Justia Pennsylvania Supreme Court Opinion Summaries

Cosmo DiNardo (“DiNardo”) suffered from bipolar disorder, schizophrenia, and schizoaffective disorder, and, as a result, exhibited psychosis, grandiose speech, suicidal ideation, as well as homicidal ideation and violent behavior. He confessed to killing four individuals, and pleaded guilty to four counts of first-degree murder. He subsequently filed a complaint against his treating psychiatrist and health care providers, claiming that his criminal conduct was the result of his psychiatrist’s grossly negligent treatment, and sought compensatory damages, indemnification for judgments levied against him by his victims’ families, and counsel fees. In an appeal by allowance, the issue presented for the Pennsylvania Supreme Court's consideration was whether the “no felony conviction recovery” rule precluded DiNardo’s cause of action. Because the Court found the rule barred the medical malpractice claims at issue in this appeal, it affirmed the order of the Superior Court. View "DiNardo v. Kohler, et al." on Justia Law

In this case, a Pennsylvania trial court transferred venue based on a determination the corporate defendant did not regularly conduct business in Philadelphia County because only 0.005% of the company’s total national revenue was derived from that county. On appeal, the Superior Court reversed, holding the trial court abused its discretion in transferring venue. The Pennsylvania Supreme Court granted discretionary review to evaluate the Superior Court’s determination, and affirmed: venue was proper in Philadelphia County. View "Hangey, et al. v. Husqvarna, et al." on Justia Law

The issue this case presented for the Pennsylvania Supreme Court's review was whether the Commonwealth Court abused its discretion in ordering Appellants, Eric Sloss and Sandor Zelekovitz, (“Objectors”) to pay the counsel fees of Appellee Michael Doyle, a candidate for the Republican nomination for Representative of Pennsylvania’s 12th Congressional District (“Candidate”) in the May 17, 2022 Primary Election. These fees were incurred during the litigation of Objectors’ petition to set aside Candidate’s nominating petitions for lack of a sufficient number of legally valid signatures from Republican electors. After review, the Supreme Court concluded the Commonwealth Court abused its discretion in ordering Objectors to pay such fees. The Court therefore reversed its order in that respect. View "In Re: Nom. Michael Doyle" on Justia Law

The Commonwealth of Pennsylvania, Department of Transportation; Yassmin Gramian, individually; Michael Carroll, in his capacity as Acting Secretary of the Department of Transportation; and Melissa Batula, P.E., individually and in her capacity as Acting Executive Deputy Secretary for the Department of Transportation (collectively, PennDOT) appealed a Commonwealth Court order that denied, in part, and granted, in part, a “Motion for Adjudication of Civil Contempt or in the Alternative . . . Motion for a Preliminary Injunction” (PI Motion) filed by Glenn O. Hawbaker, Inc. (Hawbaker). Pertinent here, the Commonwealth Court’s order preliminarily enjoined PennDOT from proceeding with any action for the debarment of Hawbaker as a prequalified bidder on PennDOT construction contracts based upon criminal charges filed against Hawbaker or Hawbaker’s subsequent entry of a corporate nolo contendere plea to those criminal charges. After review, the Supreme Court agreed with PennDOT that the Commonwealth Court erred in exercising equitable jurisdiction to award Hawbaker preliminary injunctive relief in this matter. Accordingly, the Court reversed the Commonwealth Court order, and remand the matter for further proceedings. View "Glenn Hawbaker, Inc. v. PennDOT" on Justia Law

Defendant-appellant Jessica Rizor petitioned for post conviction relief, arguing her trial counsel provided inadequate advice with regard to a plea offer. According to Rizor, her trial counsel’s inadequate advice led her to proceed to a trial - where her life sentence was all but assured - in lieu of accepting a plea offer that would have resulted in a five and a half to thirty-year sentence. The Superior Court agreed and reversed the PCRA court order denying relief and remanded “for a new trial or entry of a plea.” The Commonwealth petitioned for the Pennsylvania Supreme Court's review, arguing that the PCRA court correctly denied relief and that the Superior Court’s decision rested on a faulty foundation which assumed that trial counsel provided ineffective assistance rather than presuming the opposite. The Commonwealth further believed the Superior Court improperly ignored the PCRA court’s credibility determinations. After review, the Supreme Court agreed with the Commonwealth, finding that the Superior Court erred in reversing the PCRA court order denying relief where Rizor failed to establish a reasonable probability that but for counsel’s alleged deficient advice, she would have accepted the plea deal. The Superior Court's judgment was vacated and the case remanded to address Rizor's remaining challenges. View "Pennsylvania v. Rizor" on Justia Law

At approximately 5:30 p.m. on December 15, 2018, Alyssa Houston, Heather Lamb, and Lamb’s eight-year-old daughter exited Lamb’s house and departed in Lamb’s vehicle to go shopping. Houston noticed that Appellant Angelo Weeden was following directly behind Lamb’s vehicle in his Volkswagen Jetta, tailing them down a narrow street. When Lamb drove off of the main road to enter a residential area in the North Side neighborhood of the City of Pittsburgh (the “City”), Appellant pulled around the driver’s side of her vehicle and blocked its forward movement. Appellant then exited his vehicle and approached the passenger side of Lamb’s car, prompting Houston, who was sitting in the passenger-side front seat, to lock the car door. As Appellant aggressively attempted to pull the passenger-side front door open, Lamb’s daughter yelled “gun,” and Lamb quickly placed her car in reverse, backed around Appellant’s vehicle, and began to drive away. Simultaneously, the occupants of Lamb’s vehicle heard four gunshots, two of which struck Lamb’s vehicle on the rear passenger side. Consequently, Lamb drove to the police station, and she and Houston reported the incident. The following day, Appellant was arrested, and the Commonwealth charged him with one count each of aggravated assault, person not to possess a firearm, carrying a firearm without a license, and propulsion of missiles into an occupied vehicle, and three counts of recklessly endangering another person. At trial, a veteran detective testified about the police department’s use of a gunfire detection program, “ShotSpotter.” The issue this case presented for the Pennsylvania Supreme Court’s review was whether a printed summary created by a computerized system, “ShotSpotter,” which contemporaneously collected data regarding potential gunshots and transmitted the same to the subscribing police force, fell within the purview of the Confrontation Clause when used as evidence in the course of a criminal prosecution. The Court concluded that, under the circumstances presented, the admission of the document did not run afoul of Appellant’s rights under the Confrontation Clause. Accordingly, his conviction was affirmed. View "Pennsylvania v. Weeden" on Justia Law

The Commonwealth appealed a Post-Conviction Relief Act (PCRA) court’s grant of relief to Appellee Michael Conforti, vacating his convictions for murder of the first degree, kidnapping, rape, criminal conspiracy to commit murder, criminal conspiracy to commit rape and criminal conspiracy to commit kidnapping and his resulting death sentence. Conforti’s convictions and sentence stem from the 1990 kidnapping, rape, and murder of Kathleen Harbison. The Pennsylvania Supreme Court affirmed the PCRA court’s determination that the Commonwealth committed a Brady violation by failing to disclose another accused perpetrator, James Bellman’s psychological reports. Bellman testified against Conforti at Conforti's trial. Relevant here, immediately prior to a November 2021 PCRA hearing, the Commonwealth provided Conforti’s counsel with two mental health reports relating to Bellman from 1980. The reports were created as part of a criminal case Bellman had in Wayne County in 1979. Bellman was then evaluated by two psychiatrists, both of whom prepared written reports diagnosing Bellman as a sociopath. The PCRA court found that the reports “remained in the possession of the Commonwealth and only surfaced” during the PCRA hearing on November 5, 2021. As such, according to the PCRA court, none of the evidence of Bellman’s mental health issues was disclosed to Conforti’s defense counsel during trial. The PCRA court found that the information contained in the reports would have been extremely damaging to Bellman’s credibility. The Pennsylvania Supreme Court affirmed the PCRA court's determination the Commonwealth committed a Brady violation by failing to disclose Bellman's psychological reports: "because of the importance of Bellman’s testimony, if those reports were properly disclosed there is a reasonable probability the result of Conforti’s trial would have been different, as it could have led the jury to discredit Bellman’s testimony and given more credit to Conforti’s testimony that he was not involved in Ms. Harbison’s murder. Conforti was prejudiced by the Commonwealth’s nondisclosure." View "Pennsylvania v. Conforti" on Justia Law

At issue in this appeal was whether an order determining that grandparents had standing under Section 5325(3) of the Domestic Relations Code, 23 Pa. C.S. § 5325(3), to file and pursue an action for partial physical custody of their grandchildren was a collateral order appealable as of right under Pennsylvania Rule of Appellate Procedure 313, Pa.R.A.P. 313 (Rule 313). In August 2017, A.L.R. (Father) and T.A.D-R. (Mother) (collectively, Parents) began residing with J.C.D., III, and A.M.D. (collectively, Grandparents), Mother’s parents, at their home in York County, Pennsylvania. While Parents resided at Grandparents’ home, the Children were born to Parents: E.J.R. and A.L.R. Parents and the Children resided with Grandparents until May 2022, when, following a disagreement, Parents moved out of Grandparents’ home with the Children. Thereafter, Grandparents filed a complaint seeking shared legal and partial physical custody of the Children. Parents filed preliminary objections, alleging, inter alia, that Grandparents lacked standing to pursue an action for custody of the Children. The trial court found: (1) Parents and Children lived in the same home as Grandparents for approximately five years; (2) during that time, Grandparents were not raising the Children and did not stand in loco parentis to the Children and helped Parents with the Children as grandparents and as people sharing living quarters typically do; and (3) Grandparents filed their custody complaint within six months of when Parents removed the Children from Grandparents’ home. Based on these findings, the trial court entered an order concluding that Grandparents did not have standing to file and pursue an action for shared legal and partial physical custody of the Children. After reconsideration, the trial court entered a second order determining the Grandparents did have standing to file and pursue their action for partial custody of the Children. The Pennsylvania Supreme Court held that such an order was not a collateral order, and, therefore, it affirmed the Superior Court’s order quashing this appeal. View "A.M.D., et al. v. A.L.R, et al." on Justia Law

The Pennsylvania Supreme Court granted appeal in this matter to consider whether the Superior Court erred in holding that a trial court lacked jurisdiction to correct a patent and obvious error in a sentencing order when the defendant’s request for correction was filed outside the time limitations of the Post Conviction Relief Act (“PCRA”). In November 1994, Appellant Rodney McGee fatally assaulted Barry Williams. In 1996, Appellant entered into a negotiated guilty plea multiple accounts for acts against multiple people; court stated that Appellant’s aggregate sentence for all of the offenses was 32 1⁄2 to 65 years. On the same day that Appellant entered his plea and the trial court orally imposed the above sentence, the trial court issued a three-page typed document titled “Order” (“typed sentencing order”) that was inconsistent with what the court orally imposed on the record. Decades later, on June 3, 2020, Appellant filed a pro se PCRA petition, and counsel was appointed. On August 5, 2020, Appellant filed a “Motion to Correct Illegal Sentence” arguing that there was an obvious incompatibility between the two orders. Finding that the orders in question were “patently erroneous” and “contrary to common sense,” the trial court concluded that amendment of the orders was proper, as the time limits of the PCRA did not apply. The Commonwealth appealed the trial court’s decision to the Superior Court, asserting that the trial court did not have jurisdiction to entertain Appellant’s Motion because the underlying claim was cognizable under the PCRA, and had been filed outside the PCRA’s jurisdictional time constraints. In a unanimous memorandum opinion, the Superior Court reversed. The Pennsylvania Supreme Court affirmed, finding no "patent and obvious error" in the trial court's sentencing orders. The Court did not reach the question of whether a trial court’s inherent authority to correct patent and obvious errors in the record is subject to the time limitations of the PCRA. View "Pennsylvania v. McGee" on Justia Law

Appellant Kevin Jackson appealed a superior court judgment which vacated a pretrial order of the Court of Common Pleas of Philadelphia County (suppression court) and remanded the matter for further proceedings. The suppression court granted Jackson’s motion to suppress evidence recovered after a police officer detained Jackson via what was known as a Terry stop. While the suppression court concluded that the officer lacked the requisite reasonable suspicion to detain Jackson, the superior court reached the opposite conclusion. The superior court's judgment was affirmed by operation of law because the Pennsylvania Supreme Court was evenly divided. The opinion in support of affirmance agreed with the superior court's conclusion that the police officer had reasonable suspicion to detain Jackson under the particular facts of this case. The opinion in support of reversal noted that it was "critical that courts and practitioners in this area of the law be cognizant of the burden that rests with the Commonwealth to justify a warrantless search or seizure when it seeks to do so based upon a 'high-crime area;' ... If we assume for the purpose of analysis that the Commonwealth established with empirical evidence that the area where Jackson was stopped constituted an area known for disproportionately regular gun violence, that evidence would not be relevant because it does not tend to make it more probable that Jackson was engaged in gun violence. Contrary to the Commonwealth’s argument, the Fourth Amendment requires the government to explain how reasonable suspicion relates to the individual’s conduct taking place in the location or area, for instance, by showing that his conduct was unique and, therefore, suspicious." View "Commonwealth v. Jackson, K., Aplt." on Justia Law