Justia Pennsylvania Supreme Court Opinion Summaries

In this case, jurors could not reach a unanimous verdict on some counts, and the trial court sua sponte declared a mistrial. Defendant Joshua Wardlaw objected to the mistrial, and sought a judgment of acquittal on the unresolved charges. The trial court denied Wardlaw’s motion. Wardlaw filed an interlocutory appeal to the Superior Court, claiming a right to do so pursuant to Pennsylvania Rule of Appellate Procedure 311(a)(6). The Superior Court quashed the appeal, holding that Rule 311(a)(6) did not apply because the trial court’s declaration of a mistrial was not an “award” of a new trial. The Pennsylvania Supreme Court granted Wardlaw’s request for discretionary review to consider whether the Superior Court’s interpretation of Rule 311(a)(6) was erroneous. The Pennsylvania Supreme Court found that Wardlaw did not appeal an order awarding a new trial, and the Superior Court correctly determined that Wardlaw was not entitled to an interlocutory appeal under Pennsylvania Rule of Appellate Procedure 311(a)(6). "One cannot award that which is not sought. Consequently, a new trial is awarded only when the court grants a party’s motion for a new trial. When the new trial flows from the declaration of a mistrial, the court has not awarded a new trial." The Superior Court’s order quashing the appeal was affirmed. View "Pennsylvania v. Wardlaw" on Justia Law

In January 2010, Appellant James Finnecy was sentenced to a maximum term of two years’ imprisonment for unauthorized use of a motor vehicle and theft by unlawful taking, as well as two consecutive terms of eighteen months’ probation for escape, resisting arrest, identity theft, and ten counts of forgery. In October 2011, Appellant was released from custody and placed on probation. He committed multiple probation violations over the next several months and also failed to complete a court supervised drug treatment program. The trial court ultimately revoked Appellant’s probation. In 2014, Appellant was sentenced to twelve to twenty-four months’ imprisonment, to be followed by five years’ probation. Appellant was again released from custody and paroled to a court supervised substance abuse treatment facility. Shortly thereafter, Appellant absconded from parole and committed numerous additional violations of his supervision. As a result, the Commonwealth filed a petition to revoke Appellant’s probation and parole, which was granted. Appellant was sentenced to an aggregate term of twelve and one-half to twenty-five years’ imprisonment. Relevant here, the court found Appellant ineligible for a sentence under the Pennsylvania Recidivism Risk Reduction Act (“RRRI Act”). The issue Appellant's case presented for the Pennsylvania Supreme Court's review centered on whether a single past conviction for violent crime demonstrated “history of present or past violent behavior” for purposes of the RRRI Act, thereby disqualifying an offender from eligibility for a reduced sentence. Before addressing this question, the Court first had to determine whether a trial court’s failure to impose a sentence under the RRRI Act implicated sentencing illegality. The Supreme Court held the trial court’s failure to sentence an eligible offender pursuant to the RRRI Act implicated sentencing illegality. The Court also found that a single prior conviction for a non-enumerated crime demonstrating violent behavior did not qualify as a history of past violent behavior under the Section 4503 of the RRRI Act. Accordingly, the Superior Court judgment was reversed in part and affirmed in part, and the case remanded for further proceedings. View "Pennsylvania v. Finnecy" on Justia Law

Eleanor McLaughlin acquired all oil, gas, and mineral rights underlying two parcels in Watson Township, Warren County, Pennsylvania. In 1985, she leased the oil and gas rights for each parcel to United Land Services. United Land Services in turn assigned the leases to Appellant Mitch-Well Energy, Inc. In 2008, Jack and Zureya McLaughlin sold their interest in the Warrant 3010 to Sheffield Land and Timber Company, which merged into Appellee SLT Holdings, LLC in 2012. During the initial term of the leases, Mitch-Well drilled one well on each lease parcel and produced oil in paying quantities until 1996. Mitch-Well did not drill any additional wells. After 1996, no oil was produced or royalty payments, or delay rental payments made or tendered until 2013. Nor did Mitch-Well tender any minimum payments during that period under either lease. The Pennsylvania Supreme Court granted review to consider the propriety of the Superior Court’s affirmance of the trial court’s grant of partial summary judgment in favor of Appellees in their complaint in equity against Appellant on the grounds of abandonment. Because Appellees had available to them a full and adequate remedy at law, through contract principles generally applicable to oil and gas leases, and through the specific provisions of the subject leases, the Supreme Court concluded it was error to provide recourse through application of the equitable doctrine of abandonment. View "SLT Holdings v. Mitch-Well Energy" on Justia Law

Pittsburgh Logistics Systems, Inc. (“PLS”) was a third-party logistics provider that arranged the shipping of its customers’ freight with selected trucking companies. Beemac Trucking (“Beemac”) was a shipping company that conducted non-exclusive business with PLS. In 2010, PLS and Beemac entered into a one-year Motor Carriage Services Contract (“the Contract”), which automatically renewed on a year to year basis until either party terminated it. The Contract contained both a non-solicitation provision and the no-hire provision. In this appeal, the Pennsylvania Supreme Court considered whether no-hire, or “no poach,” provisions that were ancillary to a services contract between business entities, were enforceable under the laws of the Commonwealth. While the Contract was in force, Beemac hired four PLS employees. PLS sued Beemac, alleging breach of contract, tortious interference with contract, and a violation of the Pennsylvania Uniform Trade Secrets Act. PLS also sued the four former employees, alleging they had breached the non-competition and non-solicitation provisions of their employment contracts. The trial court held the worldwide non-compete clauses in the employees' contracts were “unduly oppressive and cannot be subject to equitable modification.” With respect to the contract between the companies, the trial court held the pertinent no-poach clause was void against public policy. “If additional restrictions to the agreement between employer and employee are rendered unenforceable by a lack of additional consideration, PLS should not be entitled to circumvent that outcome through an agreement with a third party.” Finding no reversible error in the trial court's judgments, the Supreme Court affirmed. View "Pgh. Logistics Systems, Inc. v. Beemac Trucking, et al." on Justia Law

The issue presented for the Pennsylvania Supreme Court's review required the Court to revisit its relatively recent holding that the signature of a registered voter “may not be stricken from a nominating petition solely because the address set forth on the nominating petition is different from the address at which the signer is currently registered to vote.” Following the Court's unanimous decision in In re Vodvarka, 140 A.3d 639 (Pa. 2016), the General Assembly in October of 2019 enacted Act 77, which made significant changes to Pennsylvania’s Election Code, such as the advent of no-excuse mail-in voting. One lesser-known change effected by Act 77 was the amendment of 25 P.S. section 2868, which required a signer of a nominating petition to add certain information. Significantly, only one change was made to the statute by the amendment: the former requirement that a signer add his “residence” was replaced with a new requirement that he add the “address where he is duly registered and enrolled.” After careful review, the Supreme Court concluded this legislative change in statutory text displaced the Court's holding in Vodvarka pertaining to the address requirement. Furthermore, the Court concluded the statute as amended, plainly and unambiguously imposed a mandatory duty on a signer of a nominating petition to add the address where he or she was duly registered and enrolled, and that the failure to comply with this requirement exposes the signature to viable legal challenge. As the Commonwealth Court reached this same conclusion below, the Supreme Court affirmed. View "In Re: Nom. s. of Major, R." on Justia Law

The Pennsylvania Supreme Court granted review to determine whether the attorney-client privilege and the work product doctrine could be invoked by a trustee to prevent the disclosure to a beneficiary of communications between the trustee and counsel pertaining to attorney fees expended from a trust corpus. To reach that issue, the Court had to first address the question of whether the Superior Court erred in disclaiming jurisdiction on the basis that the trial court’s order rejecting the privilege claim was not a collateral order, and immediately reviewable as such. The Supreme Court held unanimously that the Superior Court had immediate appellate jurisdiction to review the privilege question on the merits, and therefore erred in concluding otherwise. As to the privilege issue itself, the Superior Court indicated that, notwithstanding its perceived lack of jurisdiction, there was no evidence by which to substantiate a claim of privilege on the merits, nor any argument presented to the trial court in support thereof. For those reasons, the court was left to conclude that the privilege was unavailable under the circumstances and that the communications at issue were subject to disclosure. The Supreme Court did not reach a consensus on whether the privilege may be invoked in the trust context. Because disclosure would nevertheless result from the competing positions set forth by a majority of Justices, the lower court’s alternative ruling was affirmed by operation of law. View "In Re: Estate of McAleer" on Justia Law

Appellee Anthony Shaw was tried jointly with a co-perpetrator for the 2009 attempted murder of Alex Adebisi. At the pretrial stage, Appellee’s counsel filed a notice of alibi. At trial, only one of two identified alibi witnesses in the notice was called by the defense to testify. During her cross-examination of the testifying witness, the prosecutor referred to the notice of alibi to impeach the alibi's veracity. Defense objected, arguing the notice was not the witness' statement. After the Commonwealth concluded the cross-examination, Appellee’s counsel asked for a sidebar conference and moved for a mistrial. After Appellee was convicted and an unsuccessful direct appeal was concluded, he lodged a petition under the Post Conviction Relief Act, claiming he received ineffective assistance of trial counsel for failing to amend the alibi notice prior to trial to remove the reference to a non-testifying alibi witness. The PCRA court denied relief on the post-conviction petition, Appellee appealed, and the Superior Court reversed and remanded for a new trial. With respect to trial counsel’s performance, the Superior Court found the alibi notice counsel had submitted failed to reflect his own contemporaneous understanding of the circumstances. And although counsel expressed a belief that an alibi witness could not be cross-examined with an alibi notice, the court referenced its own prior decisions which it read for the proposition that “it is well-established that an alibi notice can be used for impeachment purposes.” The Pennsylvania Supreme Court reversed the Superior Court, agreeing with the Commonwealth that the matter should have been remanded to the post-conviction court for Appellee to be afforded the opportunity to create an evidentiary record to meet his burden of demonstrating the ineffectiveness, particularly in terms of the reasonable-basis criterion. "We also find that the Superior Court should have provided the post-conviction court with the opportunity to assess prejudice in the first instance. ... Although certainly it is possible that the jurors relied on the notice to discredit the defense... it is most appropriate for the PCRA court to pass, in the first instance, on whether there is a reasonable probability that the outcome of Appellee's trial would have been different had counsel correctly handled the alibi notice." View "Pennsylvania v. Shaw" on Justia Law

In the pendency of divorce proceedings, Appellee and her husband entered into agreement governing the shared custody of their five-year-old child. Appellee repeatedly and intentionally violated this custody agreement, eventually absconding with the child ultimately to Florida, where the child remained for forty-seven days separated from her father. Appellee claimed the father was abusive, her attempts to secure assistance from the local children and youth agency had been rebuffed, and she had no option but to remove the child from the father’s care. Appellee was apprehended and charged with interference with custody of children. At trial, the Commonwealth presented testimony from the father, a clinical psychologist, a social worker, and a detective to the effect that Appellee’s allegations were false and/or unfounded. Appellee said she had been advised by a nanny the child had disclosed an incident of offensive touching by the father, and that subsequently the child repeatedly made statements to Appellee personally which were indicative of abuse. Appellee also presented the nanny’s corroborative testimony, and her cousin attested the child had apprised her of inappropriate touching too. The Pennsylvania Legislature prescribed that a defendant was innocent of the crime of “interference with custody of children” when he or she believed that intrusive actions were necessary to spare the subject child from danger. Appellee was convicted as charged and sentenced; in post-conviction proceedings, the Superior Court reversed sentence and ordered a new trial. The Commonwealth contended that the belief element of the offense should have been construed to encompass only beliefs that were held reasonably. The Pennsylvania Supreme Court found Commonwealth’s arguments "are too tenuous to be credited." The Superior Court judgment was affirmed. View "Pennsylvania v. H.D." on Justia Law

The issue presented for the Pennsylvania Supreme Court's review centered on whether the Wiretapping and Electronic Surveillance Act made inadmissible a a covertly obtained audio recording of Appellee Beth Ann Mason while she worked as a nanny in the home of the family that employed her. Because Appellee failed to demonstrate that she possessed a justifiable expectation that her oral communications would not be subject to interception by a recording device located in the children’s bedrooms, the Pennsylvania Supreme Court held that the Wiretap Act did not preclude the Commonwealth from introducing these recordings as evidence at Appellee’s trial for allegedly abusing the children in her care. The Supreme Court reversed the Superior Court’s judgment, which held that the trial court properly suppressed the subject audio recording. The matter was remanded for further proceedings. View "Pennsylvania v. Mason" on Justia Law

This appeal concerned the application of the statutory compulsory joinder rules, which generally require a prosecutor to pursue, in a single proceeding, all known charges against a defendant arising from a single criminal episode occurring within the same judicial district, subject to enumerated exceptions. In 2015, as the result of a traffic stop, Appellant Dewitt Johnson was arrested and charged with driving with a suspended license, possession with intent to deliver heroin (“PWID”), and knowing and intentional possession of heroin (“K&I”). Before the Traffic Division of the Municipal Court of Philadelphia, he was found guilty, in absentia, of the summary traffic offense. The Municipal Court’s jurisdiction was capped at criminal offenses punishable by imprisonment for a term of not more than five years; because of this, the Commonwealth pursued the drug offenses in the common pleas court. Appellant moved to dismiss, contending the prosecution was required to try all of the offenses simultaneously, per the compulsory joinder requirements of Section 110 of the Pennsylvania Crimes Code. The Commonwealth conceded it was foreclosed from pursuing the K&I charge, because that crime, like the traffic offense, fell within the Municipal Court’s jurisdiction. Nevertheless, the Commonwealth argued that PWID remained viable, since the Municipal Court had lacked jurisdiction over that offense. In this regard, the Commonwealth invoked Section 112(1) of the Crimes Code, which served as an exception to Section 110’s general prohibition. The Superior Court accepted this argument and affirmed with respect to PWID. The Pennsylvania Supreme Court reversed the Superior Court and remanded the matter for dismissal of the PWID charge: "the Commonwealth must generally assure that known offenses are consolidated at the common pleas level, when they arise out of a single criminal episode and occur in the same judicial district." View "Pennsylvania v. Johnson" on Justia Law