Justia Pennsylvania Supreme Court Opinion Summaries

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

The issue before the Supreme Court in this case was whether the sentencing court properly ordered a convicted defendant, as a condition of probation, to pay amounts representing child support to the children of the victim of the defendant’s crime. The Superior Court held that such a condition was not permitted as a matter of law, vacated the sentencing court’s order, and remanded for resentencing, with a majority holding that the purpose behind the trial court's order was "clearly to support the decedent's children and not to rehabilitate [appellee]." The Supreme Court affirmed the Superior Court's order, but for different reasons: "while a probationary condition resembling the equivalent of child support is not prohibited, neither is it specifically approved. What is undeniable is that child support is a separate realm subject to very specific statutory standards and implementing guidelines."View "Pennsylvania v. Hall" on Justia Law

Appellees were teenagers at the time of the offense. They traveled to downtown Philadelphia with two others. When plans fell through, the group decided to “jump” the next person they saw, so their trip downtown would not have been “for nothing.” The young men saw the 36-year-old victim walking alone in a subway concourse and decided to attack him. At the goading of his four friends, one of the young men struck the victim from behind. The others promptly joined the attack; they punched, kicked, and stomped on the victim’s head and chest. As a result of the beating, the victim suffered a fatal asthma attack. In this appeal, the issue before the Supreme Court was whether conspiracy to commit third degree murder was a cognizable offense under Pennsylvania law. Because the Court held conspiracy to commit third degree murder was a cognizable offense, the Court reversed the Superior Court's order and remanded the case for reinstatement of the sentences.View "Pennsylvania v. Fisher, Stanton and Best" on Justia Law

Appellant was first convicted of possession of child pornography in 2001. That conviction resulted in a sentence of five years’ intermediate punishment which Appellant completed in September 2006. In January 2007, the police received a cyber-tip from the National Center for Missing and Exploited Children that Appellant had sent and received images of child pornography by computer. Appellant was arrested and arraigned on child pornography charges for a second time. The Commonwealth, although not required to do so at that point in the proceedings, informed Appellant that if convicted, he would be subject to a 25-year mandatory minimum sentence under the provisions of the Sentencing Code. At issue in this discretionary appeal before the Supreme Court was whether the 25-year mandatory minimum sentence of imprisonment imposed for Appellant’s second conviction of possessing child pornography was grossly disproportionate to the crime and, therefore, unconstitutional. The Court determined that the punishment was not grossly disproportionate to the crime and, accordingly, affirmed.View "Pennsylvania v. Baker" on Justia Law

In 2005, appellee was charged with two counts of criminal use of a communication facility, as well as single counts of delivery of cocaine, possession with intent to deliver cocaine, and simple possession of cocaine. Represented by retained private counsel, appellee proceeded to a jury trial in 2006, and was found guilty of all charges except one of the counts of criminal use of a communication facility. The trial court sentenced appellee to three to six years of imprisonment on the delivery charge and a concurrent sentence of two to four years on the criminal use of a communication facility conviction, both with credit for time served. The other drug convictions were merged for sentencing purposes. In 2007, appellee motioned for appointment of counsel in the trial court, which the trial court granted, appointing the Centre County Public Defender’s Office. Then, through counsel, appellee filed a PCRA petition seeking reinstatement of his appeal rights due to trial counsel’s failure to file a requested direct appeal. In 2008, following an earlier evidentiary hearing, the PCRA court reinstated appellee’s direct appeal rights nunc pro tunc, without addressing the substantive ineffectiveness claims. Appellee subsequently filed a notice of appeal and a statement, identifying eleven issues of ineffectiveness of trial counsel. The the PCRA court issued its opinion briefly addressing the merits of those ineffectiveness claims. In his Superior Court brief, appellee pursued only three of the eleven claims of ineffectiveness; he raised no preserved, direct review claims. The Superior Court panel determined that appellee’s merits arguments were “misguided” because he should have argued that the PCRA court, in its opinion reinstating appellee’s direct appeal rights nunc pro tunc, had erred by failing to consider the effect of appellee’s amended PCRA petition raising trial counsel’s ineffectiveness. Following “Pennsylvania v. Liston,” (941 A.2d 1279 (Pa. Super.2008) (en banc)), the Superior Court remanded to the PCRA court with instructions to permit appellee to file post-sentence motions nunc pro tunc in which he could raise his ineffectiveness claims. The issue before the Supreme Court in this case was the reviewability of claims of ineffective assistance of counsel on post-verdict motions and direct appeal under “Pennsylvania v. Bomar,” (826 A.2d 831 (Pa. 2003), cert. denied, 540 U.S. 1115 (2004)), and “Pennsylvania v. Grant,” (813 A.2d 726 (Pa. 2002)), including the question of whether ineffectiveness claims may be considered if accompanied by a waiver of review as of right under the Post Conviction Relief Act. The Supreme Court vacated the Superior Court’s order and remanded the case for further proceedings. View "Pennsylvania v. Holmes" on Justia Law