J. Michael Eakin

The case involves Terrance Williams' fourth PCRA petition challenging his 1986 death sentence for the first-degree murder of Amos Norwood. The petition alleged that the Commonwealth willfully suppressed evidence from its files, including notes showing Norwood had sexually abused young adolescents possibly including Williams, which the prosecution knew when it portrayed Norwood as kind and innocent during the penalty phase. The PCRA court found a Brady violation because the evidence was material and could have been used to impeach witnesses and argue for mitigation, and it granted a new penalty phase trial. The Supreme Court affirmed, concluding that an objective review showed capable defense counsel could have used the suppressed evidence to seek a different result in sentencing.

criminal lawprocedure

In this case, the Commonwealth appealed a lower court's decision granting Terrance Williams post-conviction relief under the PCRA, which vacated his death sentence for first-degree murder, robbery, and conspiracy and ordered a new penalty phase trial. The Supreme Court of Pennsylvania affirmed the order, holding that the prosecution had willfully suppressed material exculpatory evidence about the victim's sexual abuse of adolescents, including possibly Williams himself, in violation of Brady v. Maryland. This evidence, which was known to prosecutors at the time of trial but not disclosed to the defense, could have been used to impeach witnesses who portrayed the victim as kind and innocent and to argue for mitigating circumstances in the penalty phase. The court reasoned that the suppression prejudiced Williams by affecting defense preparation and trial strategy, as an objective analysis showed capable counsel could have used the information to seek a different sentencing outcome.

criminal lawprocedure

This case involves Terrance Williams' PCRA petition seeking to vacate his death sentence for the 1984 murder of Amos Norwood, based on a claim that the Commonwealth withheld evidence of the victim's alleged homosexual ephebophilia, which Williams argued could have supported a different penalty phase strategy. The PCRA court granted a stay of execution and ordered a new penalty hearing, but this opinion supports reversal of that order. The core reasoning is that Williams failed to meet the governmental interference exception to the PCRA's one-year time bar because he had long known about and previously asserted facts regarding the victim's sexual conduct with teenage boys, including at trial and in a 1998 PCRA hearing, and thus could not show that government action prevented timely discovery of the claim despite due diligence.

criminal lawprocedure

This case involves an appeal by the Commonwealth from a Philadelphia County PCRA court order that stayed the execution of Terrance Williams, who had been convicted of first-degree murder and sentenced to death, and granted him a new penalty-phase trial. The Pennsylvania Supreme Court, sitting with only four participating justices after three recused themselves, was evenly divided on the merits of the appeal. As a result of the tie, the Court affirmed the PCRA court's order granting the stay and ordering a new sentencing hearing, and remanded the matter for that purpose. The affirmance preserves the lower court's determination that Williams was entitled to additional proceedings on his sentence without resolving the underlying legal questions.

criminal lawprocedure

This case involves a Post-Conviction Relief Act (PCRA) petition filed by Terrance Williams, who was convicted of murder and sentenced to death in Philadelphia County. The PCRA court granted a stay of execution and ordered a new penalty phase trial based on claims of error in the original sentencing proceedings. The Commonwealth appealed that order to the Pennsylvania Supreme Court. Because the Court was equally divided, with three justices supporting affirmance and two supporting reversal, the lower court's order is affirmed by operation of law, and the matter is remanded for a new penalty phase trial.

criminal lawprocedure

This case involves Terrance Williams' 1984 murder conviction and death sentence for killing Amos Norwood, where Williams filed a PCRA petition seeking a new penalty hearing based on a claim of governmental interference under the Brady doctrine. The PCRA court granted relief, but this opinion supports reversal, concluding that the petition was untimely and that the lower court lacked jurisdiction. The core reasoning is that Williams failed to satisfy the governmental interference exception to the PCRA's time bar because he already knew of and had previously asserted facts about Norwood's alleged homosexual ephebophilia at trial and in earlier proceedings, rather than being prevented from discovering the claim by any government action. As a result, the opinion would vacate the stay of execution and reinstate the death sentence.

criminal lawprocedure

This case involves Wayne A. Smith appealing his death sentence for first-degree murder following a new penalty-phase hearing after his original conviction was upheld but the sentence vacated on ineffectiveness grounds. The Pennsylvania Supreme Court affirmed the judgment of sentence after reviewing multiple claims of error, including the 17-year delay allegedly violating due process and speedy trial rights, the admission of evidence regarding a prior voluntary manslaughter conviction and other matters such as books on murder, a witness's reference to the prior death sentence, the trial court's handling of jury deliberations, and restrictions on voir dire questions about life imprisonment. The court reasoned that the delay did not bar the death penalty as it was not a violation under relevant standards, the prior conviction was properly admitted as a statutory aggravating circumstance, other evidentiary and procedural rulings followed established law without prejudice, and the jury was adequately life-qualified.

criminal lawprocedure

This case involved appeals by the City of Philadelphia challenging awards of tax refunds and credits by the City's Tax Review Board to health insurance companies (Keystone Health Plan East and QCC Insurance) for overpayments of business privilege taxes. The core issue was whether a three-year time limit in Philadelphia Code § 19-1703(1)(d) barred claims for both refunds and credits, or only refunds. The Pennsylvania Supreme Court held that the provision is a statute of repose that extinguishes refund claims after three years from the payment date or due date, but that credits are governed by separate code sections without any time limit and are therefore not subject to the same bar. The Court affirmed the Commonwealth Court's decision upholding the award of credits while rejecting the refund claims as untimely.

taxesbusiness & regulatory

This case involves Philadelphia health insurers seeking tax credits or refunds for overpayments of business privilege taxes after a federal audit adjustment, where the three-year limitations period under Philadelphia Code Section 19-1703(1)(d) had expired. The majority allowed the credits on the ground that they are distinct from refunds and not subject to the same time bar. In this concurring and dissenting opinion, Chief Justice Saylor agrees that refunds are unavailable but disagrees that credits may be awarded, reasoning that refund credits are functionally equivalent to refunds under the Code and that refund statutes are to be strictly construed in favor of the government because refunds are a matter of legislative grace. He concludes that the taxpayers' amended returns were untimely, foreclosing both refunds and credits.

taxesbusiness & regulatory

This case concerned whether certain health insurance companies could obtain tax credits from the City of Philadelphia for overpayments of business privilege taxes, even though they had submitted amended returns after the three-year limitations period for seeking refunds had expired. The majority opinion allowed the credits while denying refunds. In this concurring and dissenting opinion, Chief Justice Saylor agrees that refunds are unavailable but disagrees with awarding credits. He reasons that refund credits are functionally equivalent to refunds, that the Philadelphia Code treats them similarly, and that limitations periods on refunds therefore also bar credits, as such relief is a matter of legislative grace to be strictly construed against the taxpayer.

taxesbusiness & regulatory

This case concerns nuisance claims brought by neighboring property owners against a farm and biosolids applicators, alleging odors from surface-applied sewage sludge. The concurring opinion joins the majority in holding that the application of biosolids constitutes a single normal agricultural operation under Pennsylvania's Right to Farm Act, triggering the statute of repose that bars untimely suits. The reasoning emphasizes the Act's broad remedial purpose requiring liberal construction, the distinction from other states' laws that tie protections to best management practices, and the conclusion that the core practice rather than its specific implementation method determines normalcy for statutory protection. The opinion notes that future cases with different evidence on odor controls might lead to a narrower view.

environmentpropertytorts & liability

The case involved the City of Philadelphia challenging Tax Review Board decisions that awarded tax refunds and credits to health insurers Keystone Health Plan East, Inc. and QCC Insurance Company for overpayments of estimated taxes. The Pennsylvania Supreme Court affirmed the Commonwealth Court’s ruling in favor of the taxpayers on credits but held that refund claims were time-barred. The court reasoned that Philadelphia Code § 19-1703(1)(d) imposes a three-year statute of repose on refund claims tied to the payment or due date, while § 19-2610 and related provisions on credits contain no time limit because credits function as prospective offsets against future liability rather than immediate payments by the City, and the two remedies are legally distinct.

taxesbusiness & regulatory

This case involved appeals by the City of Philadelphia challenging decisions by the Tax Review Board granting tax credits and refunds to health insurance companies (Keystone Health Plan East and QCC Insurance) for overpayments of business privilege taxes, which were discovered after a federal audit led to amended returns filed beyond the normal deadline. The majority of the Pennsylvania Supreme Court upheld the award of credits to the taxpayers while addressing related refund issues. The core reasoning centered on interpreting provisions of the Philadelphia Code, particularly Section 19-1703, to determine that credits are substantively distinct from refunds and not subject to the same three-year limitations period that bars late refund claims, treating the availability of such relief as a matter of statutory construction rather than legislative grace.

taxesbusiness & regulatory

This case concerns the application of Pennsylvania's sex offender registration requirements under SORNA (enacted via Act 111 of 2011) and related amendments in Act 19 of 2014, specifically whether paragraphs (2) and (3.1) of 42 Pa.C.S. §9799.13 conflict regarding registration for indecent assault convictions. The court held that the provisions are not in conflict, as the restricted definition of 'sexually violent offense' applies only to paragraph (3.1). The core reasoning traces the legislative history: paragraph (3.1) was added post-Neiman to preserve registration obligations from the invalidated Megan's Law III for offenders convicted or supervised between 2005 and 2012 (limited to first-degree misdemeanor indecent assault), while paragraph (2) uses SORNA's broader definition to cover those under supervision on or after December 20, 2012, consistent with SORNA's purposes of Adam Walsh Act compliance.

criminal law

This case involves Raymond Solano, convicted of first-degree murder and sentenced to death for shooting a victim in a crowded park, with the jury finding a grave-risk aggravator and catch-all mitigator. The Commonwealth appealed the PCRA court's grant of a new penalty phase based on trial counsel's ineffectiveness for failing to investigate and present mitigating evidence of the cognitive and psychological impact of Solano's traumatic childhood, while Solano cross-appealed the denial of his guilt-phase claims. The Pennsylvania Supreme Court affirmed the PCRA order, concluding that the additional mitigation evidence could have influenced the jury's weighing of factors in favor of a life sentence, but found no error in denying guilt-phase relief.

criminal lawprocedure

This case concerned the City of Philadelphia's challenge to Tax Review Board rulings that granted tax credits to health insurance companies (Keystone Health Plan East and QCC Insurance) for overpayments of business privilege taxes identified via federal audits and submitted through amended returns after the original filing deadlines. The companies also cross-appealed regarding the availability of direct refunds. The majority sustained the credits but addressed refunds separately, while the concurring/dissenting opinion agreed on denying untimely refunds but would have reversed the credits award as well. The core reasoning focused on strict construction of Philadelphia Code provisions like Section 19-1703(1)(d) limiting claims for refunds or credits, the treatment of amended versus initial returns under Section 19-2610 and related regulations, and the principle that tax relief is a matter of legislative grace with ambiguities resolved in favor of the government.

taxesbusiness & regulatory

The case concerned whether certain health insurance companies could obtain refunds or credits from the City of Philadelphia for overpayments of business privilege taxes after the three-year period set by Philadelphia Code § 19-1703(1)(d). The Supreme Court of Pennsylvania affirmed the Commonwealth Court’s ruling that the companies were entitled to credits but not refunds. The court reasoned that the code provision expressly limits only refund claims to three years from the payment date and functions as a statute of repose, while separate provisions governing credits contain no time limit. It further held that refunds and credits are distinct remedies—one requiring immediate payment by the City and the other allowing an offset against future liability—so the refund limitation cannot be imported into the credit provisions.

taxesbusiness & regulatory

The case concerned whether Philadelphia taxpayers could obtain refunds or credits for overpaid business privilege taxes after the three-year period specified in the city code. The Pennsylvania Supreme Court held that the three-year limit acts as a statute of repose barring refunds filed after the deadline, but does not apply to requests for tax credits. The court reasoned that the code provisions treat refunds and credits differently, with refunds requiring immediate payment by the city and credits serving as offsets against future liabilities, and no time restriction is stated for credits. Therefore, the taxpayers were entitled to credits despite being barred from refunds.

taxesprocedure

This case concerned whether Raymond Farabaugh, who pled guilty in 2011 to indecent assault graded as a second-degree misdemeanor and received probation, was required to register as a sexual offender under amendments to Pennsylvania's Megan's Law. After the 2011 amendments imposed registration requirements effective in 2012, and a 2014 amendment (Act 19) added an exception for certain indecent assault convictions, the Superior Court held sua sponte that Farabaugh was exempt and vacated the trial court's denial of his petition. The Pennsylvania Supreme Court reversed, holding that the statutory exception in 42 Pa.C.S. § 9799.13(3.1) applied only to individuals covered by that specific paragraph and not to those, like Farabaugh, covered by paragraph (2). The Court reasoned that the plain language limiting the exception "for purposes of this paragraph," combined with established principles of statutory construction distinguishing paragraphs from sections, required this narrow application, and remanded for consideration of Farabaugh's remaining claims.

criminal lawprocedure

This case involved neighbors suing a farm owner, tenant farmer, and biosolids recycling companies for nuisance due to offensive odors from the land application of treated sewage sludge as fertilizer on a York County farm between 2006 and 2009. The trial court granted summary judgment to the defendants under § 954(a) of Pennsylvania's Right to Farm Act, which bars nuisance suits against normal agricultural operations after one year. The Supreme Court held that whether the Act applies is a legal question for courts to decide via statutory interpretation, not a factual issue for juries. It further ruled that biosolids land application qualifies as a 'normal agricultural operation' under the Act's definition, based on statutory text, related environmental regulations, agency practices, and historical farming uses, thereby barring the claims as a statute of repose.

environmentpropertytorts & liabilitybusiness & regulatory