Justia Pennsylvania Supreme Court Opinion Summaries

In this capital case, the United States District Court for the Western District of Pennsylvania held that Appellant Scott Wayne Blystone was entitled to receive a new sentencing hearing after concluding that his counsel was ineffective for failing to investigate and develop penalty-phase mitigating evidence in the form of institutional records and expert mental-health evidence. The United States Court of Appeals for the Third Circuit affirmed, and Appellant the new penalty-phase hearing was pending following the completion of discovery. Throughout the course of counsel’s current mitigation investigation, Appellant’s mother, Norma Blystone, refused to divulge certain "critical" information regarding Appellant’s childhood unless she was assured that the information she provided would not be made public. In an attempt to provide Mrs. Blystone with such assurances and to obtain this additional information from her, Appellant filed a motion for limited courtroom closure and temporary sealing of transcripts with respect to Mrs. Blystone’s testimony, any expert testimony addressing the information Mrs. Blystone might reveal, and any closing arguments referencing such testimony. The trial court denied the motion, and Appellant filed an interlocutory appeal. After review, the Supreme Court concluded that it lacked jurisdiction to review the trial court’s interlocutory order denying Appellant’s closure motion, and, accordingly, this appeal was quashed. View "Pennsylvania v. Blystone" on Justia Law

Consolidated direct appeals to the Pennsylvania Supreme Court centered on appellees' efforts to resurrect a defunct state-run health insurance program. Appellees were recipients of state-subsidized, low-cost health insurance via the "adultBasic" program, which was previously administered by the Department of Insurance and made available to certain qualifying adults in Pennsylvania. The program received the bulk of its funding from the proceeds of a 1998 multi-state master settlement agreement between forty-seven states and several major U.S. tobacco product manufacturers. The allocation and distribution of funds received annually by the Commonwealth under this settlement was initially administered outside of the Fiscal Code, via the Tobacco Settlement Act (TSA). As relevant here, for purposes of fiscal years 2010-2011 and 2011-2012, the General Assembly used modifications to the Fiscal Code to override the TSA’s requirements for tobacco settlement monies. One effect of the amendments was to divert tobacco settlement funds more generally to other fiscal priorities of the Commonwealth. In March 2011, Appellees Cheryl Sears and seventy-four other former recipients of adultBasic filed an original-jurisdiction petition for review at the Commonwealth Court, styled as a class action. As amended, the petition contended, inter alia, that the redirection of tobacco settlement monies under Acts 46 and 26 violated the TSA’s requirements for appropriation and allocation of tobacco settlement funds. The petition also asserted that these enactments offended various provisions of the Pennsylvania Constitution governing legislative processes, including the general requirement that no bill shall be passed containing more than a single subject. Appellees sought declaratory, mandamus, and injunctive relief retroactively reestablishing the adultBasic program and reimbursing the program over two hundred million dollars. Appellee Eric Weisblatt commenced a separate action, also styled as a class action, proffering materially similar allegations and claims for relief, in the relevant respects, only naming executive-branch officials and agencies as defendants. Appellees in both proceedings moved for a preliminary injunction to preclude the Treasury from disbursing the tobacco settlement monies which were due to be received that month as appropriated per Act 46. Relief was denied by the court, however, upon its finding that the harm asserted by Appellees was neither immediate nor irreparable. Several weeks after the Commonwealth Court’s issuance of its opinion in Sears, the court issued a divided decision in "Weisblatt." During the pendency of the appeals, additional omnibus amendments to the Fiscal Code were enacted into law, which, inter alia, effectuated a repeal of the allocation formula provided in the TSA; the result formally displaced adultBasic funding within the terms of the TSA itself. In light of these amendments, Appellees renewed their request for relief from the supersedeas, which was again denied. Upon review of both sides' arguments appealing the Commonwealth Court's decision, the Supreme Court held that Appellees lacked standing to pursue the relief requested in their petitions for review. View "Sears v. Wolf" on Justia Law

The Commonwealth appealed the Philadelphia Court of Common Pleas' granting of appellee Edward Bracey’s Post Conviction Relief Act (PCRA) petition. The court determined appellee suffered from an intellectual disability, and vacated his death sentence. After review of the specific facts of this case, the Pennsylvania Supreme Court found no reversible error in that decision, and affirmed. View "Pennsylvania v. Bracey" on Justia Law

In 2009, two girls were sexually assaulted. Sixteen-year-old C.J. escaped, but eleven-year-old N.O. was threatened and lured into an alleyway, where she was brutally raped and sustained severe injuries requiring hospitalization and surgery. Police investigated and arrested Appellee Jose Carrasquillo, who made inculpatory statements during interrogation. Charges were lodged in two separate criminal proceedings, which were later consolidated for trial. Appellee decided to enter open guilty pleas to various sexual offenses, including rape, as well as other crimes. At the plea colloquy, the Commonwealth proffered that the evidence against Appellee that included his own statements, identification testimony from both victims, video surveillance recordings apparently showing Appellee with or in the vicinity of each victim close in time to the assaults, and DNA and fingerprint evidence linking Appellee to the rape of N.O. The plea court advised Appellee of his pertinent constitutional rights and the implications of waiver. The plea court accepted appellee's pleas and entered verdicts. Appellee was also informed that he could seek to withdraw his guilty plea at any time before sentencing and that the court "would have to consider whether or not the reasons for you doing so are fair and necessary, fair and appropriate, compared to the prejudice that that might cause to the Commonwealth's case and to their witnesses, and particularly in this case to child witnesses." Three and a half months later, the court conducted a sentencing hearing. After the defense rested, Appellee explained in allocution that he had pled guilty to spare N.O. suffering, and he therefore expressed surprise at his portrayal during the sentencing hearing. Appellee also stated that he had entered his plea because, absent a polygraph examination, his account would not have been believed and he would not have received a fair trial. In this appeal, the issue this case presented for the Supreme Court's review centered on the criteria governing the disposition of a presentence motion to withdraw a guilty plea. The Court's decision turned on the conclusion that a bare assertion of innocence was not, in and of itself, a sufficient reason to require a court to grant such a request. The Court was persuaded by the approach of other jurisdictions: "the proper inquiry on consideration of such a withdrawal motion is whether the accused has made some colorable demonstration, under the circumstances, such that permitting withdrawal of the plea would promote fairness and justice. The policy of liberality remains extant but has its limits, consistent with the affordance of a degree of discretion to the common pleas courts. This case, in our view, illustrates why the existing per se approach to innocence claims is unsatisfactory." In this case, the Supreme Court found that the trial court acted within its discretion to refuse the attempted withdrawal of the plea. View "Pennsylvania v. Carrasquillo" on Justia Law

In 2010, the United States Department of the Navy entered into an agreement with Contracting Systems, Inc. II ("CSI"), per which CSI served as the general contractor for the construction of an addition to, and renovations of, the Navy/Marine Corps Reserve Training Center in the Lehigh Valley. CSI, in turn, subcontracted with Appellee, Clipper Pipe & Service, Inc. for the performance of mechanical and heating, ventilation, and air conditioning work. Clipper filed suit against CSI and its surety, the Ohio Casualty Insurance Company (collectively "Appellants"), in the United States District Court for the Eastern District of Pennsylvania, asserting that CSI had failed to pay approximately $150,000 to Clipper, per the terms of their agreement. Among other claims, Clipper advanced one under the Contractor and Subcontractor Payment Act (CASPA). Appellants moved for summary judgment, arguing that CASPA did not apply to public works projects, because a governmental entity does not qualify as an "owner" under the statutory definition, as such an entity is neither a "person" nor an "other association." The federal district court denied relief on Appellants' motion. Among other aspects of its holding, the court followed "Scandale Associated Builders & Eng'rs, Ltd. v. Bell" which held that a governmental entity may be an "owner" under CASPA, since the statutory definition of "person" does not exclude the federal government, and the purpose of CASPA is to protect contracting parties. Clipper prevailed at the subsequent jury trial, and the district court awarded interest, penalties, and attorney fees. Appellants appealed to the United States Court of Appeals for the Third Circuit. The Pennsylvania Supreme Court accepted certification from the Third Circuit to determine whether a CASPA applied to the public works project in this case. After review, the Supreme Court concluded that CASPA did not apply to a construction project where the owner was a governmental entity. View "Clipper Pipe v. Ohio Casualty Ins." on Justia Law

This appeal was a companion case with "Pennsylvania v. Carrasquillo." The issue presented centered on whether a common pleas court was required to permit withdrawal of a guilty plea, upon the defendant-appellee's assertion of innocence. Appellee stabbed his estranged wife, Kimberly, to death. He immediately surrendered to police and confessed. Subsequently, he pled guilty to first-degree murder and possession of an instrument of crime. In exchange for the plea, the Commonwealth was to recommend that Appellee would receive the mandatory sentence of life imprisonment for first-degree murder and a consecutive term of incarceration pertaining to the possessory offense. Just over two months later, when Appellee appeared for sentencing, he advised the court that he wished to withdraw his plea. In "Carrasquillo," the Pennsylvania Supreme Court determined that a bare assertion of innocence (such as Appellee provided as the basis for withdrawing his guilty plea) was not, in and of itself, a sufficient reason to require a court to grant such a request. Accordingly, and for the reasons set forth more fully in that case, the common pleas court did not err in denying Appellee's withdrawal motion. View "Pennsylvania v. Hvizda" on Justia Law

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