Justia Pennsylvania Supreme Court Opinion Summaries

The Pennsylvania Supreme Court granted discretionary review to determine whether the Commonwealth Court erred in holding appellant Daniel Harmon was disqualified from receiving unemployment compensation benefits pursuant to Section 402.6 of the Unemployment Compensation Law. Appellant was a part-time employee at Brown’s Shop Rite beginning February 14, 2013. By December, he was convicted of driving with a suspended license and sentenced to a term of 60 days’ imprisonment to be served on 30 consecutive weekends, beginning March 14, 2014 and ending August 7, 2014. Appellant’s employment with Brown’s Shop Rite was terminated on March 24, 2014 due to a violation of company policy, which was unrelated to his incarceration. He then filed for benefits and received them for the week ending March 29, 2014 through the week ending July 26, 2014. This period included weeks when appellant was serving his sentence of weekend incarceration. The Supreme Court held appellant was not disqualified from receiving unemployment compensation benefits, and therefore reversed the order of the Commonwealth Court. View "Harmon v. UCBR" on Justia Law

In 2004, the Pennsylvania General Assembly transferred regulatory authority over Philadelphia taxicabs to the Philadelphia Parking Authority (“Authority”) through Act 94. The Act also created a budget submission process for the Authority to follow, and prescribed a formula that the Authority uses to ascertain assessments imposed upon Philadelphia taxicabs. In 2013, the Commonwealth Court found certain portions of Act 94 to be unconstitutional. The General Assembly then enacted Act 64 to cure the constitutional shortcomings identified by the Commonwealth Court. Partial rights taxicab owners in Philadelphia challenged the new scheme on constitutional grounds. The Commonwealth Court granted relief, finding that Subsection 5707(c) of the Parking Authorities Law, 53 Pa.C.S. 5707(c), violated the substantive due process rights of partial rights taxicab owners. Furthermore, the Commonwealth Court found that the budget submission process prescribed in 53 Pa.C.S. sections 5707(a) and 5710 constituted an unconstitutional delegation of legislative power. Upon review, the Pennsylvania Supreme Court concluded the Commonwealth Court erred in both respects: (1) subsection 5707(c) did not impair the substantive due process rights of partial rights taxicab owners; (2) subsections 5707(a) and 5710 did not amount to unconstitutional delegations of legislative power. View "Germantown Cab Co., et al. v. P.P.A." on Justia Law

The issue before the Pennsylvania Supreme Court in this case concerned whether counties could advance common law claims seeking legal redress against telecommunications companies for alleged deficiencies in their administration of fees associated with 911 emergency communication services. The Supreme Court concluded the Legislature balanced counties’ interests against those of other co-participants enlisted under the 911 Act and provided sufficient indicia evincing its intention to centralize enforcement authority in the relevant state agency. "Although we realize that the County may have been disadvantaged by PEMA’s apparent failure to act, this unfortunate circumstance does not control the judicial construction of a legislative enactment." Thus, the Court reversed the Commonwealth Court, and reinstated the order of the court of common pleas. View "Co. of Butler v. Centurylink, et al.." on Justia Law

Appellant Anthony Machicote argued his sentence was illegal because he was subject to a potential sentence of life without parole, and prior to imposing his sentence, the trial court did not consider the factors enumerated in Miller v. Alabama, 567 U.S. 460 (2012), as adopted by the Pennsylvania Supreme Court in Commonwealth v. Batts, 66 A.3d 286 (Pa. 2013) (Batts I) and Commonwealth v. Batts (Batts II), 163 A.3d 410 (Pa. 2017). In 2003, Appellant was 17 years old and a resident at George Junior Republic, a residential treatment facility for at-risk youth. Appellant and a co-resident, Jeremy Melvin, devised a plan to subdue a night supervisor at the facility in order to escape. Appellant called the night supervisor, Wayne Urey, Jr., to his room. Melvin, who was hiding, attacked Urey from behind, put him in a chokehold, and brought him to the ground. Appellant and Melvin bound and gagged Urey, and proceeded to steal his keys, wallet, and truck. Appellant and Melvin escaped, and Urey ultimately died of suffocation. Appellant and Melvin turned themselves in later that same day. Appellant was charged with homicide, robbery, and related offenses. Appellant pled guilty to second-degree murder and the remaining charges were dismissed. Appellant was sentenced to life without the possibility of parole. Appellant did not appeal his sentence. The Superior Court concluded that Appellant’s challenge to his sentence was moot because he was ultimately not sentenced to life without the possibility of parole. The Supreme Court concluded the issue was not moot, and the trial court erred when it failed to consider the Miller factors on the record when it resentenced Appellant. View "Pennsylvania v. Machicote" on Justia Law

James and Beryl Wicker signed a mortgage agreement for their residence in Punxsutawney, Pennsylvania in favor of Countrywide Bank, FSB (Countrywide) in February 2008. The mortgage agreement indicated that Mortgage Electronic Registration Systems, Inc. (MERS) would act as nominee for Countrywide and its successors and assigns and was designated as the mortgagee. In an assignment of mortgage recorded in November 2011, MERS, as nominee for Countrywide, assigned the mortgage to Bank of America. In May 2012, Bank of America filed a mortgage foreclosure action against the Wickers alleging that the Wickers defaulted on their mortgage as of September 1, 2010. It further averred that it had provided the Wickers with the statutorily required foreclosure notice on September 21, 2011. Bank of America then moved for summary judgment, which the trial court granted in part and denied in part. In so doing, the trial court narrowed the issues for trial to determining whether Bank of America had provided proof of: (1) the required foreclosure notices; (2) the date of default; and (3) the amount of indebtedness. The Pennsylvania Supreme Court granted review to consider the application of Pennsylvania’s business records exception to the rule against hearsay, pursuant to Pennsylvania Rule of Evidence 803(6) and the Uniform Business Records as Evidence Act, 42 Pa.C.S. 6108. The parties agreed that then-current Pennsylvania precedent allowed a records custodian to authenticate documents even if the witness did not personally record the specific information in the documents. The parties disagreed, however, as to whether a records custodian could lay a foundation for documents incorporated into the files of the custodian’s employer when the information in the documents was recorded by a third party, a process which was allowed under the similar but not identical Federal Rule of Evidence 803(6), pursuant to the so-called adopted business records doctrine. The Supreme Court affirmed the Superior Court in concluding that the trial court did not abuse its discretion in allowing the testimony of the records custodian and admitting the documents under the facts of this case. View "Bayview Loan v. Wicker" on Justia Law

The Commonwealth Court dismissed appellant Bert Hudson's petition for review, in which he argued he was entitled to be considered for parole after having received a life sentence for second-degree murder. In 1978, Appellant burglarized a home and shot two individuals with a handgun, killing one of them. The court imposed a sentence of life imprisonment on the murder conviction, and a separate, consecutive sentence of fifteen-to-thirty years on the other convictions, to be served first. Appellant completed this latter sentence in 2009, and was serving his life sentence for second-degree murder. In 2017, Appellant applied for parole. The Pennsylvania Board of Probation and Parole (the “Board”) denied his application on the basis that his life sentence had no minimum date. After exhausting administrative remedies, Appellant filed a petition for review in the Commonwealth Court’s original jurisdiction, contending that because the common pleas court had failed to specify a minimum sentence, he should be deemed to have an implied minimum of one day of confinement. Appellant thus asked the court to direct the Board to review him for parole. The Pennsylvania Supreme Court concluded the Board lacked the power to release on parole an inmate servicing a mandatory life sentence for second-degree murder. That being the case, the Commonwealth Court correctly sustained the Board’s demurrer and dismissed the petition for review. View "Hudson v. Pa. Bd. of Probation & Parole" on Justia Law

This appeal addressed the meaning and effect of section 5513 of Pennsylvania’s Probate Estates and Fiduciaries Code, which related to the appointment of emergency guardians. The Superior Court held that an emergency order for a guardianship of an estate automatically expired after thirty days. The parties did not challenge the vitality of the emergency guardianship in the trial court. Nor did either party raise any claim before the Superior Court regarding the termination of the guardianship order or the appropriate interpretation of the Termination Provisions. In addressing an issue actually raised on appeal, the Superior Court further held that an individual subject to emergency guardianship is not incapacitated and is not precluded from making decisions about his property even when his guardian has been ordered by the court to do so on his behalf. The Pennsylvania Supreme Court determined it was error for the Superior Court to consider and opine on the validity of the order at issue in the underlying case on the basis of the Termination Provisions. Moreover, the Court held that an individual under the protection of an emergency guardianship order has been determined to lack sufficient capacity to make certain decisions and that the extent of his decision-making capacity depends on the specific “powers, duties and liabilities” afforded to the guardian by court order. The Supreme Court therefore vacated the Superior Court’s decision and remanded the matter to that court for further proceedings. View "Gavin v. Loeffelbein" on Justia Law

On May 16, 2017, by write-in vote, Christine Rossi won the Republican nomination for Tax Collector of Nether Providence Township (“the Township”). On June 2, 2017, the Delaware County Bureau of Elections (“the Bureau”) notified Rossi that she was certified as the Republican nominee. The Bureau instructed Rossi to submit a Statement of Financial Interests ("SOFI") to the Bureau and to the Township by June 30, 2017, in order to have her name appear on the November 2017 general election ballot. On June 30, 2017, Rossi filed her SOFI with the Bureau, but failed to file it with the Township. On September 6, 2017, based upon a Right-to-Know Law request submitted to the Township, Christine Reuther and Ani Marie Diakatos (collectively, “Objectors”) discovered that Rossi had not filed her SOFI with the Township. On September 13, 2017, Objectors filed an emergency petition for relief to the Court of Common Pleas, stressing that Subsection 15.3(e) of the State Ethics Commission’s regulations required write-in candidates to file their SOFIs with the appropriate authorities within thirty days of the certification of the election results. Because Rossi failed to file her SOFI with the Township within that period of time, Objectors asserted that, pursuant to Subsection 1104(b)(3) of the Ethics Act, her failure constituted a fatal defect to her candidacy, and her name was required to be stricken from the general election ballot. On September 14, 2017, Rossi filed her SOFI with the Township. Because the Public Official and Employee Ethics Act (“Ethics Act”) imposed this consequence only upon candidates who petition to appear on the ballot, the Pennsylvania Supreme Court held that it is inapplicable to write-in candidates. Therefore, the Court affirmed the order of the Commonwealth Court. View "Reuther v. Delaware County Bureau of Elections" on Justia Law

In 2015, the Pennsylvania State Police filed a criminal complaint against appellant Robert Gill, Jr., charging him with, inter alia, burglary, theft by unlawful taking, receiving stolen property, and criminal trespass. The issue his appeal presented for the Pennsylvania Supreme Court's review centered on whether the Superior Court properly applied the “abuse of discretion” standard of review when, in a published opinion, it reversed a trial court order that granted Gill's motion in limine to admit evidence of a subsequent similar crime committed by another individual. The Supreme Court concluded the Superior Court misapplied this standard of review. Consequently, it reversed in part and vacated in part the Superior Court’s judgment and remanded to the Superior Court with instructions. View "Pennsylvania v. Gill" on Justia Law

During a routine patrol, Officer James Falconio of the Pleasant Hills Police Department observed a white Dodge Dart enter a parking lot that served two closed businesses – a hobby store and a pizza shop – and drive behind the buildings. Believing that the vehicle may have made a wrong turn, Officer Falconio waited and watched for the vehicle to exit the parking lot. When it did not, the officer drove into the parking lot and behind the buildings to “simply check[] to see why a car drove behind two dark, closed businesses at [three] o’clock in the morning,” as he recognized the potential for “drug activity or an attempted burglary.” When he arrived behind the buildings, Officer Falconio observed a white Dodge Dart parked behind the pizza shop. Officer Falconio found the driver inside, appellant Edward Adams, observing the driver had glassy eyes and slurred speech. The officer requested that Adams perform several field sobriety tests, and although “argumentative,” Adams complied and failed the tests. Officer Falconio then placed Adams under arrest for suspicion of driving under the influence of alcohol. He transported Adams to Jefferson Regional Hospital, where Adams consented to a blood draw. Adams declined to provide the name of a person who could pick him up, and so he remained in jail until police believed he was sober enough to leave on his own, which occurred several hours later. This discretionary appeal presented for the Pennsylvania Supreme Court's review the the question of when an interaction between an ordinary citizen and a law enforcement official ripens from a mere encounter, requiring no level of suspicion, to an investigative detention, which must be supported by reasonable suspicion that criminal activity is afoot. The Court concluded, based on longstanding precedent, that the line is crossed when a reasonable person would not feel free to leave, and that a detention effectuated by police in the interest of officer safety is impermissible in the absence of reasonable suspicion of criminal activity. The Court concluded Officer Falconio subjected Adams to an investigative detention unsupported by reasonable suspicion of criminal activity. The trial court erred by denying Adams’ suppression motion on that basis and the Superior Court erred in its affirmance of that decision. View "Pennsylvania v. Adams" on Justia Law