Justia Pennsylvania Supreme Court Opinion Summaries

The Pennsylvania Supreme Court granted review to consider whether appellant was subject to custodial interrogation during an encounter with parole agents, such that their failure to issue Miranda1 warnings violated his Fifth Amendment rights. The Superior Court held that Miranda warnings were not required during questioning by the parole agents because appellant's statements were merely part of a parole interview rather than a custodial interrogation. It noted custody was equivalent to "a formal arrest or restraint on freedom of movement of the degree associated with a formal arrest." The court reviewed various factors and found the mere fact appellant was handcuffed was insufficient to show he was arrested. Appellant argued to the Supreme Court that the parole agent should have issue Miranda warnings to a parolee when he was in custody and questioned about new crimes. Under the facts of this case, the Supreme Court agreed that appellant was subject to custodial interrogation such that his parole agents' failure to issue Miranda warnings violated his Fifth Amendment rights, and the courts below erred in failing to suppress his incriminating statements, and such error was not harmless. Thus, appellant was entitled to a new trial consistent with the guidelines the Court set out in this opinion. View "Pennsylvania v. Cooley, III" on Justia Law

The issue this case presented for the Supreme Court's review centered on the constitutionality and severability of 18 Pa.C.S. section 6317(a), which imposed a mandatory minimum sentence of two years total confinement upon a defendant for a conviction if a delivery or possession with intent to deliver a controlled substance occurs within 1,000 feet of, inter alia, a school in light of the United States Supreme Court's decision in "Alleyne v. United States," (133 S. Ct. 2151 (2013)). In 2013, the Pennsylvania State Police filed a criminal complaint against Appellee Kyle Hopkins, charging him with various violations of the Controlled Substance, Drug, Device and Cosmetic Act. The charges arose from three incidents which took place over three days in April 2012, during which Appellee sold heroin to a confidential informant in Kennett Square Borough and New Garden Township, Chester County. One sale allegedly occurred in a school zone. Appellee was held for court on all charges stemming from those instances, in all, Appellee had 12 counts against him. The trial court reasoned that it was bound by the United States Supreme Court's decision in "Alleyne," and granted Appellee's Motion for Extraordinary Relief. The Commonwealth appealed. After review, the Pennsylvania Supreme Court affirmed, holding that numerous provisions of Section 6317 were "constitutionally infirm" under Alleyne. Moreover, the remaining provisions of Section 6317, standing alone, were incomplete and "incapable of being vindicated in accord with the intent of the General Assembly." Because of the significant provisions found to violate the Constitution and the remaining unoffending provisions of Section 6317 were incapable of being severed. The Court declined to "rewrite Section 6317 or create a substantive offense which the General Assembly clearly did not desire." View "Pennsylvania v. Hopkins" on Justia Law

The primary issue presented by this case for the Supreme Court's review centered on whether Section 306(b)(3) of the Workers’ Compensation Act (Act) required an employer to provide an injured employee with written “notice of ability to return to work” before offering alternative employment where the injured employee has not yet filed a claim petition and, thus, never proved entitlement to workers’ compensation benefits. The Court held that Section 306(b)(3) notice was required where the employer was seeking to modify existing workers’ compensation benefits based on medical evidence establishing that the injured employee was able to return to work in some capacity. Because the injured employee in this case had not yet received workers’ compensation benefits when the offer of alternative employment was rendered, the employer had no duty to provide notice of ability to work pursuant to Section 306(b)(3). View "Sch. Dist of Phila. v. WCAB" on Justia Law

Leola Restaurant maintained an umbrella commercial liability insurance policy with Appellant, Mutual Benefit Insurance Company, which contained an employer’s liability exclusion. Leola Restaurant conducted its business on a property leased from Appellees Christos Politsopoulos and Dionysios Mihalopoulos. During the policy period, Appellee Marina Denovitz, an employee of Leola Restaurant, fell from an outside set of stairs and suffered injuries. She brought a negligence action against the Property Owners in the common pleas court, asserting that they were negligent in maintaining the stairs in an unsafe and dangerous condition. The Property Owners sought defense and indemnification from Appellant, per the umbrella policy. The insurance company sought a declaratory judgment that an exclusion in the restaurant's umbrella policy applied to Appellee's case, and that it was not obligated to indemnify the restaurant. After review, the Supreme Court concluded the employer’s liability exclusion in the umbrella policy was ambiguous. "Application of governing principles of insurance policy construction yields the understanding that the ambiguous exclusionary language pertains only to claims asserted by employees of 'the insured' against whom the claim is directed, which understanding gains further support by reference to the policy’s separation-of-insureds provision. Since the Property Owners are not Ms. Denovitz’s employers, the employer’s liability exclusion is inapplicable." View "Mutual Ben. Ins. Co. v. Politsopoulos" on Justia Law

This appeal centered on the nature of a valid invocation of the Miranda-based right to counsel, specifically, in terms of whether the right must be asserted in close temporal proximity to custodial interrogation or may be effectively invoked remotely from such questioning. Appellee Dennis Bland, Jr. allegedly shot and killed Keron Remberan in Philadelphia, then fled to his mother’s house in Florida. After learning of Appellee’s whereabouts, police obtained an arrest warrant and notified Florida law enforcement. Federal authorities in Florida detained Appellee, who was seventeen years old at the time, and he was placed in a juvenile facility to await extradition to Pennsylvania. The day after Appellee’s arrest, his father contacted the Defender Association of Philadelphia and apprised an attorney of his son’s circumstances. The lawyer sent a form letter via facsimile to Florida counsel representing Appellee in connection with the extradition proceedings, asking that Appellee sign and return the document. The letter reflected a very clear putative invocation of the Miranda-based right to counsel. Six days after Appellee had signed the form sent by the Defender Association while he was in Florida, a detective provided him with Miranda warnings. During ensuing questioning, Appellee ultimately confessed to perpetration of the killing, and, after later consultation with his father, he also provided a written confession. Appellee was charged with murder, firearms violations, and several related offenses, and the Defender Association was formally appointed as counsel. Appellee filed a pre-trial motion to suppress his written statement, claiming that police violated his rights under Miranda, as well as under Article 1, Section 9 of the Pennsylvania Constitution. The Supreme Court held that, to require a suspension of questioning by law enforcement officials on pain of an exclusionary remedy, an invocation of the Miranda-based right to counsel must be made upon or after actual or imminent commencement of in-custody interrogation. View "Pennsylvania v. Bland" on Justia Law

In response to time demands of this primary election appeal, the Pennsylvania Supreme Court entered a per curiam order on an expedited basis vacating the order of the Commonwealth Court and directing that Appellee Michael W. Beyer’s name be stricken from the primary ballot for the Democratic Party nomination for the Office of Representative in the General Assembly for the 131st Legislative District. In the per curiam order, the Court stated that an opinion would follow; this was that opinion. Beyer filed nomination petitions with the Department of State seeking placement of his name on the ballot for Democratic Nomination for the Office of Representative in the General Assembly. Appellant Objectors, qualified electors residing in the 131st Legislative District, petitioned to set aside the nomination petition on grounds that Beyer intentionally misrepresented his occupation as “lawyer” on both his Statement of Financial Interests (SOFI) and nomination petitions. At a hearing, .Beyer confirmed he had graduated law school, but had yet to pass or even take any state’s bar examination. Consequently, he was not licensed to practice law at the time he circulated his nomination petitions. He listed his occupation as “lawyer,” he said, because he understood the definition of “lawyer” as found in the Oxford English Dictionary to include someone who studied the law. He therefore thought it fair comment to describe his profession or occupation as “lawyer” on his nomination petition. Though she found that he likely used the title of “lawyer” to “enhance his stature with the electorate,” the trial judge accepted Beyer's explanation that he believed his having studied law and graduated law school in the past, alone, entitled him to claim the occupation. Appellant Objectors contended the Commonwealth Court erred in failing to find that Beyer’s self-designation as a lawyer-by-occupation represented a material defect borne of the intent to mislead the electorate. The Supreme Court agreed: the defect was both material to an elector’s decision to nominate a legislator and incurable by amendment because the candidate knew his representation had the potential to mislead signers about his credentials for the legislative office he sought. Having demonstrated as much, Objectors met their burden of disproving the presumptive validity of the contested nomination petition. Striking Mr. Beyer’s petition under such circumstances to avoid misleading the electorate was consistent with the Election Code’s purpose of protecting, and not defeating, a citizen’s vote. View "In Re: Nom. of Michael W. Beyer" on Justia Law

Following a jury trial on charges that he endangered the welfare of children, appellee William Lynn was convicted and sentenced to a term of three to six years of incarceration. On appeal, he challenged the sufficiency of the evidence, arguing that he had no direct supervision of the children he was found to have endangered. The Superior Court agreed, and reversed his conviction. On the Commonwealth’s appeal, the Supreme Court reversed the Superior Court, concluding that there was no statutory requirement of direct supervision of children. "Rather, that which is supervised is the child’s welfare. Under the facts presented at trial, Appellee was a person supervising the welfare of many children because, as a high-ranking official in the Archdiocese of Philadelphia, he was specifically responsible for protecting children from sexually abusive priests." View "Pennsylvania v. Lynn" on Justia Law

Appellant Noel Montalvo was the brother of Milton Montalvo. Milton was convicted of the 1999 murder his common-law wife Miriam Ascensio. Appellant would later be charged as being an accomplice to the murder. More than three years after Milton was convicted of two counts of first-degree murder for the deaths of Miriam and Nelson, a jury convicted Appellant of first-degree murder for the death of Miriam, second-degree murder for the death of a friend of Miriam's, Nelson Lugo, conspiracy to commit murder, and burglary. Appellant applied for post-conviction relief, listing eleven alleged errors at trial that ultimately entitled him to relief. "As a result of the PCRA court’s failures, [the Pennsylvania Supreme] Court has no findings of fact, no determinations of credibility, and no legal conclusions regarding Appellant’s PCRA claims; in short, [the Court had] no basis upon which to conduct meaningful appellate review." The Court vacated the PCRA court's judgment, and remanded the case for further proceedings. View "Pennsylvania v. Montalvo" on Justia Law

In July 2012, claimant Charles Chamberlain was unemployed and was receiving unemployment compensation benefits. In October, he pled guilty to the summary offenses of operating a vehicle without a valid inspection, and driving with a suspended license. Relating to the latter conviction, Claimant was sentenced to sixty days in the Keystone House Arrest Program (from November 1, 2012 to December 31, 2012) with the condition that if he failed to comply, he would serve sixty days in the York County Prison. Claimant was also required to attend reemployment eligibility assessment classes. The terms of Claimant’s house arrest restricted him to the home of his sister, but permitted him to work, run errands, and do his Christmas shopping. On November 28, 2012, the local service center of the Office of Unemployment Compensation Benefits issued a notice of determination that Claimant’s sentence of house arrest disqualified him from receipt of benefits because he was “incarcerated after a conviction” under Section 402.6. Claimant appealed the finding of disqualification and, in 2013, a hearing was held before a referee for the Unemployment Compensation Board of Review (UCBR). The referee concluded Claimant was disqualified from receiving benefits, and Claimant appealed. Mindful of the remedial purpose of the Unemployment Compensation (UC) Law, the Commonwealth Court held that a claimant sentenced to house arrest is not “incarcerated” under Section 402.6. Because the terms and conditions of the claimant’s house arrest did not otherwise prevent him from satisfying the statutory requirements for obtaining unemployment compensation benefits, the Commonwealth Court reversed the denial of benefits. Agreeing with the Commonwealth Court's conclusion, the Supreme Court affirmed. View "Chamberlain v. Unemployment Compensation Review Bd." on Justia Law

In 2009, George Lawrence, while employed by Schneider National Inc., suffered a work-related injury when he slipped and fell in a parking lot leased by Domtar Paper Company, and allegedly owned and maintained by Commercial Net Lease Realty Services, Inc., Commercial Net Lease Realty Trust, Commercial Net Lease Realty, Inc., National Retail Properties, Inc., and National Retail Properties Trust. As a result of this injury, Schneider's workers' compensation carrier, Liberty Mutual Insurance Company, paid Lawrence $33,929.23 in workers' compensation benefits. The issue this case presented for the Supreme Court's review centered on whether section 319 of the Pennsylvania Workers' Compensation Act (WCA) conferred on employers or their workers' compensation insurers a right to pursue a subrogation claim directly against a third-party tortfeasor when the injured employee took no action against the tortfeasor. Based on established precedent, the Superior Court held that Section 319 did not permit employers/insurers to commence an action directly against the third-party tortfeasor, and affirmed the trial court's grant of preliminary objections in favor of the tortfeasors. Agreeing with that reasoning, the Supreme Court affirmed. View "Liberty Mutual Ins. Co. v. Domtar Paper Co." on Justia Law