Justia Pennsylvania Supreme Court Opinion Summaries

This was a capital direct appeal arising out of Appellant Ricky Smyrnes' participation, with a group of five other individuals, in the kidnapping, torture, and murder of Jennifer Lee Daugherty. The case was a companion one to that of co-perpetrator Melvin Knight. Appellant forced the victim to write a staged suicide note, after which Appellant and Knight dragged her to the bathroom; Knight repeatedly and fatally stabbed her; Appellant slit her wrists (albeit superficially); Appellant and Knight choked her as she lay dying; and her body was placed in a trash can. Appellant and Knight moved the can and body outside to a remote location, where these were discovered the next day. Apparently in light of developing evidence that a disturbance had occurred in Appellant’s apartment, police began to interview the co-perpetrators, and inculpatory statements were obtained. At the penalty hearing, the Commonwealth pursued, and the jury found present, the aggravating circumstances involving torture and a significant history of felony convictions involving the use or threat of personal violence. One or more jurors also found mitigation in the form of “mental illness, childhood physical abuse, [and] childhood sexual abuse.” Upon balancing, however, the jurors unanimously agreed that the aggravating factors outweighed the mitigation and, accordingly, returned the death verdict. This direct appeal followed, in which Appellant presented fifteen claims for relief. Finding no reversible error after review, the Pennsylvania Supreme Court affirmed Appellant's conviction and sentence. View "Pennsylvania v. Smyrnes" on Justia Law

Appellants Main Line Gardens, Inc. and Coffman Associates, LLC (collectively, “Main Line”), petitioned the Pennsylvania Supreme Court on the issue of whether it was proper for the Commonwealth Court to dismiss its appeal because it did not file briefs at the trial court in support of post-trial motions. The Supreme Court concluded that the Commonwealth Court erred, and thus remanded the case for merits review of the issues raised on appeal. View "Willistown Twp. v. Main Line Gardens" on Justia Law

The Pennsylvania State Police (“PSP”) appealed a Superior Court judgment holding that section 6111.1(g)(2) of the Uniform Firearms Act, which provided for review by a court of common pleas of a request for the expungement of the PSP’s records of an individual’s involuntary civil commitment under section 7302 (“302”) of the Mental Health Procedures Act (“MHPA”), required a de novo hearing at which clear and convincing evidence must be presented in support of the 302 commitment. The Supreme Court concluded that the Superior Court erred, as the plain language of section 6111.1(g)(2) required a court of common pleas to review only the sufficiency of the evidence to support the 302 commitment, limited to the information available to the physician at the time he or she made the decision to commit the individual, viewed in the light most favorable to the physician as the original decision-maker to determine whether his or her findings are supported by a preponderance of the evidence. Because the Superior Court reviewed the trial court’s decision through an "improper lens," the Supreme Court vacated its decision and remanded this case back to that court for further proceedings. View "In Re Vencil" on Justia Law

The issue in this workers’ compensation appeal was ultimately whether a notice of compensation payable closely circumscribes the range of health-related conditions to be considered in impairment rating evaluations. The Supreme Court held that physician-examiners must exercise independent professional judgment to make a whole-body assessment of “the degree of impairment due to the compensable injury,” which discernment cannot be withheld on the basis that the physician-examiner believes the undertaking is a more limited one. The order of the Commonwealth Court with respect to this issue was reversed, and the matter remanded for reinstatement of the finding of invalidity rendered by the Worker's Compensation Appeal Board. View "Duffey v. WCAB" on Justia Law

The issue this case presented for the Pennsylvania Supreme Court's consideration was whether individuals who were not named in an executed testamentary document have standing to bring a legal malpractice action against the testator’s attorney, as purported third-party beneficiaries to the contract for legal services between the testator and his attorney. After review, the Court concluded such individuals do not have standing to sue the testator’s attorney for a breach of contract. The Court therefore reversed the Superior Court and remanded for reinstatement of the trial court’s order granting summary judgment and dismissing the claims. View "Est. of Robert Agnew v. Ross" on Justia Law

Harrisburg Police Officer Darin Bates and Dauphin County Adult Probation Officer (APO) Richard Anglemeyer were traveling in an unmarked police vehicle in an area known for frequent drug activity when they observed two men conversing on a street corner; one of those men was Appellant Khiri Arter. Notwithstanding Appellant's objection, APO Anglemeyer performed a pat-down search of Appellant and felt a bulge in the right coin pocket of Appellant's pants. APO Anglemeyer reached into Appellant's pocket and retrieved what appeared to be crack cocaine. APO Anglemeyer then "turned the case over to Officer Bates," who arrested Appellant. The Pennsylvania Supreme Court granted allowance of appeal in this matter to determine whether illegally-obtained evidence which was suppressed during criminal proceedings should likewise be suppressed during parole and probation revocation proceedings pursuant to Article I, Section 8 of the Pennsylvania Constitution. The Court concluded that it should, reversed the Superior Court's order affirming the trial court's denial of Appellant's motion to suppress, vacated the order revoking Appellant's parole, and remanded to the trial court for further proceedings. View "Pennsylvania v. Arter" on Justia Law

The issue this case presented for the Supreme Court’s review centered on whether, pursuant to section 8327(b)(2) of the Public School Employees’ Retirement Code, 24 Pa.C.S.A. 8327(b)(2), the school district that originally approved the creation of a charter school was financially responsible, after the revocation of the charter, for the charter school’s prior failure to make payments to its employees’ retirement fund. The Court surmised the question hinged upon whether unpaid retirement contributions constituted an outstanding obligation of the closed charter school. The Court concluded that the deficiency resulting from the failure to make the payments was indeed an outstanding financial obligation of a closed charter school and therefore, pursuant to section 17-1729-A(i) of the Charter School Law, 24 P.S. section 17-1729-A(i), the school district could not be held liable for the amounts owed. View "Pocono Mtn. Sch. Dist. v. Dept. of Educ." on Justia Law

Philadelphia police officers executed a search warrant for a residence where appellant Kareem Barnes lived with his two younger brothers. The search of one of the bedrooms yielded a firearm, assorted drugs and drug paraphernalia. As a result, the Commonwealth charged Appellant with possession with intent to deliver ("PWID"), possession of a firearm prohibited, and other related charges. Appellant waived his right to a jury trial and proceeded to a bench trial. At trial, Appellant's youngest brother testified that he, not Appellant, occupied the bedroom where the seized items were found and he, not Appellant, owned the contraband. The trial court, however, did not credit the brother's testimony, and instead, found Appellant guilty of the crimes charged. The trial court sentenced Appellant to 5 to 10 years' imprisonment on the PWID conviction, which included a 5-year mandatory minimum sentence based on the trial court's finding that Appellant was in constructive possession of drugs "in close proximity to" a firearm. No further penalty was imposed for the other convictions. This appeal presented the issue of whether a challenge, on direct appeal, alleging that a mandatory minimum sentence violated "Alleyne v. United States," (133 S.Ct. 2151 (2013)), implicating the "legality" of a sentence for issue preservation purposes, and thus was not waivable. The Pennsylvania Supreme Court held that an "Alleyne" challenge implicated legality of sentence, and that Appellant's sentence violated "Alleyne." Accordingly, the Court reversed the trial court's decision, vacated Appellant's judgment of sentence, and remanded for resentencing. View "Pennsylvania v. Barnes" on Justia Law

In 2012, Appellant Frankie Rosado was accused of sexually abusing his former girlfriend’s teenage daughter, whereupon he was charged with one count each of indecent assault, corruption of minors, and unlawful contact with minor. Appellant, then represented by a public defender, proceeded to trial, whereafter he was convicted of the aforementioned offenses and later sentenced to an aggregate term of 33 to 69 months imprisonment. Appellant hired new counsel to represent him at the post-sentencing and appellate stages of his case. Appellate Counsel filed a postsentence motion raising, as relevant here, a sufficiency-of-the-evidence claim, but the trial court denied relief. Appellate Counsel then filed a notice of appeal to the Superior Court which later summarily affirmed the trial court's judgment. Appellant later filed for post-conviction relief, arguing he received ineffective assistance of counsel. In his application, appellant argued that Appellate Counsel filed a document styled as a “preliminary” concise statement, wherein he raised three issues for appeal, but failed to file a revised concise statement. When the appellate brief was filed, Appellate Counsel abandoned the three issues raised in the preliminary statement and raised three others. In an unpublished memorandum opinion, the Superior Court, while noting the three issues preserved in Appellant’s concise statement, found a sufficiency-of-the-evidence claim to be waived, as it was not included therein. The PCRA court found that Appellate Counsel’s conduct did not amount to ineffectiveness per se, and, accordingly, denied relief. So the issue for the Supreme Court's review was whether filing an appellate brief which abandoned all preserved issues in favor of unpreserved ones constituted ineffective assistance of counsel per se. After careful review, the Court held that it did, and so the Court vacated the Superior Court’s order and remanded this case back to that court for further proceedings. View "Pennsylvania v. Rosado" on Justia Law

Sheldon Hannibal appealed an order of the Court of Common Pleas of Philadelphia County denying his petition for relief from his death sentence. In 1992, Hannibal and a co-defendant, Larry Gregory, got into an argument with the victim, Peter LaCourt. LaCourt was pistol whipped before attempting to flee. Hannibal shot LaCourt six times. A fifteen-year-old girl witnessed the robbery and beating, and later gave statements to police, implicating Hannibal and Gregory. She also testified at their preliminary hearings. However, she and two of her female friends were murdered "execution-style" in an apartment located in the same housing development where LaCourt had been murdered. The jury convicted appellant and codefendant of first-degree murder. Hannibal applied for post-conviction relief, raising a number of issues for the Supreme Court's review. Finding that Hannibal was not entitled to relief, the Court affirmed dismissal of his PCRA petition. View "Pennsylvania v. Hannibal" on Justia Law