failed to establish a reasonable expectation of privacy in the vehicle.The Supreme Court of Pennsylvania reviewed the case to determine whether the Commonwealth met its initial burden of production to show Anderson lacked a reasonable expectation of privacy by presenting evidence that the car was registered to someone else. The court held that the mere fact that the vehicle was registered to another person was insufficient to meet the Commonwealth's burden. The court emphasized that ownership is not a prerequisite for a reasonable expectation of privacy and that lawful possession or control can also establish such an expectation. The court reversed the Superior Court's decision and remanded the case for further proceedings to consider the totality of the circumstances and whether the Commonwealth met its burden based on all the evidence presented. View "Commonwealth v. Anderson" on Justia Law

In 2012, the appellant was charged with DUI and resolved the charge through acceptance into an Accelerated Rehabilitative Disposition (ARD) program. In 2020, he was again charged with DUI and convicted based on a guilty plea. The Pennsylvania Department of Transportation (PennDOT) received notice of his conviction and suspended his license for one year under Section 3804(e) of the Vehicle Code, which mandates a suspension for DUI convictions unless the individual has no prior offenses, including ARD acceptances within the past ten years.The appellant appealed the suspension to the Cumberland County Court of Common Pleas, which upheld the suspension despite the Superior Court's ruling in Commonwealth v. Chichkin, which disapproved of enhanced criminal sentencing based on an earlier ARD. The county court reasoned that the license suspension was a civil penalty and did not implicate the constitutional safeguards applicable in criminal matters. The Commonwealth Court affirmed this decision, agreeing that the suspension was a civil consequence and should be upheld as long as PennDOT acted in accordance with the law.The Supreme Court of Pennsylvania reviewed the case to determine whether the license suspension violated due process, given that the appellant's prior ARD acceptance was not a criminal conviction. The court held that the suspension did not violate due process. It reasoned that the suspension was based on the 2020 DUI conviction, not the prior ARD acceptance, and that the legislative scheme was rationally related to the state's interest in deterring drunk driving and ensuring public safety. The court affirmed the Commonwealth Court's order, upholding the one-year license suspension. View "Ferguson v. Dept. of Transportation" on Justia Law

An attorney, admitted to practice law in 2002, served as a Deputy District Attorney and later as Chief Deputy District Attorney in Bucks County. From 2005 to 2008, he also served as a Youth Fellowship Group Leader at a Methodist Church. During this period, he engaged in misconduct by providing alcohol and marijuana to minors and engaging in a consensual sexual relationship with a 16-year-old boy from the church youth group. This led to his arrest in 2008, and he subsequently pled guilty to multiple charges, including endangering the welfare of children and corruption of minors. He was sentenced to incarceration and probation.Following his conviction, the attorney was placed on temporary suspension in 2009, and the Office of Disciplinary Counsel (ODC) filed a Petition for Discipline. A disciplinary hearing was held, and the Hearing Committee recommended disbarment, which the Disciplinary Board of the Supreme Court of Pennsylvania initially recommended as a five-year suspension. However, the Supreme Court of Pennsylvania ultimately disbarred him in 2012.In 2016, the attorney filed his first petition for reinstatement, which was denied by the Board, citing the need for more time to pass. He accepted this decision and did not seek further review. In 2022, he filed a second petition for reinstatement. The Hearing Committee recommended reinstatement, but the Board disagreed, finding his misconduct too egregious for reinstatement.The Supreme Court of Pennsylvania reviewed the case de novo and determined that the attorney's misconduct, while severe, did not preclude consideration of his reinstatement. The Court found that he had demonstrated significant rehabilitation, remorse, and compliance with all probationary requirements. Consequently, the Court granted his petition for reinstatement, concluding that he met the criteria under Pa.R.D.E. 218(c)(3) and that his resumption of practice would not be detrimental to the integrity of the bar or the public interest. View "In re Cappuccio" on Justia Law

The case involves a facial constitutional challenge to Section 3755 of the Pennsylvania Vehicle Code, which authorizes warrantless blood draws from individuals requiring emergency medical treatment after a motor vehicle accident if there is probable cause to suspect DUI. Larry Wardell Hunte was involved in a serious car accident, and while unconscious at the hospital, a state trooper requested a blood draw under Section 3755, which revealed the presence of alcohol and controlled substances. Hunte was charged with multiple offenses, including homicide by vehicle while DUI.The Cumberland County Court of Common Pleas found Section 3755 unconstitutional, holding that it violated the Fourth Amendment and Article I, Section 8 of the Pennsylvania Constitution. The court reasoned that the statute authorized warrantless searches without any recognized exception to the warrant requirement, such as exigent circumstances or voluntary consent.The Supreme Court of Pennsylvania affirmed the lower court's decision. The court held that Section 3755 is facially unconstitutional because it mandates warrantless blood draws based solely on probable cause, without requiring a search warrant or demonstrating any exception to the warrant requirement. The court emphasized that the Fourth Amendment requires a warrant for such searches unless a valid exception applies, and statutory "implied consent" does not constitute such an exception. The court also rejected arguments that the statute could be applied constitutionally in certain circumstances, such as when a warrant is later obtained or exigent circumstances are present, noting that these scenarios do not involve actual applications of the statute. The court concluded that Section 3755 violates both the Fourth Amendment and the Pennsylvania Constitution. View "Commonwealth v. Hunte" on Justia Law

In this case, the appellant, Brendan Linton, was riding his bicycle on a heavily trafficked state highway in Butler Township, Pennsylvania. The highway had one lane of travel in each direction, with a speed limit varying from 45 to 55 mph. Pennsylvania State Trooper Joshua Osche observed Linton riding his bicycle at speeds significantly lower than the posted speed limits, causing a buildup of traffic behind him. Despite multiple vehicles successfully passing Linton, Trooper Osche eventually initiated a traffic stop, citing Linton for impeding the normal and reasonable movement of traffic under Section 3364(b)(2) of the Vehicle Code.The Court of Common Pleas of Butler County found Linton guilty of violating Section 3364(b)(2), concluding that he should have moved to the berm area to allow faster-moving traffic to pass. The court imposed a $25 fine. The Superior Court of Pennsylvania affirmed the judgment, agreeing that Linton's failure to use the berm constituted a violation of the statute.The Supreme Court of Pennsylvania reviewed the case to determine whether Section 3364(b)(2) requires pedalcyclists to leave the roadway whenever faster-moving traffic approaches. The Court concluded that the statute calls for a fact-bound assessment of reasonableness, taking all relevant considerations into account. The Court held that there may be circumstances under which a factfinder could determine that the "reasonable efforts" a pedalcycle operator must exert include temporarily leaving the roadway. However, the Court rejected the rigid interpretations of both the appellant and the lower courts, emphasizing that the statute does not mandate pedalcyclists to always vacate the roadway for faster-moving traffic.The Supreme Court reversed the Superior Court's order and remanded the case for further proceedings consistent with its opinion, instructing the lower court to reconsider the sufficiency of the evidence using the proper legal standard. View "Commonwealth v. Linton" on Justia Law

In this case, the appellant, Willie James Hardy, was convicted of first-degree murder in 1993 and again in 1996 after being granted a new trial. Hardy has consistently maintained his innocence. In 2020, Hardy filed a petition for post-conviction DNA testing under Pennsylvania's Section 9543.1, seeking to test evidence from his case using modern DNA technology that was not available at the time of his trials. The evidence against Hardy was circumstantial, and previous DNA testing excluded him as a contributor.The Court of Common Pleas of Erie County denied Hardy's petition, reasoning that the request was untimely based on the precedent set by Commonwealth v. Edmiston, and that further testing would not provide substantially more accurate or probative results. The Superior Court affirmed this decision, emphasizing the delay in Hardy's request and the strength of the circumstantial evidence against him.The Supreme Court of Pennsylvania reviewed the case, focusing on three main issues: the timeliness of Hardy's request, the applicability of Section 9543.1(a)(2) regarding previously tested and untested evidence, and whether Hardy presented a prima facie case that DNA testing would establish his actual innocence. The court noted that the 2018 amendments to Section 9543.1 allow for DNA testing "at any time" and authorize retesting with newer technology.The Supreme Court held that Hardy's petition was timely, as the statute permits requests for DNA testing at any time and there was no indication that Hardy's request was intended to cause delay. The court also found that the lower courts erred in their interpretation of Section 9543.1(a)(2), as the statute allows for retesting with newer technology and does not preclude testing of previously untested evidence. Finally, the court concluded that Hardy met the prima facie burden by demonstrating a reasonable possibility that DNA testing could produce exculpatory evidence establishing his actual innocence.The Supreme Court reversed the Superior Court's order and remanded the case for further proceedings consistent with its opinion. View "Commonwealth v. Hardy" on Justia Law