Justia Pennsylvania Supreme Court Opinion Summaries

The Commonwealth filed a criminal complaint charging appellee Junius Burno with, inter alia, two counts of criminal homicide. A jury found him guilty on two counts of first-degree murder. The jury found one aggravating circumstance and the mitigation catchall, and determined that the aggravating circumstance outweighed the mitigating, thus sentencing appellee to death. The Commonwealth appealed the trial court’s order granting appellee a new trial based on his trial counsel’s alleged ineffective representation in failing to object to remarks made by the prosecutor during her closing argument to the jury. Appellee filed a cross-appeal claiming the trial court erred in refusing to grant him relief on numerous remaining issues, which he raised in post-sentence motions. Upon review of the trial court record, the Supreme Court reversed the trial court’s order granting Burno’s motion for a new trial, remanded for the resolution of any pending preserved claims related to trial court error raised in appellee's post-sentence motion, and dismissed his claims of ineffective assistance of trial counsel without prejudice to his right to pursue those collateral claims under the PCRA. View "Pennsylvania v. Burno" on Justia Law

Appellant raised twenty-five lettered issues, "nearly exhausting the alphabet," to challenge the two death sentences he received after a jury convicted him of first degree murder and abuse of corpse. "Appellant’s brief is replete with beyond-boilerplate allegations containing sparse argument and even less citation to supporting authority or identification of pertinent portions of the record. His attempt to incorporate the entire trial transcript into his brief [was] insufficient, [. . .] as are his bald assertions containing no developed argument." Finding no reversible error, the Supreme Court affirmed appellant's convictions and sentences. View "Pennsylvania v. Perez" on Justia Law

In 1975, the Pennsylvania Labor Relations Board certified Intervenor, AFSCME, District Council 89 ("Union") as the exclusive representative of a unit for purposes of collective bargaining which included, inter alia, prison security guards, special guards, and transportation, maintenance, and supply employees. Since the unit certification, Appellee Lancaster County and the Union have been parties to several collective bargaining agreements. However, notwithstanding the Board's certification of maintenance employees in the bargaining unit, the parties have not negotiated over the wages, hours, and conditions of employment for the Maintenance Mechanic I and Maintenance Mechanic II positions. In 2009, the County Commissioners adopted a reorganization plan that placed all County maintenance and custodial employees under the centralized Facilities Management Department. Two days later, the Union filed with the Board a petition for bargaining unit clarification which sought to include the positions of Maintenance Mechanic I and Maintenance Mechanic II in the unit of prison guards. The issue on appeal to the Supreme Court was whether county prison maintenance employees who supervise inmates constituted "guards at prisons" for purposes of collective bargaining unit placement under the Pennsylvania Employe Relations Act. After review, the Court held that the Commonwealth Court did not apply the proper level of deference in its appellate review of the decision of the Labor Relations Board which concluded that supervisory maintenance employees at issue were “guards at prisons” for purposes of collective bargaining. Thus, the Court reversed the decision of the Commonwealth Court and reinstated the Board’s determination. View "Lancaster Cty v. PA Labor Relations Bd." on Justia Law

This appeal centered on whether the Pennsylvania School Code's compulsory school age and attendance provisions applied to children under eight years old whose parents voluntarily enrolled them in public kindergarten programs made available by school districts. The trial court and Commonwealth Court both held that once a child who meets a district's minimum entrance age is enrolled in a district's public school kindergarten program, the child is subject to compulsory school attendance, meaning continuous and consistent attendance without excessive unexcused absences. Finding no reversible error, the Supreme Court affirmed. View "Pennsylvania v. Kerstetter" on Justia Law

This case was among a number of civil actions brought by state attorneys general against pharmaceutical companies challenging the propriety of prescription drug pricing, as it impacted third-party reimbursement for brand-name drug purchases subsidized by government social welfare programs. The Commonwealth focused its claims upon alleged overpayments tied to the use of an industry benchmark figure (average wholesale price, or "AWP") in government reimbursement formulas. While many issues of concern were raised about the Commonwealth’s approach to this litigation and the judgment it has obtained, the Pennsylvania Supreme Court overturned the monetary component of that judgment grounded on the Commonwealth’s failure to offer a rational accounting for the billion dollars in rebate monies which Commonwealth agencies received from the drug manufacturers it sued. View "Pennsylvania v. TAP Pharmaceutical Products, Inc." on Justia Law

In consolidated appeals, the issue before the Supreme Court was whether the manifestation of an occupational disease outside of the 300-week period prescribed by Section 301(c)(2) of the Workers’ Compensation Act removes the claim from the purview of the Act, such that the exclusivity provision of Section 303(a) does not apply. After careful consideration, the Supreme Court concluded that claims for occupational disease which manifest outside of the 300-week period prescribed by the Act do not fall within the purview of the Act, and, therefore, that the exclusivity provision of Section 303(a) does not apply to preclude an employee from filing a common law claim against an employer. Accordingly, in these cases, the Court reversed the Superior Court's decision.View "Tooey v. AK Steel" on Justia Law

The issue before the Supreme Court in this case centered on the proper scope of the “illegal sentence” doctrine. The Superior Court held that the claim at the heart of this appeal, implicated the legality of appellee’s sentence; found that the claim was meritorious; vacated appellee’s aggravated assault conviction; and then directed that the principle of double jeopardy precluded appellee from being recharged in connection with the assault. The Supreme Court addressed the question of whether the claim was subject to waiver. The Court found that appellee’s claim concerning her underlying conviction for aggravated assault did not implicate the legality of the sentence for purposes of issue preservation. Accordingly, the Court vacated the Superior Court's order and remanded the case back to to that court for consideration of appellee’s remaining appellate claims. View "Pennsylvania v. Spruill" on Justia Law

The Commonwealth appealed a court of common pleas order that declared Section 9543(a)(1)(i) of the Post-Conviction Relief Act (PCRA) was unconstitutional as applied to Petitioner Emma Turner. The PCRA court held that barring Petitioner from obtaining collateral relief on her timely claim of trial counsel ineffectiveness because she had completed serving her sentence, as Section 9543(a)(1)(i) requires, would violate Petitioner’s constitutional due process right to be heard on this issue. The PCRA court, therefore, permitted Petitioner to proceed with her PCRA petition, despite her ineligibility under Section 9543(a)(1)(i), granted an evidentiary hearing, and ultimately awarded her a new trial. Because the Supreme Court concluded that Petitioner had no due process right to be heard outside of the limits imposed by Section 9543(a)(1)(i) of the PCRA, and that she had the opportunity to attempt to vindicate her claim on direct appeal under "Commonwealth v. Bomar," (826 A.2d 831 (Pa. 2003)), or within the time frame permitted by the PCRA, the Court reversed the PCRA court's decision and held that this section was constitutional as applied to Petitioner.View "Pennsylvania v. Turner" on Justia Law

In 1994, Appellee Joseph Elliott was convicted of the first degree murder of Kimberly Griffith, and sentenced to death. Following the denial of relief on direct appeal, appellee filed a petition for collateral relief. Without holding an evidentiary hearing, the Court of Common Pleas of Philadelphia County (the PCRA court) granted appellee a new trial on the following grounds: (1) that trial counsel was ineffective for failing to prepare for trial or interview appellee in person prior to trial; and (2) that trial counsel was ineffective for failing to object to the medical examiner’s testimony regarding the estimated time of the victim’s death. The PCRA court denied appellant relief on his remaining claims. The Commonwealth appealed the PCRA court’s grant of a new trial, and appellee filed a cross-appeal from the denial of relief on his other issues. After careful consideration of the PCRA Court record, the Supreme Court found appellee did not meet his burden to prove he received ineffective assistance of counsel, and that it was an error for the lower court to grant a new trial without an evidentiary hearing. Therefore the Supreme Court reversed the grant of a new trial, and affirmed the denial of relief on appellee's remaining claims.View "Pennsylvania v. Elliott" on Justia Law

Appellant Annette Shoap sustained a work-related injury in the nature of a left shoulder injury while working as an employee of Phoenixville Hospital. She began receiving temporary total disability benefits pursuant to a Notice of Compensation Payable dated 2003. The treatment for Appellant’s injury included three surgeries and physical therapy. In 2007, the employer filed a modification petition alleging both that Appellant’s physical condition had improved and that work was generally available to her within her physical restrictions in the relevant geographical area, as demonstrated by two labor market surveys. Appellant denied the material allegations of Employer’s petition, and a hearing was held before a Workers’ Compensation Judge. After the WCJ ruled in the employer's favor, Appellant unsuccessfully appealed to the Workers' Compensation Appeal Board and Commonwealth Court. On appeal to the Supreme Court, Appellant asserted that the Commonwealth Court erred by concluding that “substantial gainful employment existed” for purposes of granting a modification of her compensation benefits pursuant to Section 306(b) of the Workers' Compensation Act, despite the fact that her application for the specific jobs involved failed to result in any offers of employment. Secondarily, Appellant argued that the Commonwealth Court, even if correct in its interpretation of Section 306(b), erred by not remanding the case for further evidentiary development based on its interpretation of Section 306(b), which Appellant contended represented a change in the standard for evaluating cases under that statute. After careful review, the Supreme Court agreed with Appellant's second contention, and reversed and remanded for further proceedings. View "Phoenixville Hospital v. WCAB (Shoap, Aplt)" on Justia Law