Justia Pennsylvania Supreme Court Opinion Summaries

In 2011, while driving home from a funeral reception, Appellee William Bell crossed the center line of a road and struck another vehicle. A woman was killed as a result of the impact. Following trial, Bell was convicted of driving under the influence of alcohol or a controlled substance-bac.16+, homicide by vehicle while DUI, and homicide by vehicle, In this appeal, the Supreme Court addressed questions of whether convictions for homicide by vehicle and homicide by vehicle while driving under the influence (DUI) merged for operating privilege suspension purposes under the Vehicle Code, and, more generally, whether the criminal doctrine of merger was applicable to the collateral civil consequences which flow from merged, underlying criminal convictions. The Court held that the Commonwealth Court improperly found the criminal doctrine of merger was applicable in the civil arena of operating privilege suspensions under 75 Pa.C.S. sections 1532(a), (a.1). Accordingly, the Supreme Court reversed. View "Bell v. Bureau of Driver Licensing" on Justia Law

Appellant Kenneth Hairston was convicted of two counts of murder and sentenced to death for each count. He failed to file a timely post-conviction motion or appeal, and thereby waived any claims of error. The Supreme Court automatically reviewed the case, evaluated the sufficiency of the evidence supporting the convictions, and the sentences appellants receive. The Supreme Court affirmed appellant's convictions and sentence. Appellant thereafter moved for reinstatement of his appellate rights nunc pro tunc. After the trial court granted appellant's motion, he raised numerous claims of error at trial relating to his convictions. Upon consideration of those claims, the Supreme Court found no reversible error and reaffirmed his convictions and death sentence. View "Pennsylvania v. Hairston" on Justia Law

Appellant Patrick Stollar was convicted for the murder of an elderly Upper Saint Clair woman in 2003. Appellant received the death penalty for the murder, as well as a ten to twenty year sentence for predicate robbery and burglary charges. Appellant appealed the denial of his post-sentence motions, raising three issues for the Supreme Court's consideration. After review of those issues, the Supreme Court concluded the arguments appellant raised were without merit and affirmed his convictions and sentences.View "Pennsylvania v. Stollar" on Justia Law

In a products liability matter, the issue before the Supreme Court was whether under Pennsylvania law a pharmaceutical company was immune from responding in damages for a lack of due care resulting in injury or death except for two discrete grounds: drug impurities or deficient warnings. Appellee made her primary claim against the makers of "phen-fen" as one of "negligence - unreasonable marketing of a dangerous rug and unreasonable failure to remove the drug from the market before 1997." The manufacturer moved for summary judgment, arguing that the appellee failed to assert a cognizable cause of action. The court of common please granted the company's motion. The Superior Court reversed, and both parties appealed, challenging respectively the Superior Court's holdings that pharmaceutical companies were not immune from claims of negligent drug design, and that claims of negligent marketing, testing, and failure of remove the drugs from the market were unviable claims. The Supreme Court affirmed in part, reversed in part, and remanded for further proceedings: "there has been no supported presentation here which would persuade us to immunize companies from the responsibility to respond in damages for such a lack of due care resulting in personal injury or death." View "Lance v. Wyeth" on Justia Law

In an interlocutory appeal, appellant Gordon Williams appealed the Superior Court's order reversing the trial court's determination that he had the right to present testimony of an expert witness to rebut the Commonwealth's evidence in support of its motion to allow a child victim to testify at a preliminary hearing via contemporaneous alternative method. Finding no reversible error, the Supreme Court affirmed.View "Pennsylvania v. Williams" on Justia Law

In a discretionary appeal, the issue before the Supreme Court in this case was whether, under an insurance policy for underinsured motorist coverage, the amount of an insured's recovery may be offset by the amount of all damages paid in satisfaction of the underlying judgment, or by only the amount of compensation paid under the auto insurance policy of the underinsured driver/tortfeasor. Under the circumstances of this case, the Court held that the amount of damages which could be offset against recovery under a UIM policy includes damages recovered from all tortfeasors. Accordingly, the Court reversed the Superior Court. View "AAA Mid-Atlantic Ins. Co. v. Ryan" on Justia Law

The Commonwealth appealed a Superior Court order which reversed an order denying Appellee’s petition pursuant to the Post Conviction Relief Act (PCRA), vacated his judgment of sentence, and remanded for a new trial. Appellee, who was on parole for a robbery conviction at the time, and his brother, Dustin Spotz, got into an argument. The argument began when Dustin’s fiancee's teenage son placed a pet gerbil in front of Appellee’s face while he was watching television, resulting in Appellee yelling at the child and threatening to physically harm him. This angered Dustin, and the argument escalated into a physical confrontation, during which Dustin stabbed Appellee twice in the upper back with a butter knife, slightly wounding him. In response, Appellee threatened to kill Dustin, and he proceeded upstairs, returning with a handgun. Appellee fired eight shots at Dustin, two of which fatally struck Dustin in the chest. Appellee was charged with first degree murder, third degree murder, voluntary manslaughter, aggravated assault, recklessly endangering another person, carrying a firearm without a license, and former convict not to own a firearm. Appellee took the stand at trial, claiming self-defense and defense of others, seeking an outright acquittal of the non-firearms charges. The jury acquitted Appellee of first and third degree murder, but convicted him of voluntary manslaughter (heat of passion), aggravated assault, recklessly endangering another person, and the firearms offenses. No timely direct appeal followed. However, in early 1996, Appellee filed a timely petition for PCRA relief in which he claimed ineffective assistance of trial counsel for failing to file a timely appeal from his judgment of sentence and seeking the restoration of his direct appeal rights nunc pro tunc. Following a hearing, the PCRA court granted Appellee relief, and he later filed a timely nunc pro tunc appeal. The Commonwealth subsequently filed a petition for allowance of appeal challenging the Superior Court’s summary finding trial counsel was ineffective. Appellee filed a protective cross-petition alleging the Superior Court erred in failing to address and resolve his additional ineffective assistance of counsel claims. Upon review, the Supreme Court concluded the Superior Court erred in vacating Appellee’s judgment of sentence and awarding him a new trial due to trial counsel’s ineffectiveness.View "Pennsylvania v. Spotz" on Justia Law

Appellant Francis Lagenella, Jr. argued on appeal to the Supreme Court that the Superior Court erred in affirming the trial court's denial of his motion to suppress evidence seized by a police officer during a warrantless inventory search of his vehicle following a valid traffic stop. Upon careful consideration of the trial court record, the Supreme Court concluded there was no basis for the officer to conduct an inventory search of Appellant's vehicle, therefore that the evidence discovered during the inventory search should have been suppressed.View "Pennsylvania v. Lagenella Jr." on Justia Law

Appellant Lebanon Valley Farmers Bank (LVFB) is a Pennsylvania chartered bank, and a subsidiary of Fulton Financial Corporation, which merged with Keystone Heritage Group, Inc. The merger made Fulton the parent company of Lebanon Valley National Bank, which merged with Farmers Bank as part of the transaction, thereby forming LVFB. Prior to the merger, both Farmers Bank and National Bank were "institutions" subject to the Shares Tax. For the 2002 tax year, LVFB filed a Bank Shares Tax return, which included National Bank's pre-merger value in its calculation of its six-year average share value, as required by the combination provision. However, in 2005, LVFB filed a petition with the Board of Appeals, seeking a refund of the portion of its 2002 tax payment attributable to National Bank’s pre-merger share value. It claimed disparate treatment because the combination provision was inapplicable when mergers involved out-of-state banks or banks less than six years old. The Commonwealth Court has held, under the plain language of the statute, the combination provision applied only to combinations of "institutions" (i.e., banks with Pennsylvania locations). The trial court held LVFB, as the survivor of the merger of two Pennsylvania banks, should have reported a taxable share value which averaged the combined share value of each constituent institution over the past six years and was, therefore, not entitled to a refund. However, the court ordered the Commonwealth "to provide meaningful retrospective relief" to cure LVFB’s non-uniform treatment. The Commonwealth Court affirmed the Board of Finance and Revenue's classification of the merged LVFB and the 2002 tax assessment. After careful review, the Supreme Court disagreed with the Commonwealth Court's decision and reversed for further proceedings. View "Lebanon Valley Farmers Bank v. Pennsylvania" on Justia Law

Appellant Guillermo Ramos entered an open guilty plea to charges of Manufacturing of a Controlled Substance (Marijuana) and Possession with Intent to Deliver a Controlled Substance (Marijuana) (PWID) both of which were violations of 35 P.S. 780-113(a)(30). The Commonwealth provided written notice that it intended to proceed under the mandatory sentencing provision of 42 Pa.C.S. 9712.1 and 35 Pa.C.S. 780-113(a)(30) with regard to Ramos’s guilty plea to the PWID count. The trial court sentenced Ramos to an aggregate sentence of five months to ten years in prison. Specifically, Ramos received nine months to five years in prison on the Manufacturing of a Controlled Substance (Marijuana) conviction to run concurrently with a term of five months to ten years in prison on the PWID conviction. In an amended sentencing order after stating its belief that the sentence it had imposed on the PWID count exceeded the allowable statutory maximum, the sentencing court modified the sentence for that conviction to a flat, five year prison term which it deemed to be a mandatory sentence pursuant to 42 Pa.C.S. 9712.1. The Superior Court unanimously affirmed his judgment of sentence in an unpublished memorandum opinion. Ramos challenged on appeal to the Supreme Court the legality of imposing a mandatory minimum sentence pursuant to 42 Pa.C.S. 9712.1. After review, the Supreme Court concluded that as the most recent and the specific statute, 42 Pa.C.S. 9712.1 controlled in this case. Accordingly, under 1 Pa.C.S. 1933, the general provision of 42 Pa.C.S. 9756(b)(1) must yield to the specific sentencing provisions of Section 9712.1(a) and Section 780-113(f)(2), respectively requiring a five-year mandatory minimum sentence and a maximum sentence of no more than five years for a violation of Section 780-113(a)(30). As such, the trial court properly imposed a flat, five-year prison sentence for Ramos’s PWID conviction. View "Pennsylvania v. Ramos" on Justia Law