Justia Pennsylvania Supreme Court Opinion Summaries

The Supreme Court of Pennsylvania reviewed a case involving Kevin Dowling, who was convicted of first-degree murder and sentenced to death. Dowling was initially charged with robbery, indecent assault, and attempted rape of Jennifer Myers, who identified him as her assailant. Two days before his trial, Myers was found dead in her art gallery. Dowling was subsequently charged with her murder. At trial, the prosecution argued that Dowling killed Myers to prevent her from testifying against him. The prosecution presented evidence including a video of Dowling’s fabricated alibi, a letter in which he confessed to attacking Myers, and testimony from several witnesses. Dowling was convicted and sentenced to death.Dowling later filed a petition under the Post Conviction Relief Act, alleging that his trial counsel was ineffective for failing to investigate the accuracy of a receipt from a store where a witness claimed to have seen him on the day of the murder. He also claimed that the prosecution violated his due process rights by not disclosing cash register journals from the store, which would have shown that the time on the receipt was correct. The PCRA court granted Dowling a new trial, but the Commonwealth appealed.The Supreme Court of Pennsylvania reversed the PCRA court's decision, concluding that Dowling failed to demonstrate a reasonable probability that the outcome of his trial would have been different had his counsel conducted further investigation or had the prosecution disclosed the register journals. The court also found that the false testimony of a police officer about the time on the receipt could not have affected the judgment of the jury, given the substantial independent evidence incriminating Dowling in Myers’ murder. View "Commonwealth v. Dowling" on Justia Law

The case involves a legal malpractice claim filed by minors N.W.M. and E.M., through their parents, against their former guardian ad litem (GAL), Patrice Langenbach, and her employer, the Defender Association of Philadelphia. The minors alleged that Langenbach acted negligently throughout her representation of them in a dependency matter and a corresponding termination of parental rights matter. The trial court dismissed all claims on grounds of immunity, asserting that Langenbach and the Defender Association were immune from suit under the doctrine of quasi-judicial immunity.On appeal, the Superior Court reversed the trial court's decision, holding that it was not within its authority to extend such immunity to GALs. The Superior Court maintained that it was not its role to make policy decisions or to expand existing legal doctrines, which it considered to be the prerogative of the Supreme Court or the General Assembly.The Supreme Court of Pennsylvania affirmed the Superior Court's decision, concluding that GALs in juvenile dependency cases do not operate as an arm of the court and, therefore, are not entitled to quasi-judicial immunity. The court also clarified that the Superior Court is authorized to address novel legal issues, including those involving policy considerations. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "N.W.M. v. Langenbach" on Justia Law

The Supreme Court of Pennsylvania was asked to clarify the use of hearsay evidence in establishing a prima facie case at a preliminary hearing. The case involved Ronald Harris, who was charged with multiple crimes, including attempted murder. The victim did not appear at the preliminary hearings, and the Commonwealth proceeded with the testimony of two police officers who relayed the victim's out-of-court statements. Harris's counsel objected to the use of hearsay evidence, but the trial court overruled the objections and bound all charges over for trial.Harris filed a motion to quash the charges, arguing that the Commonwealth's case was established solely through hearsay, which he claimed was not legally competent evidence. The trial court granted the motion, and the Commonwealth appealed to the Superior Court, which affirmed the decision. The Superior Court held that all material elements of a criminal offense need to be proved at a preliminary hearing by non-hearsay evidence to avoid violating a defendant's constitutional rights to due process.The Commonwealth appealed to the Supreme Court of Pennsylvania, arguing that the Superior Court's ruling was too broad and that hearsay evidence could be used to establish some elements of the crimes charged. The Supreme Court affirmed the Superior Court's decision but disapproved of its rationale. The Supreme Court held that while hearsay evidence could be used to establish a prima facie case that an offense has been committed, it could not be used alone to prove a prima facie case as to the defendant's identity. The court clarified that the Commonwealth must produce some non-hearsay or admissible hearsay evidence to sustain its prima facie burden as to the defendant's identity. View "Commonwealth v. Harris" on Justia Law

The case involves a dispute between Stewart Kramer and Valerie Concinello (Parents) and Nationwide Property and Casualty Insurance Company (Nationwide) over the interpretation of their homeowners insurance policy. The dispute arose after the fatal drug overdose of Michael T. Murray, Jr. (Decedent) at Parents' home. The administrator of Decedent's estate sued Parents and their son, Adam Kramer, for wrongful death and survival actions. Parents sought coverage under their insurance policy with Nationwide, but Nationwide denied coverage based on a controlled substance exclusion in the policy. Parents then filed a declaratory judgment action, and the trial court ordered Nationwide to defend Parents.The Superior Court affirmed the trial court's decision but based its ruling on a different interpretation of the policy. The Superior Court concluded that the policy's controlled substance exclusion applied to the bodily injury claims in the underlying lawsuit but did not apply to emotional distress damages claimed in the wrongful death action.The Supreme Court of Pennsylvania reversed the Superior Court's decision. The Supreme Court held that the Superior Court's interpretation that Nationwide was potentially required to pay out for emotional and mental distress damages was contrary to the unambiguous provisions of the policy and erroneous as a matter of law. The Supreme Court concluded that Nationwide had no duty to defend the underlying lawsuit because emotional and mental distress damages in the wrongful death claims were not bodily injuries under the policy. View "Kramer v. Nationwide Insurance" on Justia Law

The case involves the Pennsylvania Public Utility Commission (PUC) and the City of Lancaster, Borough of Carlisle, and Borough of Columbia (collectively referred to as the Municipalities). The dispute centers around Section 59.18 of the PUC’s regulations, which gives natural gas distribution companies (NGDCs) the authority to determine the location of gas meters in historic districts. The Municipalities argued that this regulation violates Article II, Section 1 of the Pennsylvania Constitution, which vests legislative power in the General Assembly, not in private entities like NGDCs.The Commonwealth Court agreed with the Municipalities, concluding that Section 59.18 unlawfully delegates legislative authority to NGDCs without providing adequate standards to guide their decisions. The court therefore declared Section 59.18 unenforceable.The PUC appealed this decision to the Supreme Court of Pennsylvania. The PUC argued that Section 59.18 does not delegate legislative power to NGDCs, but rather is a regulatory act under the PUC’s administrative authority. The PUC also contended that the Commonwealth Court failed to consider the safety issues related to meter placement, which is the primary concern of the regulation.The Supreme Court of Pennsylvania reversed the decision of the Commonwealth Court. The court found that the General Assembly never enacted a statute giving the PUC legislative authority to determine the location of gas meters in historic districts. Therefore, the PUC could not have unlawfully delegated this authority to NGDCs. The court concluded that the Municipalities' disagreement with the PUC's regulation does not amount to a constitutional violation. The case was remanded to the Commonwealth Court for further proceedings. View "City of Lancaster v. PUC" on Justia Law

The case involves Lamarcus Eugene Drayton, who was charged with multiple counts of sexual assault against his nephew. The case proceeded to a jury trial, where Drayton was found guilty on all charges and sentenced to an aggregate term of 10 to 20 years' imprisonment, followed by five years' probation. Drayton appealed, asserting that the verdict was against the weight of the evidence, and that the trial court erred when it excluded an alleged prior inconsistent statement by the victim. The Superior Court affirmed the judgment of sentence, and Drayton did not seek further review.Drayton later filed a petition under the Post Conviction Relief Act (PCRA), asserting that his trial counsel was ineffective for failing to object when the court sent written instructions to the jury in violation of Pennsylvania Rule of Criminal Procedure 646, and for failing to call three witnesses whom Drayton claimed would have testified that he had no opportunity to commit the sexual offenses. The PCRA court dismissed Drayton’s petition, and the Superior Court affirmed the dismissal.The Supreme Court of Pennsylvania granted review to consider whether trial counsel’s failure to object, when a trial court provides certain written instructions to the jury during deliberations in contravention of Pennsylvania Rule of Criminal Procedure 646, constitutes ineffective assistance of counsel per se such that a PCRA petitioner need not establish prejudice in order to obtain relief. The court held that counsel’s failure to object to a Rule 646 violation is not one of the limited bases establishing ineffectiveness per se. Accordingly, the court affirmed the decision of the lower courts. View "Commonwealth v. Drayton" on Justia Law

In this case, the plaintiff, Beverly Ferraro, slipped and fell at a Burger King restaurant in Butler County, Pennsylvania, and filed a negligence lawsuit against the restaurant's operators. Ferraro filed her complaint within the two-year statute of limitations for negligence actions. However, she encountered difficulties in serving the complaint to the defendants, Patterson-Erie Corporation D/B/A Burger King and Burger King Corporation, due to issues with the Sheriff's service and the COVID-19 pandemic. Ferraro eventually served the complaint through a private process server and later reinstated the complaint and served it through the Sheriff, but this occurred after the original statute of limitations period had elapsed.The defendants argued that the action was barred by the statute of limitations because Ferraro did not make a good faith effort to serve them in a timely manner. The trial court denied the defendants' motion for judgment on the pleadings, and the Superior Court affirmed this decision. The defendants appealed to the Supreme Court of Pennsylvania, arguing that the lower courts' conclusions conflicted with previous court rulings on the issue of timely service of process.The Supreme Court of Pennsylvania reversed the order of the Superior Court. The court held that Ferraro failed to meet her burden of demonstrating that she made a good faith effort in diligently and timely serving process on the defendants. Therefore, the defendants' informal receipt of actual notice was irrelevant. The court emphasized that plaintiffs cannot opt out of the rules to give notice of the commencement of a lawsuit by informal means. If attempts at service of process are optional for giving such notice, then no plaintiff would be required to rely on the service of process rules to impart notice. View "Ferraro v. Patterson-Erie" on Justia Law

The case involves Earl John and Christine Dwyer, who sued Ameriprise Financial, Inc. for negligent and fraudulent misrepresentation. In 1985, Ameriprise fraudulently and negligently induced the Dwyers to purchase a universal whole life insurance policy by misrepresenting that their quarterly premium payments would remain the same for the life of the policy. The Dwyers surrendered life insurance policies they had purchased from other companies to facilitate this purchase. In reality, if the Dwyers’ premium payment had remained the same, the policy would have lapsed for insufficient funds in 2020.The trial court found Ameriprise guilty of violating Pennsylvania’s Unfair Trade Practices and Consumer Protection Law (CPL) and awarded the Dwyers compensatory damages. However, the court declined to award treble damages under the CPL, reasoning that they would be duplicative of the punitive damages awarded by the jury on the common-law claims. The Superior Court affirmed this decision.The Supreme Court of Pennsylvania disagreed with the lower courts' decisions. The court held that treble damages under the CPL are a separate remedy available to the Dwyers and must be considered by the trial court without regard to a punitive damages award on related common-law claims. The court concluded that nullifying the availability of a statutory award because of a common-law award is not a permissible exercise of discretion. Therefore, the court reversed the order of the Superior Court and remanded the case for reconsideration of damages under the CPL. View "Dwyer v. Ameriprise Financial" on Justia Law

In this appeal, the Pennsylvania State Education Association (PSEA) challenged a resolution issued by the Public School Employees’ Retirement Board (PSERB), which addressed how it intended to apply a statute related to the withdrawal of public school employees from a multi-employer pension system. The Commonwealth Court dismissed PSEA’s action for lack of standing. The court held that PSEA had not shown a substantial, direct, and immediate interest in PSERB’s action or inaction, as PSEA's true dispute was with school district employers over subcontracting, not with PSERB.However, the Supreme Court of Pennsylvania reversed this decision, finding that PSEA did have standing to challenge the resolution. The Supreme Court held that PSEA’s interest in the issue was substantial as it far exceeded the interest of the public at large in the correct application of the statute. The court also found that PSEA’s interest was direct because the resolution was causally connected to the harm PSEA alleged in its ability to effectively negotiate over subcontracting decisions. Additionally, the court found that PSEA’s interest was immediate because the causal connection was real and concrete, not remote or speculative. The court noted that PSEA's averments established a substantial, direct, and immediate interest sufficient to warrant a request for the sort of remedy that a declaratory judgment action seeks—a clarification of the law to resolve a dispute between interested parties over its meaning. Consequently, the Supreme Court of Pennsylvania reversed the Commonwealth Court’s order and remanded the matter to allow PSEA’s action to proceed. View "PSEA v. PSERB" on Justia Law

In this case, the Supreme Court of Pennsylvania was tasked with interpreting the definition of “nudity” as used in 18 Pa.C.S. § 6321. The case involved a minor, T.Q.B., who encouraged another minor, A.D., to lift her shirt during an Instagram live video. A.D., who has an intellectual disability, exposed the bottom portion of her breasts below the nipple area. The rest of A.D.’s breasts, including the nipple, were covered by a bra. T.Q.B. was charged with transmission of sexually explicit images by a minor, a second-degree misdemeanor under 18 Pa.C.S. § 6321(c). T.Q.B. argued that the nudity element of the statute had not been established because the nipple was not exposed.The trial court adjudicated T.Q.B. delinquent, interpreting the statute to cover the exposure of any part of the breast below the nipple. On appeal, the Superior Court affirmed, determining that the term "nudity" in the statute does not require that the nipple must be exposed for the offense to be committed.The Supreme Court of Pennsylvania affirmed the lower courts' decisions. The court found that the language of Section 6321(g) does not require exposure of the nipple to establish the element of nudity. The court held that nudity is sufficiently established where any area below the top of the nipple is visible. The court concluded that the clear language of the statute and the evidence presented at the adjudication hearing established the nudity requirement, and affirmed the Superior Court’s dispositional order finding the evidence sufficient to support T.Q.B.’s adjudication of delinquency. View "In the Int of: T.Q.B., a Minor; Apl of: T.Q.B." on Justia Law