Justia Pennsylvania Supreme Court Opinion Summaries

The Pennsylvania Supreme Court granted review in this case to consider whether the Superior Court exceeded its scope and standard of review by substituting its judgment for that of the trial court in determining whether the child at issue in this case suffered abuse and whether that abuse was perpetrated by his mother. In 2011, twenty-one-month-old L.Z. was brought to Abington Memorial Hospital by L.F., his mother, and R.F., his maternal-aunt, who lived and cared for child together, to be treated for a deep cut nearly halfway around the base of his penis. The physicians also observed a dark bruise in the buckle area (above the jawbone and below the cheekbone) of Child's right cheek and another on his left cheekbone, as well as a severe diaper rash and yeast infection on the front of his body. The child was also unkempt with very dirty legs and feet. The presentation of these injuries was consistent with abuse and inconsistent with several explanations given by Mother and Aunt, which led the treating physicians to suspect that the injuries were non-accidental. The hospital staff filed a report with the Philadelphia Department of Human Services (DHS). After initial emergency proceedings, the court placed the child in protective custody, with physical custody given to Child's maternal grandfather. At an adjudicatory hearing at which Mother was present and represented by counsel but did not testify, the court considered DHS's dependency and aggravated circumstances petitions. The trial court determined that the Mother perpetrated the abuse, and that medical evidence presented by DHS demonstrated the child's injuries were neither accidental nor self-inflicted. The Superior Court reversed the trial court, and the Supreme Court's review of this matter centered on whether the Superior Court misapplied the Child Protective Services Law's (CPSL) definition of child abuse and whether the court misconstrued the evidentiary presumption of 23 Pa.C.S. 6381(d), which provided that when a child incurs abuse not ordinarily suffered absent acts or omissions of a parent or other person responsible, the fact of abuse suffices to establish prima facie evidence of abuse by the parent or person responsible. The Supreme Court concluded that the Superior Court indeed misapplied the CPSL and misconstrued the evidentiary presumption of 23 Pa.C.S. 6381(d). Accordingly, the decision of the Superior Court was reversed and the trial court's order reinstated. View "In the Matter of: L.Z." on Justia Law

The Third Circuit Court of Appeals certified a question of Pennsylvania law to the Pennsylvania Supreme Court. In August 2007, Appellee Wayne Harrison entered into a lease with Appellant Cabot Oil & Gas Corporation, per which Cabot obtained the exclusive right to explore oil-and-gas resources on Harrison's property. In exchange, the company agreed to pay an initial bonus plus a one-eighth royalty on oil or gas successfully produced from the land. Approximately halfway through the primary lease term, Harrison and his wife commenced a civil action against Cabot in a federal district court, seeking a declaration that the lease was invalid. The Harrisons alleged the company had fraudulently induced Mr. Harrison to enter into the lease via an agent's representation that Mr. Harrison would never receive any more than $100 per acre as a threshold bonus payment from a gas producing company. The Harrisons learned of other landowner-lessors receiving higher payments. The Pennsylvania Court accepted certification from the Third Circuit to address whether the primary term of an oil-and-gas lease should have been equitably extended by the courts, where the lessor pursued an unsuccessful lawsuit challenging the validity of the lease. In its counterclaim, Cabot sought a declaratory judgment that, in the event the Harrisons' suit failed, the primary term of the lease would be equitably tolled during the period of time during which the suit was pending, and, concomitantly, the lease would be extended for an equivalent period of time beyond what was provided by its actual terms. The district court awarded summary judgment in Cabot's favor on the suit to invalidate the lease. The court, however, resolved the counterclaim in the Harrisons' favor, concluding that Pennsylvania law does not provide for equitable extensions of oil and gas leases under the circumstances. Cabot appealed, arguing that it would be deprived of the full benefit of the bargained-for terms of its contract with the Harrisons by their "meritless lease challenges." Cabot contended Pennsylvania law provided that a party repudiates a contract, and thus effectuates an essential breach, when he makes an unequivocal statement that he will not perform in accordance with his agreement. The Pennsylvania Supreme Court disagreed with Cabot's contention, holding that the Harrisons' lease challenge was not an anticipatory breach of the lease. "Our reluctance, in this respect, is bolstered by the Harrisons' observation that oil-and-gas-producing companies are free to proceed according to their own devices to negotiate express tolling provisions for inclusion in their leases. [. . .] Certainly, in light of the voluminous decisional law, such companies are on sufficient notice of the prospect for validity challenges to warrant their consideration of such protective measures. [ . . .] Our determination is only that, consistent with the prevailing substantive law of this Commonwealth, the mere pursuit of declaratory relief challenging the validity of a lease does not amount to such." View "Harrison v. Cabot Oil & Gas Corp." on Justia Law

After state police seized over two and one-half pounds of marijuana from appellee Dreama Stotelmyer's residence pursuant to a search warrant, she was charged with possession of a controlled substance with intent to deliver (PWID) and possession of drug paraphernalia. Appellee entered an open guilty plea to PWID, and the Commonwealth nolle prossed the remaining charge. After entry of the plea, the Commonwealth entered notice of its intent to seek application of the mandatory minimum one-year sentence of incarceration. After a hearing, the trial court determined the Commonwealth proved by a preponderance of the evidence that appellee possessed over two pounds of marijuana with the intent to distribute it, invoking 18 Pa.C.S. 7508's mandatory minimum sentencing provisions. However, the trial court instead sentenced appellee to county intermediate punishment, imposing six months of work release from the county jail followed by six months of electronic home monitoring. Following the denial (by operation of law) of its motion to modify sentence, the Commonwealth appealed to the Superior Court, and then to the Supreme Court. The Supreme Court, after review, concluded the Superior Court erred in holding that appellee was eligible for the intermediate punishment sentence when the mandatory minimum sentence under 18 Pa.C.S. 7508 applied. View "Pennsylvania. v. Stotelmyer" on Justia Law

Appellants, twenty-four Pennsylvania voters, filed this action in 2006 in the Commonwealth Court's original jurisdiction to challenge the certification of six direct-recording electronic voting systems (DREs) models in use in Pennsylvania. Seeking declaratory, mandamus, and injunctive relief, Appellants claimed the Secretary of the Commonwealth should have been ordered to decertify the DREs which did not comply with the Election Code and compelled to adopt more rigorous testing standards. In this appeal, the issue presented for the Supreme Court's review centered on whether the Commonwealth Court erred in upholding the decision of the Secretary to certify certain DREs for use in Pennsylvania elections. The Commonwealth Court found that the DREs satisfied the certification requirements set forth in the Election Code and did not infringe on the fundamental right to vote as protected by the Pennsylvania Constitution. The Supreme Court concluded that the Commonwealth Court did not err in granting the Secretary's petition for summary relief. In particular, the Court found the Secretary exercised proper discretion in determining that the certified DREs satisfied the requirements for electronic voting systems set forth in the Election Code and the use of the DREs did not violate Appellants' fundamental right to vote as embodied within Article I, Section 5 of the Pennsylvania Constitution or the uniformity requirement in Article VII, Section 6 of the Pennsylvania Constitution. View "Banfield v. Sec'y of Commonwealth" on Justia Law

In this capital case, Herbert Blakeney, a.k.a. Shabazz Muhammad, appealed a Court of Common Pleas order that denied his petition for relief under the Post Conviction Relief Act (“PCRA”) without a hearing. Blakeney was convicted for the stabbing deaths of his wife and her 14-month old son in the early morning hours of February 2, 2000. After careful consideration of Blakeney's arguments on appeal, the Supreme Court found that the PCRA court properly dismissed his petition for post-conviction relief without a hearing. View "Pennsylvania v. Blakeney" on Justia Law

Appellant Gerald Watkins appealed the denial of his petition for post-conviction relief, which was filed after the Supreme Court’s affirmed his direct appeal from three death sentences imposed following his conviction for murdering his girlfriend, their newborn daughter, and his girlfriend’s son. Finding that the PCRA court did not err in denying appellant relief, the Supreme Court affirmed that court's decision. View "Pennsylvania v. Watkins" on Justia Law

Eight years after the charges against him were dismissed, appellee Todd Allen petitioned to have the property seized from the vehicle he was driving at the time of his arrest returned to him. The trial court concluded appellee's claim was waived because it had not been raised before the trial court that had jurisdiction over his criminal case. The Commonwealth Court applied a six-year statute of limitations, declining to follow the authority relied upon by the trial court ("Pennsylvania v. Setzer, 392 A.2d 772 (Pa.Super 1978)), and found appellee's motion was therefore untimely. The Commonwealth appealed the Commonwealth Court's judgment, and the Supreme Court was persuaded that the Commonwealth Court erred by applying the statute of limitations analysis. The Supreme Court concluded the trial court was correct in its analysis: because appellee had a prior opportunity to move for the return of the property in the pendency of criminal charges against him, failing to do so waived the issue. View "Pennsylvania v. Allen" on Justia Law

In a discretionary appeal, the issue this case presented for the Supreme Court's review centered on whether the Superior Court erred in making certain legal determinations leading it to vacate the judgment of sentence imposed upon Appellee Tyde Pasture following the revocation of his probation. Pasture sexually molested his live-in paramour’s daughter, beginning when she was nine years of age. Upon review, the Supreme Court concluded the Superior Court misapplied certain sentencing provisions, leading it to give insufficient deference to the revocation court’s imposition of the sentence following the revocation of Pasture’s probation. The Supreme Court vacated the Superior Court’s order and reinstated Pasture’s original judgment of sentence. View "Pennsylvania v. Pasture" on Justia Law

Appellant Christopher Johnson appealed the sentence of death he received for first-degree murder and related charges in the 2010 shooting death of Officer David Grove. Grove was patrolling an area near Gettysburg National Military Park when he saw appellant's car stopped near the Battlefield. Grove was later discovered by a fellow officer, shot three times, including a fatal shot to the back of the neck. Appellant raised multiple issues on appeal to the Supreme Court, but finding no reversible error, and that the evidence sufficiently supported the sentence, the Supreme Court affirmed appellant's sentence of death. View "Pennsylvania v. Johnson" on Justia Law

In 2012, the Commonwealth filed a criminal complaint against appellee Jason Hoover alleging he and two co-conspirators, Barry Martell and D.M. (a juvenile), stole parts and equipment from RES Coal Company and later sold the stolen parts to a local salvage yard. The Commonwealth appealed Superior Court Order vacating appellee’s judgment of sentence for theft by unlawful taking, receiving stolen property, criminal conspiracy, and corruption of minors, and remanding for a new trial. The Superior Court concluded that the trial court abused its discretion in determining that the probative value of appellee’s prior crime of dishonesty substantially outweighed its prejudicial effect. The Supreme Court reversed and remanded: "[t]here was no need, or warrant, for the Superior Court to seek to innovate a novel standard for admitting a prior conviction for impeachment purposes, particularly one based on federal sources, since the applicable Pennsylvania Rule of Evidence and the corresponding federal rule, F.R.E. Rule 609, are quite distinct. Thus, while subsection (d)(2) of the corresponding federal rule limits the admissibility of juvenile adjudications to those of witnesses other than the defendant, subsection (d) of the Pennsylvania rule, as stated, contains no such limitation, but specifically allows the use of juvenile adjudications for impeachment purposes. Thus under Pennsylvania law, prior adult convictions of crimes of dishonesty remain fair game for impeachment in appropriate circumstances. The case was remanded for the Superior Court to consider appellee’s remaining claim regarding appellee’s proposed alibi testimony. View "Pennsylvania v. Hoover" on Justia Law