Debra Todd

This case concerned whether a trial court properly denied the Commonwealth's motion to nolle prosequi charges of negligent simple assault against former police officer Stuart Harrison, who was accused of shooting a suspect during an arrest at a bank after a Taser malfunctioned. The Pennsylvania Supreme Court affirmed the Superior Court's order upholding the denial. The Court held that the trial court had correctly applied the legal standard from Commonwealth v. Reinhart for reviewing such motions. It further found that the Commonwealth's stated reasons for seeking to drop the charges were neither valid nor reasonable, as other available witnesses could establish the facts needed to meet the prosecution's burden at trial.

criminal lawprocedure

This case concerned whether Pennsylvania's mandatory sentence of life imprisonment without parole for a conviction of second-degree murder (felony murder) violates the Eighth Amendment or the state constitution's prohibition on cruel punishments. The defendant was convicted of second-degree murder and other charges after participating in a home invasion robbery during which his co-defendant shot and killed the victim. The Supreme Court of Pennsylvania held that the mandatory LWOP sentence, imposed without any individualized assessment of the defendant's culpability, violates Article I, Section 13 of the Pennsylvania Constitution. The court reversed the Superior Court's order, vacated the sentence, and remanded for resentencing while staying the mandate for 120 days to allow the legislature time to respond.

criminal law

The case involved David Heater, the sole owner and employee of a general contracting business, who suffered a work-related neck injury in 2015 and sought workers' compensation benefits under a policy issued by Erie Insurance. Erie denied the claim, asserting among other things that Heater failed to provide timely notice of the injury to the insurer within 120 days as required by Section 311 of the Workers’ Compensation Act. The Supreme Court of Pennsylvania held that Section 311 does not require a sole proprietor to notify his insurer within 120 days to preserve eligibility for benefits, because the statutory definition of “employer” for notice purposes does not encompass the insurer. The Court reversed the Commonwealth Court’s contrary ruling and remanded the matter to the Workers’ Compensation Appeal Board.

labor & employment

This case concerns a child support enforcement action in which the Lebanon County Domestic Relations Office sought civil contempt sanctions against Michael Hall for unpaid arrearages, resulting in a trial court order imposing 100 days' imprisonment with a $2,000 purge condition. The Supreme Court of Pennsylvania, through the Opinion Announcing the Judgment of the Court, affirmed the Superior Court's decision to vacate the imprisonment order. The core reasoning, as explained in the concurring opinion, is that under Barrett v. Barrett and Pa.R.C.P. 1910.25(b), imprisonment for civil contempt requires proof beyond a reasonable doubt of the contemnor's present ability to pay the purge amount; here the record showed insufficient evidence of Hall's ability to pay, as he testified to unemployment and reliance on family support without rebuttal, and the trial court did not compel financial disclosures. The concurrence further details a burden-shifting framework in which the contemnor has an initial burden of production regarding inability to pay, after which the petitioning party bears the burden of persuasion, while emphasizing that the ultimate standard remains proof beyond a reasonable doubt to avoid punitive rather than coercive sanctions.

family lawcriminal lawcivil rightsprocedure

This case involved a mother who petitioned to involuntarily terminate the parental rights of the father to their minor child under Pennsylvania's Adoption Act, without any plan for the child to be adopted by another person. The trial court granted the termination, but the Superior Court reversed, and the Supreme Court affirmed that reversal. The Court held that the mother's petition was not valid under the Act because Section 2512 requires that a petitioning parent generally must show an anticipated adoption and agree to relinquish their own parental rights, and the "cause shown" exception in Section 2901 applies only in the context of a contemplated adoption. The opinion reviewed the statutory provisions on termination grounds, petition requirements, and limited exceptions such as those for children conceived through rape or incest, noting that the legislature had not altered the adoption-contemplation rule despite prior judicial interpretations. The Court concluded that the trial court erred in terminating the father's rights absent compliance with these requirements.

family law

This case concerned Derrick Walker's convictions for raping three separate victims, with the appeals raising questions about the admissibility of evidence of the other assaults under the common plan, scheme, or design exception to the bar on propensity evidence, as well as whether rape kit reports could be introduced without testimony from the examining nurses. The majority held that the other offenses were not admissible because they were neither signature crimes nor linked to a common goal, and that the reports were testimonial and thus violated confrontation rights, requiring a new trial. The dissent disagreed on both points, contending that the exception should allow the evidence and that the reports were primarily medical records created for treatment rather than prosecution, making them nontestimonial. The reasoning centered on the precise standards for the common plan exception and the primary purpose test for determining if statements are testimonial under the Confrontation Clause.

criminal lawprocedure

This case involved Derrick Walker's convictions for raping three separate victims, where the Commonwealth introduced evidence of each assault in the consolidated trial and admitted rape kit reports prepared by nurses without their live testimony. The Pennsylvania Supreme Court majority held that the other-acts evidence was inadmissible under the common plan, scheme, or design exception because the assaults were neither signature crimes nor linked to achieve a common goal, and that the reports were testimonial and violated the confrontation clause. On those grounds the Court vacated the judgments of sentence and remanded for a new trial. The dissent maintained that the reports were created primarily for medical treatment rather than prosecution and would have affirmed the convictions.

criminal lawprocedure

This case involved appeals by Derrick Walker challenging his convictions for raping three women, specifically contesting the admission at trial of evidence regarding each assault in the others under the common plan, scheme, or design exception to propensity evidence rules, as well as the introduction of rape kit reports without testimony from the preparing nurses. The majority concluded that the prior acts did not qualify as signature crimes or acts linked to a common goal, rendering the evidence inadmissible, and that the reports were testimonial in nature and violated the confrontation clause, warranting reversal of the judgments of sentence and remand for a new trial. The dissent disagreed, maintaining that the common plan exception applied and that the reports served a primary medical purpose rather than a prosecutorial one.

criminal lawprocedure

The case involved a public employee who sued her union for breach of the duty of fair representation after the union allegedly mishandled a grievance under a collective bargaining agreement. The majority of the Pennsylvania Supreme Court held that such a claim constitutes a dispute arising out of the interpretation of the CBA under the Public Employe Relations Act, limiting the employee's judicial remedy to an order directing arbitration of the underlying grievance nunc pro tunc. The court reasoned that PERA channels these matters to arbitration rather than allowing direct court actions for damages. A dissent argued that the claim does not arise from the CBA and that employees should be able to pursue damages in court if bad faith is proven.

labor & employmentprocedure

The case concerned a challenge to an upset tax sale of a 52-acre property in Tioga County, Pennsylvania, conducted under the Real Estate Tax Sale Law after the owner repeatedly failed to pay real estate taxes since 2004; the property sold for $83,000, about 18% of its appraised $465,000 fair market value. The owner filed objections claiming inadequate notice under the statute, that the sale effected an unconstitutional taking without just compensation, and that the low sale price violated substantive and procedural due process. The Pennsylvania Supreme Court affirmed the trial court's denial of the objections and the Commonwealth Court's affirmance, holding that the RETSL exclusively governs upset tax sales and does not authorize setting aside a sale based solely on an allegedly inadequate price absent any irregularity or illegality in the sale proceedings linked to that price.

taxesproperty

The case involved John Edward Kurtz appealing his convictions for rape and related offenses, challenging the validity of a warrant obtained by police to access Google search data tied to the victim and her address. The court affirmed the Superior Court's upholding of the convictions and sentences. The concurring opinion concluded that the warrant was supported by probable cause, based on circumstances such as the secluded location of the victim's home, the timing of the attack while she was alone, and the inference that the perpetrator likely used Google searches in planning the crime, without reaching the constitutional question of privacy expectations in internet search queries and IP addresses.

criminal lawprocedure

This case concerned John Edward Kurtz's appeal of his criminal convictions, challenging the validity of a warrant issued to Google for search histories involving a rape victim and her address under Article I, Section 8 of the Pennsylvania Constitution. The Supreme Court of Pennsylvania affirmed the Superior Court's order upholding the trial court's judgment of sentence. The concurring opinion determined that a warrant was statutorily mandated in these circumstances and that probable cause existed based on the affidavit detailing the secluded nature of the victim's home, her isolation during the attack, and the likelihood that online searches were used in planning the crime. It held that direct evidence of Google use was not required, only a fair probability that relevant evidence would be found, and thus did not reach the novel constitutional privacy issue.

criminal lawprocedure

The case concerns the interpretation of Section 712.1 of Pennsylvania's Sunshine Act, which governs when a public agency like the Parkland School District may take official action on matters not included in required meeting notifications. The majority applied traditional rules of statutory construction and found ambiguity in the statute's structure of exceptions. In dissent, Chief Justice Todd contended that those rules produce a result inconsistent with the General Assembly's manifest intent and urged invocation of 1 Pa.C.S. § 1901 to treat subsections (b), (c), and (d) as substantive exceptions and subsections (e) and (f) as procedural directions. The dissent would affirm the Commonwealth Court's order on this alternative ground.

procedure

In this case, Vincent Smith pleaded guilty to four counts of arson endangering persons after setting a single fire in a residence that endangered four police officers who had entered to search for a missing person. The trial court sentenced him on all four counts consecutively, and the Superior Court affirmed. The Pennsylvania Supreme Court granted review to decide the unit of prosecution under the arson endangering persons statute, 18 Pa.C.S. § 3301(a)(1)(i). The Court held that the statute punishes each act of arson, not each person placed at risk, relying on statutory text, legislative intent, and precedent such as Commonwealth v. Satterfield. It therefore reversed the Superior Court and remanded for resentencing consistent with a single AEP conviction.

criminal law

In Commonwealth v. Jenkins, the Pennsylvania Supreme Court considered whether a trial court could revoke a defendant's participation in an Accelerated Rehabilitative Disposition (ARD) program solely for failing to disclose on his ARD application a prior arrest for suspected driving under the influence, even though he had not yet been charged for that arrest and the application did not ask about uncharged arrests. The defendant had answered all questions on the application truthfully, including affirming that he had no pending criminal charges at the time. The Court held that the trial court erred in revoking ARD participation on this basis and reversed the Superior Court's affirmance of the revocation order. The core reasoning was that the Commonwealth bears the burden of asking for any information it deems relevant on the application, and there was no basis to find deceptive behavior or to revoke when the defendant had complied with the application's specific requirements regarding convictions and pending charges.

criminal lawprocedure

This case concerned a dispute over the appointment to fill a vacancy in the Lackawanna County Commissioner office, specifically whether Pennsylvania Rule of Judicial Administration 1908 conflicted with Lackawanna County Home Rule Charter § 1-2.206. The Supreme Court of Pennsylvania affirmed the Commonwealth Court's ruling that the provisions do not conflict. The concurring opinion agreed with that resolution but declined to address any potential separation of powers violation that might arise if a conflict existed, following the principle of avoiding constitutional questions when a case can be decided on other grounds.

procedure

In Commonwealth v. Walker, the defendant was convicted of multiple sexual offenses against a minor victim based primarily on her testimony describing repeated abuse. The appeal challenged the trial court's decision to allow the prosecution, during voir dire, to ask prospective jurors whether they could follow the principle that an alleged victim's testimony alone, if believed, is sufficient to prove guilt beyond a reasonable doubt. The Pennsylvania Supreme Court affirmed the judgment of sentence, holding that the question did not exceed the proper scope of voir dire because it tracked 18 Pa.C.S. § 3106 and the corresponding standard jury instruction and did not suggest a different credibility standard for victims.

criminal lawprocedure

This case concerned whether Pottstown Hospital, LLC qualified as a purely public charity entitled to exemption from local property taxes under Article VIII, Section 2(a)(v) of the Pennsylvania Constitution. The Supreme Court of Pennsylvania held that the Hospital met the Hospital Utilization Project test criteria, including operating entirely free from private profit motive, and was therefore entitled to the exemption for the relevant tax years. The Court reasoned that the Hospital's executive compensation was reasonable, determined through an arm's-length annual review process using market comparisons by an independent consultant, and that its management relationship with Tower Health did not introduce a profit motive. Accordingly, the Court reversed the Commonwealth Court's order and reinstated the trial court's grant of the tax exemption.

taxeshealthcareproperty

This case involved a challenge by Firearms Owners Against Crime and related parties to the Pennsylvania State Police's (PSP) performance of background checks under the Uniform Firearms Act for firearm purchases through the Pennsylvania Instant Check System (PICS). The appellants alleged that PSP's response times violated the statutory requirement for instantaneous checks and sought injunctive relief, mandamus, and declaratory relief to compel faster compliance. The Supreme Court of Pennsylvania affirmed the denial of permanent injunctive and mandamus relief, as well as the dissolution of a preliminary injunction, but reversed the denial of declaratory relief and vacated the order denying leave to amend the petition. The core reasoning was that while the Act imposes duties on PSP to establish and operate an instantaneous check system with sufficient personnel, those duties do not support coercive remedies like injunctions or mandamus in this context, though a declaration of the parties' rights and duties under the statute remains available. The matter was remanded for further proceedings on the declaratory claim.

gunscriminal law

This case concerned whether a prior acceptance of accelerated rehabilitative disposition (ARD) for a DUI offense could constitutionally be treated as a prior offense to enhance the sentence for a later DUI conviction under Pennsylvania's Motor Vehicle Code. The Pennsylvania Supreme Court held that such use of an ARD acceptance violates the requirements of Alleyne v. United States because it permits a fact that increases the penalty to be determined without being charged, submitted to a jury, and proven beyond a reasonable doubt. The court reasoned that the relevant provision in Section 3806 is facially unconstitutional but severable from the remainder of the statute, allowing the trial court to properly sentence the defendant as a first-time offender. The Superior Court's order vacating the sentence was reversed, and the case was remanded to reinstate the original judgment of sentence.

criminal lawprocedure