Justia Pennsylvania Supreme Court Opinion Summaries

Circle of Seasons Charter School (Charter School) purchased two properties from The Pennsylvania State University (PSU) in May 2017. These properties were previously tax-exempt as part of PSU's Lehigh Valley Campus. Following the sale, Lehigh County issued assessment notices changing the properties' status from non-taxable to taxable, effective January 1, 2018. The notices did not include the required mailing date. Charter School claimed it did not receive these notices and subsequently did not pay the 2017 and 2018 tax bills until refinancing the properties in June 2018.The Lehigh County Court of Common Pleas sustained the preliminary objections of Northwestern Lehigh School District (School District) and dismissed Charter School's complaint with prejudice. The trial court found that Charter School had actual notice of the tax assessments by November 2017 and could have addressed the taxes in its 2018 annual appeal to the Lehigh County Board of Assessment Appeals (the Board). The Board granted tax-exempt status effective January 1, 2019, but Charter School did not seek retroactive relief or a refund for the taxes paid for 2017 and 2018.The Commonwealth Court reversed the trial court's decision, ruling that the defective notices entitled Charter School to a nunc pro tunc hearing before the Board to determine the validity of the assessment changes and potential refunds. The court emphasized that the omission of the mailing date on the notices was a significant defect, warranting a new hearing.The Supreme Court of Pennsylvania reversed the Commonwealth Court's decision, reinstating the trial court's order. The Supreme Court held that Charter School had the burden to establish the properties' tax-exempt status and failed to do so in a timely manner. The court concluded that Charter School waived its claims by not seeking retroactive relief or a refund during the 2018 appeal and that nunc pro tunc relief was not warranted. View "Circle of Seasons Chart School v. Northwestern Lehigh School District" on Justia Law

The case involves the District Attorney (DA) of Philadelphia, who challenged articles of impeachment passed by the Pennsylvania House of Representatives. The articles were transmitted to the Senate on the last day of the 206th General Assembly session. The DA argued that the articles became null and void upon the session's expiration, and the new Senate could not conduct a trial based on them.The Commonwealth Court initially denied the DA's request for summary relief, ruling that the impeachment articles did not expire with the session's end. The court also found that the DA, as a local official, could be impeached under the Pennsylvania Constitution. However, the court agreed with the DA that some articles of impeachment did not allege conduct amounting to "misbehavior in office" and that certain articles intruded on the judiciary's exclusive authority to govern attorney conduct.The Supreme Court of Pennsylvania reviewed the case. The court first addressed the justiciability of the issue, concluding that it had the authority to determine whether the impeachment articles expired with the session's end. The court emphasized that the Constitution must be read as an integrated whole, and the General Assembly's powers, including impeachment, are limited to the duration of its session.The court held that the articles of impeachment became null and void upon the expiration of the 206th General Assembly session. Consequently, the Senate of the 207th General Assembly could not conduct a trial based on those articles. The court reversed the Commonwealth Court's order denying the DA's request for summary relief on this issue. View "Krasner v. Ward" on Justia Law

In this case, the appellant was convicted of two counts of first-degree murder, one count of first-degree murder of an unborn child, and two counts of endangering the welfare of children. The crimes occurred in July 2020, when the appellant fatally shot Sydney Parmalee and Kaylee Lyons. Sydney was found dead in an apartment with a gunshot wound to her head, and Kaylee was found dead under similar circumstances later that month. The appellant was the father of both women’s children and was present at the scenes of both murders. He initially claimed Sydney’s death was a suicide but later admitted to killing both women.The Court of Common Pleas of Cumberland County convicted the appellant and sentenced him to death for Kaylee’s murder, life imprisonment for Sydney’s murder, and life imprisonment for the murder of Kaylee’s unborn child. The jury found one aggravating circumstance for Kaylee’s murder, which was that the appellant had been convicted of another offense punishable by death (Sydney’s murder). The appellant’s post-sentence motion was denied, leading to this direct appeal.The Supreme Court of Pennsylvania reviewed the case and affirmed the judgment of sentence. The court found that the evidence was sufficient to support the convictions for first-degree murder, as the appellant used a deadly weapon on vital parts of the victims’ bodies, demonstrating malice and specific intent to kill. The court also upheld the conviction for endangering the welfare of a child, noting that the appellant left his son alone in the apartment after killing Kaylee.The court rejected the appellant’s argument that his spontaneous confession should have been suppressed, ruling that it was a voluntary statement not prompted by police questioning. The court also found no abuse of discretion in the trial court’s denial of a new trial based on the weight of the evidence. Finally, the court concluded that the death sentence was not the product of passion, prejudice, or any other arbitrary factor and was supported by the evidence of the aggravating circumstance. View "Commonwealth v. Anderson" on Justia Law

In September 2007, Donte Thomas was convicted of first-degree murder and sentenced to death for the killing of Tyreese Gaymon. Thomas was also convicted of carrying a firearm on public streets, recklessly endangering another person, and conspiracy, though no sentences were imposed for these convictions. The murder occurred in February 2006, while Gaymon was standing on a street corner. Multiple witnesses identified Thomas as the shooter. Thomas was arrested in April 2006 and admitted to knowing Kareem Glass, who was awaiting trial for the murder of Gaymon’s cousin. Thomas denied shooting Gaymon but admitted to smuggling a cell phone into prison for Glass.On direct appeal, the Supreme Court of Pennsylvania affirmed Thomas’ conviction and sentence. Thomas then filed a timely petition under the Post Conviction Relief Act (PCRA) in October 2013, which he amended multiple times. The PCRA court held several hearings over two and a half years and ultimately dismissed Thomas’ petition in May 2023. Thomas appealed this dismissal.The Supreme Court of Pennsylvania reviewed Thomas’ claims, which included allegations of ineffective assistance of counsel and prosecutorial misconduct. Thomas argued that his trial counsel failed to consult with him adequately, investigate potential alibi witnesses, and object to prejudicial statements. He also claimed that the prosecution induced false testimony and withheld exculpatory evidence. The court found that Thomas’ counsel had met with him multiple times and that the potential alibi witnesses were either not credible or unavailable. The court also determined that the alleged prosecutorial misconduct did not deprive Thomas of a fair trial.The Supreme Court of Pennsylvania affirmed the PCRA court’s dismissal of Thomas’ petition, concluding that Thomas failed to prove his claims of ineffective assistance of counsel and prosecutorial misconduct. The court found no abuse of discretion in the PCRA court’s rulings. View "Commonwealth v. Thomas" on Justia Law

James Berry was convicted of sexually abusing two young family members. The court found that Berry had no prior convictions or juvenile adjudications, resulting in a prior record score of zero. However, the sentencing court imposed a sentence significantly above the standard range, citing Berry’s arrest record as a factor. Berry appealed, arguing that considering his arrest record, which did not result in convictions, was improper.The Superior Court affirmed the sentencing court’s decision, stating that a sentencing court may consider prior arrests as long as it recognizes that these arrests did not result in convictions. The court believed that Berry’s arrest record was relevant to his amenability to rehabilitation and the protection of the public.The Supreme Court of Pennsylvania reviewed the case and held that a sentencing court may not consider a defendant’s prior arrests that did not result in convictions. The court emphasized that prior arrests are not probative of a defendant’s character or likelihood of recidivism and are not relevant under the Pennsylvania Sentencing Code. The court noted that allowing prior arrests to influence sentencing would undermine the intent of the sentencing guidelines and the defendant’s prior record score.The Supreme Court vacated Berry’s sentence and remanded the case for resentencing without considering his prior arrest record. The court did not address the constitutional question of due process, as the case was resolved based on existing legal precedents regarding the irrelevance of prior arrests in sentencing. View "Commonwealth v. Berry" on Justia Law

A dental practice owned by Timothy A. Ungarean, DMD, purchased a commercial property insurance policy from CNA and Valley Forge Insurance Company. The policy was intended to cover business-related losses. In March 2020, due to the COVID-19 pandemic, Pennsylvania's Governor ordered non-essential businesses to close, which led to significant financial losses for Ungarean's practice. Ungarean filed a claim under the policy, which was denied by CNA on the grounds that there was no physical damage to the property.Ungarean then filed a class action complaint in the Court of Common Pleas of Allegheny County, seeking a declaration that the policy covered his pandemic-related business losses. The trial court granted summary judgment in favor of Ungarean, interpreting the policy's language to include loss of use of the property as a form of "direct physical loss." The court also found that none of the policy's exclusions applied to bar coverage.The Superior Court affirmed the trial court's decision, agreeing that the policy language was ambiguous and should be interpreted in favor of the insured. The court held that the loss of use of the property due to the government shutdown constituted a "direct physical loss."The Supreme Court of Pennsylvania reviewed the case and reversed the Superior Court's decision. The court held that the policy's language was unambiguous and required a physical alteration to the property for coverage to apply. The court found that the economic losses suffered by Ungarean due to the government shutdown did not meet this requirement. Consequently, the court ruled that Ungarean was not entitled to coverage under the policy and remanded the case to the Superior Court with instructions to enter summary judgment in favor of CNA. View "Ungarean v. CNA" on Justia Law

On December 30, 2018, Phillip Walters reported his girlfriend, Hayley Lorenzen, missing. Lorenzen had recently moved into Walters' apartment. Walters claimed that after staying up late the previous night, he found Lorenzen missing the next morning. He contacted her father and then the police. On January 9, 2019, Gabel Bell, who had a prior relationship with Walters, informed the police that Walters had killed Lorenzen. Bell detailed that Walters had strangled Lorenzen and disposed of her body in a river. Lorenzen's remains were found on July 20, 2019, leading to Walters being charged with first-degree murder, strangulation, and abuse of a corpse.The Wyoming County Court of Common Pleas convicted Walters, and he was sentenced to life imprisonment without parole. Walters appealed, arguing that the trial court erred in admitting the testimony of Dr. Gary Ross, the pathologist, who concluded that Lorenzen's cause of death was "strangulation by history" based solely on Bell's account, without physical evidence. The Superior Court affirmed the conviction, reasoning that the pathologist's reliance on case history was permissible.The Supreme Court of Pennsylvania reviewed the case and found that Dr. Ross' testimony did not meet the requisite standard of being offered to a reasonable degree of medical certainty. Dr. Ross admitted that his conclusion was based solely on Bell's statements and not on any objective medical findings due to the advanced decomposition of Lorenzen's body. The court held that this testimony improperly bolstered Bell's credibility, encroaching on the jury's role in determining witness credibility. Consequently, the court vacated Walters' judgment of sentence and remanded the case for a new trial. View "Commonwealth v. Walters" on Justia Law

Jamie Walsh and Mike Cabell competed in the April 23, 2024, primary election for the Republican nomination to represent the 117th District in Pennsylvania’s House of Representatives. Several provisional ballots were returned, and Walsh led Cabell by three votes before counting them. The Luzerne County Board of Elections held hearings to review the provisional ballots. Cabell challenged a ballot submitted by Timothy Wagner because the envelope was unsigned, and Walsh challenged a ballot submitted by Shane O’Donnell, who was registered to vote in a different county. The Board decided to count Wagner’s ballot but not O’Donnell’s.Cabell appealed to the Luzerne County Court of Common Pleas, which held a hearing where Wagner and O’Donnell testified. Wagner could not remember if he signed the envelope, but the court affirmed the Board’s decision to count his ballot due to no evidence of fraud and clear intent to vote. O’Donnell testified he moved to a new home less than 30 days before the election, and the court affirmed the Board’s decision not to count his vote, as he could have voted in his new district.The Commonwealth Court reversed both rulings. It held that Wagner’s unsigned ballot should not be counted based on the Election Code’s clear language. It also held that O’Donnell’s ballot should be counted because he moved within 30 days before the election, allowing him to vote in his old district.The Supreme Court of Pennsylvania affirmed the Commonwealth Court’s decision. It held that Wagner’s unsigned ballot should not be counted due to the clear statutory requirement for a signature. It also held that O’Donnell’s ballot should be counted because he moved within 30 days before the election, allowing him to vote in his previous district. View "IN RE: CANVASS OF PROVISIONAL BALLOTS IN THE 2024 PRIMARY ELECTION" on Justia Law

The case involves a dispute over the enforcement of a partnership agreement following the death of a partner. Mary Ann Caruso and her sons, Peter and John, formed a partnership in 1983 to operate Hays Land Company (HLC). After Mary Ann's death, Peter and John continued the business until John's death in 2003. John's wife, Geraldine, became the executrix of his estate. Peter did not exercise the buy-out provision in the partnership agreement after John's death, and he continued to operate HLC with Geraldine, who received 50% of the business proceeds.The Court of Common Pleas of Allegheny County initially granted summary judgment in favor of Sandra, Peter's daughter and executrix of his estate, ruling that the Dead Man’s Act precluded Geraldine from proving the partnership agreement's continued applicability. The Superior Court reversed, finding sufficient evidence that Peter and Geraldine intended to continue the partnership under the original agreement. On remand, the trial court ordered specific performance of the buy-out provision, which the Superior Court affirmed.The Supreme Court of Pennsylvania reviewed the case and concluded that Geraldine could not enforce the partnership agreement because she was neither an original party to the agreement nor a third-party beneficiary. The court found no evidence that Peter and Geraldine explicitly agreed to be bound by the original partnership agreement after John's death. The court emphasized that the formation of a new partnership between Peter and Geraldine did not automatically incorporate the terms of the original agreement. Consequently, the Supreme Court reversed the Superior Court's order, holding that Geraldine could not compel specific performance of the buy-out provision against Sandra. View "In Re: Estate of P. Caruso" on Justia Law

A mother filed for sole custody of her two daughters, alleging the father, who resides in Guatemala, had abused, neglected, and abandoned the children. The Delaware County Court of Common Pleas granted her sole custody but denied her request for Special Immigrant Juvenile (SIJ) findings, which are necessary for the children to seek SIJ status with federal immigration authorities. The court found insufficient evidence of abuse, neglect, or abandonment under Pennsylvania law and questioned whether it was in the children's best interest to issue an SIJ order.The mother appealed to the Superior Court of Pennsylvania, which affirmed the lower court's decision. The Superior Court held that SIJ determinations could only be made in dependency proceedings, not in custody proceedings where one parent is awarded sole custody.The Supreme Court of Pennsylvania reviewed the case and reversed the Superior Court's decision. The Court clarified that under federal SIJ law, a child involved in custody proceedings resulting in sole custody being awarded to a parent in the United States can seek SIJ determinations in that context. The Court held that the Superior Court erred in limiting SIJ determinations to dependency proceedings and that the record supported the children's entitlement to predicate SIJ determinations.The Supreme Court directed the custody court to enter orders consistent with its opinion, including findings that reunification with the father is not viable due to abandonment and neglect, and that it is not in the children's best interest to return to Guatemala. The case was remanded to the custody court for entry of these orders. View "Velasquez v. Miranda" on Justia Law