Justia Pennsylvania Supreme Court Opinion Summaries

In a capital post-conviction appeal, Appellant Michael Pruitt raised six challenges, several of which fell within the category of the claims deemed to have been abandoned by the PCRA court. In 2003, Appellant forcibly entered the home of Greta Gougler, where he robbed, raped, and murdered her. Appellant was arrested, tried, and convicted for first -degree murder, rape, robbery, and other offenses, and a jury returned a death verdict in a capital sentencing proceeding. On direct appeal, the Pennsylvania Supreme Court affirmed. In 2009, Appellant brought these proceedings under the Post Conviction Relief Act (the "PCRA"). The post -conviction court conducted a series of evidentiary hearings, throughout which Appellant was represented by the members of the Federal Community Defender Office. Later, per Appellant's request, those attorneys were removed from the representation and new counsel was appointed in their place. In 2015, Appellant submitted a request to proceed pro se. The PCRA court scheduled a proceeding, at which Appellant agreed to continue to be represented by counsel but was deemed by the court to have "knowingly, intelligently and voluntarily abandon[ed] any issues raised by prior PCRA counsel and/or [current counsel] that are not contained in [a] memorandum in support of the PCRA relief petition filed this date[.]" The PCRA court subsequently denied relief on the remaining claims for relief. This appeal followed. The Supreme Court concluded the record supported the PCRA court's determination that Appellant abandoned the six claims at issue here, and affirmed the court's subsequent order. View "Pennsylvania v. Pruitt" on Justia Law

Appellant Leon Mills challenged a superior court decision to overturn a county court’s finding of a violation of Rule of Criminal Procedure 600 that he receive a prompt trial. The Rule requires that trial commence within 365 days from the date the criminal complaint is filed. Delays at any stage of the proceedings caused by the Commonwealth when it fails to exercise due diligence count in the 365-day tally. On June 6, 2011, the Commonwealth filed a complaint against Appellant charging him with a series of crimes arising out of a drive -by shooting, including attempted murder and aggravated assault. At a status meeting on March 20, 2012, however, per the Commonwealth's request, trial was continued. Trial was rescheduled to September 10, 2012. The outcome of the dismissal motion turned on whether or not 174 days was to be included or excluded in the 365 -day calculation. The common pleas court enforced the rule's main directive, and dismissed. Upon review, the Pennsylvania Supreme Court agreed with Appellant that time attributable to the normal progression of a case simply was not "delay" for purposes of Rule 600, and reinstated the dismissal order. View "Pennsylvania v. Mills" on Justia Law

SugarHouse HSP Gaming ("SugarHouse"), the holder of a Category 2 slot machine license for a casino it operated in Philadelphia, and Market East Associates, L.P. ("Market East"), an unsuccessful applicant for the Category 2 license awarded to Stadium Casino, LLC (“Stadium”), both filed petitions for review ofa Supplemental Adjudication issued by the Pennsylvania Gaming Control Board, in which the Board awarded the last remaining Category 2 license. After careful consideration, the Supreme Court dismissed SugarHouse's petition for review, finding it was not entitled to intervene in the proceedings on remand. In Market East's petition for review, the Supreme Court affirmed the Board's determination that Watche Manoukian, an individual who is an affiliate of Stadium, was not eligible to apply for a Category 1 slot machine license at the time of Stadium's application for its Category 2 license, and, thus, that Section 1304(a)(1) of the Gaming Act would not be violated by the issuance of a Category 2 license to Stadium. However, the Court reversed the Board's determination of what constitutes a "financial interest" as that term was used in Section 1330, and defined that term in this opinion. Because the Board admitted that it did not determine the nature of the specific "equity infusion" Manoukian would supply post-licensure to the trust which has an ownership interest in Stadium, the Court could not affirm the Board's conclusion that Manoukian would not be in violation of Section 1330's 33.3% limit on the possession of a financial interest in a Category 2 slot machine licensee by another slot machine licensee. Thus, the Court again remanded this case for further proceedings. View "Market East Assoc. v. PA Gaming Control Bd." on Justia Law

The issue before the Pennsylvania Supreme Court in this matter was whether a recently terminated employee was an "employee" and, thus, entitled to inspect her personnel file, according to the Inspection of Employment Records Law ("the Personnel Files Act" or "the Act"). Reading the Personnel Files Act according to its plain terms, the Court concluded that former employees, who were not laid off with re-employment rights and who are not on a leave of absence, have no right to access their personnel files pursuant to the Act, regardless of how quickly following termination they request to do so. The Court reversed the contrary holding of the Commonwealth Court. View "Thomas Jefferson Univ Hosp v. Dept of Lab. & Ind." on Justia Law

At issue in this case was the ownership and use of certain undesignated property and the road that ran the length of a peninsula jutting into Lake Meade, the man-made lake at the heart of a planned community. Property owners complained about loitering and trespassing, and accused their governing homeowners association (HOA) of not enforcing community rules to encourage the bad behavior. The property owners took the HOA to court in a quiet title action to settle ownership over the undesignated property, specifically that they owned the property at issue, that the HOA asserted wrongful possession over the property at issue, and that the HOA intentionally and unreasonably allowed trespass and loitering. The Pennsylvania Supreme Court affirmed in part, and reversed in part, finding that the property owners have an easement across the property at issue, like the other owners in the community. “Although the Superior Court seemed skeptical about the complained-of uses of the disputed property, it evidently recognized that it would be premature to venture a legal opinion on that subject.” The Supreme Court reversed the superior court under directing the entry of judgment in the Starlings’ favor on their claim for injunctive relief regarding the use of disputed property, as well as its reversal of the trial court’s determination that the HOA did not own the property in fee simple subject to Subdivision owners’ access easements and any other established rights-of-way. View "Starling v. Lake Meade Prop." on Justia Law

Petitioner challenged as unconstitutional certain restrictions imposed upon attorneys who were employed by the Pennsylvania Gaming Control Board (Board), and sought declaratory and injunctive relief. The Board filed preliminary objections, asserting petitioner lacked standing to pursue her claim, her claim was not yet ripe, and in any event, her claim failed on the merits. The Pennsylvania Supreme Court overruled the Board’s preliminary objections as to standing and ripeness, but nevertheless concluded petitioner was not entitled to relief on the merits as the restrictions included in the Gaming Act were constitutionally sound. View "Yocum v. PA Gaming Control Board" on Justia Law

Appellee was charged with a single count of possession with intent to distribute, or possession, of a “designer drug,” a substance similar to a scheduled controlled substance, not the same. The trial court here determined experts have been unable to reach an agreement on a method for analyzing and determining the similarities between the chemical structures the controlled substance and its designer analogue, leading it to conclude this disagreement rendered the Pennsylvania designer drug statute unconstitutionally vague. The Pennsylvania Supreme Court reversed, finding the common pleas court did not account for the difference between the concepts of analogue and substantial similarity, the latter of which is more readily apprehensible to the lay citizen in the context of comparing chemical structures; nor did it recognize that, unlike the controlled-substance provision, the designer drug provision included a narrowing scienter specification. Moreover, the Court found in this case that there were “considerable similarities” as between the two molecules based on their two-dimensional diagrams. View "Pennsylvania v. Herman" on Justia Law

The Pennsylvania Supreme Court affirmed appellant Marcel Johnson’s convictions and his sentence of death for the 2013 murder of Ebony Talley, her unborn child, and her four-year-old daughter, R.R. In this automatic direct appeal, Johnson raised nine issues for review. After thorough consideration of these issues, the Court affirmed his convictions and the imposition of the death sentence. View "Pennsylvania v. Johnson" on Justia Law

Trial courts must identify the circumstances that make it reasonable to infer that the property owner had actual knowledge of the illegal use of the property or consented to the underlying criminal activity before allowing a civil in rem forfeiture of that property. The proper constitutional construct in determining whether an in rem forfeiture violates the Excessive Fines Clause of the Eighth Amendment requires an initial determination regarding the relationship between the forfeited property and the underlying offense (the instrumentality prong). If this threshold prong is satisfied, the next step of the analysis is a proportionality inquiry in which the value of the property sought to be forfeited is compared to the gravity of the underlying offense to determine whether the forfeiture is grossly disproportional to the gravity of the offense. A 71-year-old grandmother who owned the house in which she lived, and owned a 1997 Chevrolet minivan, suffered from blood clots in her lungs, was hospitalized, and released, ordered to bed rest. Her adult son and two grandchildren also lived in the house. The son sold drugs from the house and the van, without his mother’s knowledge. The Commonwealth filed a petition for forfeiture of the house and minivan, with the trial court determining there was a nexus between the seized house and violations of the Controlled Substance, Drug, Device and Cosmetic Act (Drug Act). The trial court rejected the grandmother’s statutory innocent owner defense afforded by the Forfeiture Act because, after the police notified her of her son’s drug activities (through service of search warrants and personally informing her of the activities) she “refused to take any proactive measures or steps to demonstrate her lack of consent to this illegal activity. The Commonwealth Court reversed the trial court, concluding that the lower tribunal applied an erroneous standard for determining whether the forfeiture violated the Eighth Amendment, and that it failed to consider all relevant circumstances in rejecting the innocent owner defense. The Pennsylvania Supreme Court agreed and affirmed the Commonwealth Court. View "Pennsylvania v. 1997 Chevrolet, etc." on Justia Law

In a discretionary appeal, the issue before the Pennsylvania Supreme Court centered on whether a home rule municipality could amend its home rule charter to eliminate mandatory subjects of bargaining as defined by the Police and Firemen Collective Bargaining Act ("Act 111"), the Pennsylvania Labor Relations Act ("PLRA"), and applicable case law. Appellant, the Fraternal Order of Police, Fort Pitt Lodge No. 1 (“FOP”) was the exclusive collective bargaining representative for the police officers of Appellee, the City of Pittsburgh (“City”), pursuant to Act 111 and the PLRA. The City was subject to the Policemen’s Civil Service Act, which requires officer applicants be residents of the city at the time of application and throughout their term of employment. The General Assembly repealed the residency mandate in 2012. The parties met to bargain the residency issue, but were unable to reach an agreement. The matter went to arbitration, and pending those proceedings, the Pittsburgh City Council passed a resolution to place a referendum on the upcoming general election ballot asking the voters whether the City’s home rule charter should be amended to require all City employees and officials, including police and fire personnel, to maintain their domicile within the City. Voters approved the home rule charter amendment in 2013. The arbitration panel issued a Supplemental Interest Arbitration Award, which provided that the City-only residency requirement would immediately discontinue and be replaced with a different residency requirement: officers would be required to reside within a twenty-five air-mile radius from the Pittsburgh City-County Building. The City sought review with the court of common pleas, seeking to vacate the arbitration supplemental award. The Supreme Court found that to ensure that home rule municipalities would not abrogate the right of police and firefighters to collectively bargain, the General Assembly enacted Section 9 of Act 111, specifically providing that the act was applicable to every political subdivision in the Commonwealth, regardless of its adoption of a home rule charter. Because the home rule charter amendment changed or modified Act 111 by removing residency as a subject of collective bargaining, it violated Section 2962(e) of the Home Rule Charter law. Thus, based strictly on Section 2962 of the Home Rule Charter Law, the FOP was entitled to relief. The trial court affirming the supplemental interest arbitration award directing officers be required to reside within a twenty-five mile radius from the City-County Building was reinstated. View "City of Pittsburgh v. Fraternal Order of Police Ft. Pitt Ldg. 1" on Justia Law