Justia Pennsylvania Supreme Court Opinion Summaries

The issue this case presented for the Supreme Court's review was the interpretation of the Commonwealth Charter School Law. Pursuant to the Charter School Law, the Walter D. Palmer Leadership Learning Partners Charter School was awarded a charter for a five-year term ending June 30, 2005. In late 2004, the Charter School filed a renewal application. On March 16, 2005, the School Reform Commission of the School District of Philadelphia (“SRC”) adopted a resolution that granted, “upon signing a new Charter Agreement,” the Charter School’s request for renewal of the charter for a second five-year period commencing on September 1, 2005. The SRC denied the Charter School's request for expansion of enrollment, and granted approval "to enroll a maximum of six hundred and seventy five (675) students and serve grades kindergarten through 8." The SRC and the Charter School then entered into, as of September 1, 2005, a legally binding agreement that incorporated the SRC Resolution in its entirety and extended the charter for five years ("the 2005 Charter"). The 2005 Charter explicitly referenced and incorporated the SRC Resolution, one provision of which capped student enrollment, explicitly mandated that the Charter School comply with the SRC Resolution; and explicitly constituted a legally binding, mutual agreement of five years duration, the terms of which could not be changed absent a written agreement signed by both parties. The legally binding nature of the terms of the 2005 Charter was mandated by a provision of the Charter School Law. Notwithstanding the terms of the 2005 Charter, the Charter School consistently enrolled more than the 675 students permitted by that Charter. For the 2007-2008 school year, the Charter School’s average daily enrollment was approximately 729 students; for 2008-2009 and 2009-2010, the average daily enrollment was approximately 732 and 765 students, respectively. In each school year, the School District of Philadelphia provided funding for 675 students based on the 2005 Charter. In July 2010, asserting that it had been underpaid by the School District, the Charter School requested that the Pennsylvania Department of Education withhold $1,678,579 from the School District's basic education subsidy allocation as payment to the Charter School for the students it had educated in addition to the 675 students permitted by the enrollment cap for school years 2007-2008, 2008-2009, and 2009–2010. The School District objected to the withholding and a hearing was held before the Department. The Secretary of Education determined that the Charter School had agreed and legally assented to the enrollment cap when it signed the 2005 Charter, and therefore, the Charter School was not entitled to payment for students enrolled above that cap in the 2007-2008 school year. However, with regard to the school years 2008-2009 and 2009-2010, the Secretary determined that the enrollment cap set forth in the 2005 Charter was no longer valid because of the enactment of an amendment to the Charter School Law which had become effective on July 1, 2008 (24 P.S. section 17-1723-A(d)). Based on his interpretation, the Secretary concluded that, to maintain the 2005 Charter’s enrollment cap subsequent to the effective date of the amendment, the School District was required to re-obtain the Charter School’s “legal assent” to the cap. Ultimately, the Secretary determined that the Charter School was entitled to payment by the School District for the education of all the students enrolled in the school for the years 2008-2009 and 2009-2010, including those enrolled beyond the cap. The School District appealed to the Commonwealth Court, which affirmed. The School District appealed to the Supreme Court, which reversed: "based on the plain text of 24 P.S. section 17-1723-A(d), we conclude that an enrollment cap is valid if agreed to by the parties as part of a written charter." View "Sch. Dist. of Philadelphia v. Dept. of Education" on Justia Law

Appellant Richard Baumhammers went on a two-hour crime spree in 2000 whereby he shot six racial or ethnic minorities. Four victims died of their wounds; the fifth was paralyzed from the neck down. During the spree, appellant burned his Jewish neighbor's house, and damaged two synagogues by spray painting swastikas on the outside then shooting bullets into both. Appellant was charged with five counts of first-degree murder and related offenses. He was found guilty by jury and sentenced to death. Appellant petitioned for post-conviction relief, which was ultimately denied. On appeal to the Supreme Court, appellant argued multiple instances of violations of appellant's constitutional rights were violated, and multiple instances of alleged ineffective assistance of counsel (both at trial and in the penalty phase). The Supreme Court found no reason to overturn the PCRA Court's ruling on appellant's claims of error, and therefore affirmed appellant's conviction and sentence. View "Pennsylvania v. Baumhammers" on Justia Law

Appellant fatally shot three men outside a private social club in Altoona after he and two friends were denied admission. Appellant was convicted and received the death penalty on three counts of first-degree murder. On direct appeal, appellant raised six issues for the Supreme Court's review, all challenging alleged errors in trial procedure and sufficiency of the evidence. Finding no errors, and holding that the evidence was sufficient to convict appellant and support his sentence, the Supreme Court affirmed.View "Pennsylvania v. Padilla" on Justia Law

Ronald Weiss appealed the denial of guilt-phase claims raised in his petition for post-conviction relief. Upon review, the Supreme Court concluded that the Post Conviction Relief Act (PCRA) court’s rejection of Appellant’s guilt-phase claims was supported by the record and free from legal error. However, because the PCRA court granted relief on a penalty phase issue and the Commonwealth did not cross-appeal, Appellant was afforded a new penalty hearing. Accordingly, the order of the PCRA court was affirmed. View "Pennsylvania v. Weiss" on Justia Law

The issue on appeal to the Supreme Court in this case centered on whether the Commonwealth Court erred by affirming the reversal by the Workers’ Compensation Appeal Board (“WCAB”) of the decision of a workers’ compensation judge (“WCJ”) that granted Appellant Philip Payes's claim application. The WCJ determined that Appellant was entitled to workers’ compensation disability benefits based on factual findings that Appellant established the existence of a mental disability that had been caused by abnormal working conditions. Upon review, the Court concluded that the Commonwealth Court erred in reversing the WCJ’s decision, and accordingly reversed the order.View "Payes v. WCAB (PA State Police)" on Justia Law

The Supreme Court granted allocatur in this case to decide “whether and when a reviewing court considering a challenge to a pretrial ruling, whether in a post-verdict or appellate context, may look beyond the record of evidence presented at the suppression hearing.” The Superior Court relied on a footnote from the Court's decision in "Commonwealth v. Chacko," (459 A.2d 311 (Pa. 1983)), for the proposition that “it [was] appropriate to consider all of the testimony, not just the testimony presented at the suppression hearing, in determining whether evidence was properly admitted.” The Superior Court, (pursuant to "Chacko") considered evidence adduced for the first time at trial when deciding whether the police properly seized contraband from Appellant, L.J. Specifically, the court affirmed the trial court’s denial of suppression because trial testimony established that L.J. voluntarily consented to the search at issue. Upon review of the record, the Supreme Court found that the Superior Court’s reliance on Chacko was understandable but ultimately misplaced. Accordingly, the Court vacated the disposition order, and remanded this case to the juvenile court for a new suppression hearing. View "In the Interest of: L.J." on Justia Law

Appellee was sentenced to death for the 1998 murder of James Mowery. Although represented, Appellee filed a pro se document in federal court, demanding that his direct appeal be discontinued and that he be allowed to proceed immediately to execution. Appellee also filed papers reflecting that he wished to discharge counsel due to irreconcilable differences, and that counsel was forbidden to communicate with Appellee. Shortly thereafter, in December 2008, the Supreme Court affirmed Appellee’s judgment of sentence. Appellee asked the federal district court to supply him with a replacement attorney to assist him in pursuing guilt-phase claims at federal court. The court denied the request, stating that Appellee had not established the existence of an irreconcilable conflict with counsel. Separately, Appellee petitioned the Third Circuit Court of Appeals for mandamus relief in the form of an order directing the district court to rule on his pro se filings. In August 2010, the Third Circuit denied the petition without prejudice, retaining jurisdiction and instructing the district court to determine whether Appellee was competent to waive counsel. The Commonwealth appealed an order finding Appellee incompetent to waive his state post-conviction rights, including his right to counsel. The Supreme Court determined the Commonwealth was not entitled to relief, and ultimately affirmed the PCRA court's order. View "Pennsylvania v. Wright" on Justia Law

In the summer of 2005, in connection with a charity event, several persons were riding motorcycles southbound on Route 309 in Wilkes-Barre. At that same time, Appellee was driving his vehicle on Route 309 in the opposite direction. His child was in the back seat of the car. As the motorcycles approached, Appellee crossed the double yellow line and drove directly into them. One person was killed, and four others were seriously injured. A blood test to which Appellee submitted upon his arrest showed he had .76 nanograms of morphine in his system. As a result, Appellee was charged in a criminal information with multiple offenses including homicide by vehicle while driving under the influence; homicide by vehicle; aggravated assault by vehicle while driving under the influence; accidents involving death or personal injury while not properly licensed; and endangering the welfare of children. Appellee entered an open guilty plea to all 20 counts in the information. On June 9, 2006, Appellee was committed to the custody of the Department of Corrections (“DOC”) to commence serving his jail sentence. Over two years later, the trial court was asked by the DOC to comment on Appellee’s application for participation in a pre-release program. The trial court informed the DOC that Appellee was ineligible for participation in such a program “at this stage of his sentence.” The trial court further informed the DOC that a review of the transcript from Appellee’s sentencing hearing demonstrated "beyond all doubt that the intent of this court was to impose consecutive sentences.” The Commonwealth subsequently filed a Petition to Clarify Sentence, alleging that it and the DOC calculated Appellee’s aggregate term of imprisonment differently. Over Appellee’s objections, the court granted the Commonwealth's Petition and restated Appellee’s sentence. On appeal, the Superior Court held that the trial court did not have the inherent power to issue the latter order. Finding no error with the Superior Court's order, the Supreme Court affirmed. View "Pennsylvania v. Borrin" on Justia Law

Appellant Christopher Roney appealed the denial of his petition filed pursuant to the Post Conviction Relief Act (“PCRA”), following his conviction of first-degree murder and other offenses, the imposition of a sentence of death, and the Supreme Court's affirmance of his judgment of sentence. Finding that the PCRA court's determinations were supported by the record and free of legal error, the Supreme Court affirmed the PCRA court's order. View "Pennsylvania v. Roney" on Justia Law

Appellant Glenn Lyons appealed the death sentence he received after a jury convicted him of first-degree and third-degree murder for the 2008 stabbing death of Kathy Leibig. Having addressed and rejected each of Appellant's claims of error, the Supreme Court affirmed his death sentence.View "Pennsylvania v. Lyons" on Justia Law