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Commonwealth v. Stevenson, V., Aplt.
Supreme Court of Pennsylvania · 2022-09-29
The case involved Viktor Stevenson, who was convicted of indirect criminal contempt for violating a final Protection from Abuse (PFA) order by entering his former fiancé's home. The Pennsylvania Supreme Court affirmed the Superior Court's decision upholding the conviction. The court held that to convict someone of indirect criminal contempt for violating a PFA order, the Commonwealth must prove beyond a reasonable doubt that the defendant had actual knowledge of the order at the time of the violation, regardless of how that knowledge was obtained. In this case, evidence including the prior temporary order, the scheduled hearing that Stevenson skipped, and statements made to him at the scene sufficiently demonstrated his actual knowledge.
criminal lawfamily law
Commonwealth v. Reid, A., Aplt.
Supreme Court of Pennsylvania · 2022-08-16
This case involves Albert Reid, who was convicted by a jury of two counts of first-degree murder and sentenced to death; he later filed a PCRA petition challenging his convictions. The primary remaining issue on appeal was whether Reid was incompetent to stand trial and represent himself, and whether prior counsel was ineffective for failing to litigate that issue. The Supreme Court of Pennsylvania held that the PCRA court erred in assessing the substantive competency claim by not properly considering newly proffered post-conviction evidence of mental health issues. The court therefore vacated the PCRA court's order in part and remanded for further proceedings applying the framework from Commonwealth v. Santiago to determine if a meaningful retrospective competency hearing is possible. The decision focused on ensuring due process in evaluating competency based on contemporaneous and new evidence.
criminal lawprocedure
Commonwealth v. Reid, A., Aplt.
Supreme Court of Pennsylvania · 2022-08-16
This case is a direct appeal from the dismissal of a Post Conviction Relief Act (PCRA) petition filed by Albert E. Reid, who was convicted of burglary and two counts of first-degree murder for killing his estranged wife Carla Reid and her fourteen-year-old daughter D.M. in 1996, resulting in a death sentence. The Pennsylvania Supreme Court reviewed numerous claims of ineffective assistance of counsel and other alleged errors but affirmed the PCRA court's order in most respects. The court remanded solely for the PCRA court to issue a supplemental opinion explaining its denial of relief on the claims regarding the appellant's competency to stand trial and represent himself, as well as prior counsel's alleged ineffectiveness for not pursuing that issue. The reasoning emphasized that other claims lacked merit or failed to show prejudice, while the competency-related issue required further explanation from the lower court due to its fact-intensive nature.
criminal lawprocedure
PA Enviro Defense Fdn, Aplt. v. Commonwealth
Supreme Court of Pennsylvania · 2022-08-05
The Pennsylvania Environmental Defense Foundation challenged provisions of the 2017 and 2018 General Appropriations Acts and related Fiscal Code amendments, claiming they violated Article I, Section 27 (the Environmental Rights Amendment) of the Pennsylvania Constitution by improperly using oil and gas leasing revenues from state forest and park lands. This was the third in a series of cases in which PEDF contested budgetary transfers and funding decisions following prior rulings that treated such revenues as part of a public trust. The Supreme Court of Pennsylvania affirmed the Commonwealth Court's order denying relief. It held that the challenged provisions either did not involve trust assets or complied with trust principles under Section 27, as some funds came from non-trust sources and others were not shown to breach fiduciary duties.
environment
Kneebone, R. v. Lutz, P., Aplts.
Supreme Court of Pennsylvania · 2022-04-28
The case concerned Patrick and Pamela Lutz's application for a dimensional variance to allow an 18-foot encroachment into the rear setback on their undersized lot in Plainfield Township's Farm and Forest Zoning District so they could construct an addition. The Zoning Hearing Board unanimously granted the variance after finding that strict compliance created an unnecessary hardship and that the addition would not harm neighboring properties, and the trial court affirmed based on substantial evidence. The Commonwealth Court reversed, concluding that the Board lacked substantial evidence of hardship. Chief Justice Baer, writing in support of reversal, reasoned that the Commonwealth Court failed to apply the deferential abuse-of-discretion standard applicable when no new evidence is taken and that Hertzberg v. Zoning Board of Adjustment permits a relaxed showing of unnecessary hardship for dimensional variances.
property
Commonwealth v. Edwards, D., Aplt.
Supreme Court of Pennsylvania · 2022-04-12
This case involved Derrick Edwards, who was convicted of multiple armed robberies in Philadelphia but received a new trial after the prosecutor was found to have violated Batson v. Kentucky by using a peremptory strike against an African American juror based on race. Edwards sought to dismiss the charges entirely on double jeopardy grounds under the Pennsylvania Constitution, arguing that the prosecutor's discriminatory intent constituted overreaching that barred retrial. The Supreme Court of Pennsylvania held that the Batson violation did not rise to the level of prosecutorial overreaching under its prior decision in Commonwealth v. Johnson, which extends double jeopardy protections to reckless misconduct that deprives a defendant of a fair trial. The court reasoned that the single discriminatory strike, after accepting several other African American jurors, did not demonstrate an intentional or reckless disregard for the fairness of the trial process sufficient to preclude retrial, as opposed to mere error warranting a new trial. It therefore affirmed the lower courts' denial of the motion to dismiss.
criminal lawcivil rightsprocedure