Justia Pennsylvania Supreme Court Opinion Summaries

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

In the Spring of 2014, the supervising judge for the Thirty-Fifth Statewide Investigating Grand Jury found that there were reasonable grounds to believe that an investigation should be conducted into allegations that grand jury secrecy had been compromised. The work of a Special Prosecutor culminated in a grand jury presentment recommending the filing of criminal charges against Pennsylvania Attorney General Kathleen Kane. Through the filing of an action in quo warranto, Attorney General Kane asked the Supreme Court to quash the appointment of a special prosecutor investigating violations of grand jury secrecy requirements. The Supreme Court affirmed, concluding that the supervising judge acted within his authority and sound prerogative in appointing the Special Prosecutor: "although we recognize that there are legitimate concerns arising out of a judicial appointment of a special prosecutor, we follow the approach of the United States Supreme Court and the many other jurisdictions which have found such appointments proper as an essential means to vindicate the courts' own authority." The request for quo warranto relief was denied. View "In Re: 35th Statewide Inv Grand Jury" on Justia Law

The issue this discretionary appeal presented for the Pennsylvania Supreme Court's review centered on whether a county was required to collectively bargain with a union representing county employees before a local workforce investment board could seek competitive bids for the provision of workforce development services previously provided by the same county employees. The issue reduced to whether the local board acted as the county's agent when it sought the bids and ultimately contracted with private entities for the services at issue. The appellant Union argued that the Local Board was to merely "advise and assist" the County in "setting policy to promote workforce investment programs," and that ultimately it was the County who needed to make the decision to bargain with the Union over seeking competitive bids. The Supreme Court found that substantial evidence supported the Pennsylvania Labor Relations Board's finding that the County lacked control over the Local Board's decision to contract for the services through a competitive bid process, and that the decision was well within the statutory authority granted to the Local Board. As such, the Commonwealth Court's decision to affirm the Labor Relations Board's decision was affirmed. View "AFSCME, Council 87 v. Labor Relations Board" on Justia Law

Appellee Maria Brady had a lengthy history of foot problems. By 2007, both of her feet were in pain due to toe deformities. Appellee’s podiatrist, William Urbas, D.P.M., successfully treated toes on her left foot with surgery; he then turned his attention to her right foot. One of Appellee’s primary complaints on her right foot pertained to a hammer-toe condition of her second toe: this deformity caused the middle of Appellee’s second toe to rise above the plane of the foot, which in turn caused rubbing and pain when Appellee wore shoes. Dr. Urbas performed a total of four operations between March 2008 and January 2010. Before each surgery, he explained the risks and complications that could occur, and Appellee signed a consent form acknowledging her awareness of these possible outcomes. The first operation did not finally alleviate Appellee’s condition, and Dr. Urbas eventually performed three more surgeries, each involving, among other things, the removal of additional bone material with the expectation that the foot would, over time, generate soft tissue to fill the gap and provide flexibility. Nevertheless, Appellee’s pain persisted and, in the end, her toe was less stable and significantly shorter than it had been initially. In August 2010, Appellee consulted a different podiatrist, Dr. Harold Schoenhaus, who performed a bone-graft operation which returned the toe to approximately ninety percent of its original length. This procedure also had the effect of restoring some of the toe’s stability and substantially reducing the pain. Appellee testified that she was pleased with the outcome of Dr. Schoenhaus’ surgery and that she returned to all levels of activity. In December 2010, Appellee filed a complaint against Dr. Urbas, alleging that he negligently treated her toe in the three follow-up surgeries performed after March 2008. In this appeal by allowance involving alleged medical negligence, the issue before the Supreme Court centered on whether a doctor may introduce evidence that the patient was informed of and acknowledged various risks of surgery, although the complaint does not assert a cause of action based on a lack of informed consent. After unsuccessfully moving for a new trial on the basis that the trial court erred in admitting the consent evidence, Appellee appealed. The Superior Court vacated and remanded for a new trial. In concluding that the trial court had abused its discretion, the Superior Court court adopted the reasoning of the Supreme Court of Virginia regarding the relevancy of consent evidence in a medical malpractice case: assent to treatment does not amount to consent to negligence, regardless of the enumerated risks and complications of which the patient was made aware. In a trial on a malpractice complaint that only asserts negligence, and not lack of informed consent, evidence that a patient agreed to go forward with the operation in spite of the risks of which she was informed is irrelevant and should be excluded. The Supreme Court affirmed, holding that evidence that a patient affirmatively consented to treatment after being informed of the risks of that treatment is generally irrelevant to a cause of action sounding in medical negligence. View "Brady v. Urbas" on Justia Law

The Post Conviction Relief Act (PCRA) court, after a hearing, rendered an opinion in which it resolved several issues on remand from the Supreme Court. Pertinent to this appeal, the issue was whether appellant received ineffective assistance of trial counsel, and was therefore entitled to relief. With the remand proceedings complete, the Supreme Court considered the issue of whether appellant was entitled to relief based on the cumulative prejudicial effect of all of the alleged errors he set forth in his petition. The Court held that the PCRA court properly resolved the ineffectiveness claims before it, and the Supreme Court concluded that appellant was not entitled to relief on his claim of cumulative prejudice. Thus, the Court affirmed the order of the PCRA court and dismissed all of appellant's claims. View "Pennsylvania v. Simpson" on Justia Law