Justia Constitutional Law Opinion Summaries

Appellant Stephen Edmiston appealed the denial of relief on two separate Post-Conviction Relief Act (PCRA) petitions: (1) the denial of relief raised in his second PCRA petition; and (2) the denial of his request for post-conviction DNA testing in support of his motion for petition. Upon review, the Supreme Court found that the claims Appellant raised regarding the second petition were untimely. Further more, the Supreme Court affirmed denial of post-conviction DNA testing because Appellant failed to demonstrate that his DNA petition was made "in a timely manner and for the purpose of demonstrating [his] actual innocence and not to delay the execution of sentence or administration of justice." View "Pennsylvania v. Edmiston" on Justia Law

Appellees filed an original-jurisdiction petition for review challenging recent changes to the Department of Public Welfare's practices and policies in determining appropriate reimbursement of county expenditures for out-of-home, child-welfare placement services. According to the petition, the reimbursement scheme as published in the Code, Department regulations, and in previous administrative practices, embodied a needs-based budgeting process supplemented by compliance review via intermittent auditing of county and service provider records by the state agency. Appellees contended however, that DPW through a series of recent administrative bulletins, had unilaterally and inappropriately substituted a restrictive, statewide rate-setting process in place of the prior regime. Appellees lodged substantive and procedural challenges, claiming that the changes effected by the bulletins were ultra vires and unconstitutional, or, alternatively, that DPW had failed to comply with mandatory regulatory-review procedures designed to ensure a meaningful opportunity for public participation and independent regulatory oversight. Upon review, the Supreme Court concluded that the Commonwealth Court did not err in concluding that the bulletins contained procedurally invalid legislative regulations. View "NW Youth Svcs. v. Dept. Pub. Welfare " on Justia Law

Appellant Lewis Jordan, a/k/a John Lewis, pled pled guilty to murder generally in the shooting death of Philadelphia Police Officer Charles Cassidy. Following a trial by jury to determine degree of guilt, Appellant was convicted of first-degree murder and sentenced to death. In a direct appeal, Appellant raised four issues. Concluding that Appellant was not entitled to relief on any of these issues and that the evidence was sufficient to sustain Appellant's conviction, the Supreme Court affirmed the judgment of sentence. View "Pennsylvania v. Jordan" on Justia Law

In 2005, Appellees Monroe County Detective Eric Kerchner and First Assistant District Attorney Michael Mancuso were investigating and prosecuting Dennis Slayton for theft and drug-related offenses, as well as Jill Goldstein in connection with the drug offenses. Appellant John P. Karoly, Jr., Esq., was acting as Slayton's attorney. Goldstein appeared at a bail revocation hearing represented by Eric Dowdle, Esq. At the conclusion, bail was revoked and Goldstein was placed in custody at the Monroe County Correctional Facility (MCCF). The next day, Goldstein called Slayton from the jail. During the conversation, Appellant, who was with Slayton, began speaking with Goldstein. The MCCF recorded the conversation. In a direct appeal involving alleged intentional violations of the Wiretap Act, the issue before the Supreme Court was whether the Commonwealth Court erred in granting a defense motion for summary judgment. In the amended complaint, Appellant alleged that Appellees committed multiple violations of the Wiretap Act, most notably that: ADA Mancuso violated Section 5703(2) of the Act by disclosing the conversation between Appellant and Goldstein when he included it in legal filings that were not placed under seal; and ADA Mancuso and Detective Kerchner conspired to transmit such filings to the press. On the basis of this conduct, Appellant asserted that Appellees intentionally violated the statute and, as such, should be removed from their employment pursuant to Section 5726. "In [this] context, the most obvious manner of accomplishing the appropriate investigative and law-enforcement use of the intercepted conversation . . . would have been to file the motion and brief under seal. The failure to do so, as all parties acknowledge, caused the intercepted conversation to become a matter of public record." The Supreme Court found that the Commonwealth Court did not evaluate whether the unsealed filing of the motion and brief was permissible under Section 5717. Because this issue, as well as an appropriate treatment of the alleged disclosure to the press, were material to the outcome, the Court found that the Commonwealth Court improperly granted Appellees' motion for summary judgment. Thus, the case was remanded for hearings on these questions, the question of intent, and/or on whether Appellees acted in good-faith reliance on the Act. View "Karoly v. Mancuso" on Justia Law

At issue in this case was the "interaction" of the attorney-client privilege and the Right-to-Know Law, Act of February 14, 2008, P.L. 6, 65 P.S. secs. 67.101-67.3104 ("RTKL"). In 2010, Associated Press member Marc Levy sent two written requests to the Senate’s Right to Know Officer seeking "all bills, contracts and payment records related to the hiring of any outside lawyer or law firm to represent Sen. Robert J. Mellow beginning Jan. 1, 2009" and the same documents related to "any current or former employee of the Senate Democratic caucus beginning Jan. 1, 2009." The requests came a few days after the media reported that federal authorities executed search warrants on Senator Mellow's home and office as part of a grand jury investigation. After review, the Supreme Court reaffirmed the general rule that client identities are not protected by the attorney-client privilege, but adopted specified exceptions to this general rule. The Court affirmed the Commonwealth Court's determination that general descriptions of legal services included in attorney invoices are not covered by the umbrella of the attorney-client privilege but that specific descriptions that would reveal attorney-client communications are protected. Furthermore, the Court reversed the Commonwealth Court and overturned its decision in "Signature Information Solutions, LLC. v. Aston Township," (995 A.2d 510 (Pa. Cmwlth. 2010)), to the extent it determined that any reasons for denial not raised in the initial written denial of a RTKL request were waived and could not be raised at a later stage of the RTKL process. View "Levy v. Senate of Pennsylvania" on Justia Law

The issue before the Supreme Court in this matter arose from direct appeal of an order that denied injunctive and declaratory relief by an en banc panel of the Commonwealth Court regarding various constitutional challenges to a law enacted by the General Assembly known as "Act 108 of 2011." Specifically, it was alleged that Act 108 was violative of: (1) the "single subject rule" of Article III, Section 3 of the Pennsylvania Constitution; (2) the separation of powers doctrine of Article V, Sections 1 and 10 of the Pennsylvania Constitution establishing a unified judicial system supervised by the Supreme Court; and (3) the due process clause of the Fourteenth Amendment to the United States Constitution under the void for vagueness doctrine. The Commonwealth Court, in a 4-3 decision, rejected the constitutional challenges and dismissed the action. After oral argument and consideration of the Commonwealth Court record, the Supreme Court concluded that with regard to the Article III, Section 3 single subject challenge, Act 108 was unconstitutional. Given this disposition, the Court did not consider the remaining arguments. View "PA State Ass'n of Jury Commissioners v. Pennsylvania" on Justia Law

The issue before the Supreme Court centered on the award of attorney's fees against an insurance company under the peer-review provisions of the Motor Vehicle Financial Responsibility Law (MVFRL). The MVFRL limits the amount providers may charge for treatment, products or services rendered to patients injured in automobile accidents where the injury is covered by an insurance policy. An individual obtained treatment from Appellee Herd Chiropractic Clinic for injuries sustained in a motor vehicle accident. The insurance company submitted the clinic's invoices to a Peer Review Organization (PRO) pursuant to the MVFRL. The PRO determined that certain treatments were not necessary or reasonable, and the insurance company subsequently refused to pay for such treatment The Clinic then sued for unpaid bills, plus treble damages and attorney's fees under the theory that the MVFRL authorized payment. The Common Pleas court found an award of fees proper and mandatory under the MVFRL. The Superior Court affirmed. The Supreme Court, however, reversed, finding that the MVFRL did not allow for what amounted to "fee shifting" by the lower courts' outcome: "We acknowledge [the Clinic's] concerns with the financial incentives in the peer-review industry and with the fact that litigation costs incurred by providers may discourage legitimate challenges. The fee accruals here – in the amount of $27,000 to vindicate a $1380 claim - present a stark example of the difficulty. . . . Nevertheless, fee shifting raises a host of mixed policy considerations in and of itself, which this Court has found are best left to the General Assembly, in the absence of contractual allocation or some other recognized exception to the general, American rule." View "Herd Chiropractic Clinic v. State Farm Mutual Automobile Ins. Co." on Justia Law

The issue before the Supreme Court in this matter concerned the standard of review with respect to a claim that the verdict was against the weight of the evidence. Appellees Jamel Clay, James Claybrook and Rashid Lewis visited "R.B." at her dormitory room in West Chester to socialize. Eventually Appellees, R.B. and her friend H.S. discussed how Appellees would stay the night. H.S. testified that Appellees "ended up" in her room, and did not dispute that she allowed them to stay. Over the course of the stay, the three Appellees engaged in sex with H.S. H.S. contacted her Resident Assistant and claimed that Appellees had raped her. Ultimately Appellees were charged and convicted with the sexual assault of H.S. Each was sentenced to two to four years' incarceration and two years' consecutive probation. Appellees filed a joint motion for post-sentence relief, arguing that the evidence was insufficient to sustain their convictions, and that the jury's verdicts were against the weight of the evidence. Upon review, the Supreme Court concluded that the superior court used the incorrect standard of review and erroneously substituted its own conclusions for those of the jury and the trial court. Accordingly, the Court reversed and remanded the case to the superior court for reconsideration. View "Pennsylvania v. Clay" on Justia Law

The issue before the Supreme Court in this case was whether Appellee John Brock waived his speedy trial claim by either failing to file a written motion to dismiss, or by failing to appear for a trial listing. Upon review, the Supreme Court concluded that under Pa.R.Crim.P. 600, a defendant must file a written motion to dismiss, and that by failing to appear in court on the day his or her case is listed for trial, a defendant waived his Rule 600 claim. Accordingly, the Court reversed. View "Pennsylvania v. Brock" on Justia Law

The issue on appeal before the Supreme Court in this case was whether sheriffs and their deputies have the independent authority to establish and conduct suspicionless roadside sobriety checkpoints. In 2007, sheriffs and deputies of the Forest and Wayne County Sheriffs' Departments established temporary checkpoints in Forest County. Appellee drove a vehicle into the checkpoint, was stopped, was found to have used alcohol, and underwent a field sobriety and chemical test. Based on the results, he was arrested and charged with DUI and other offenses. "The members of [the Supreme Court] maintain great respect and express gratitude for sheriffs and their deputies in the performance of indispensable public services within their realm. We reiterate, however, that they are not police officers - nor are they invested with general police powers beyond the authority to arrest for in-presence breaches of the peace and felonies - in the absence of express legislative designation." The Court held that the sheriffs did not have the authority to independently establish and conduct the suspicionless sobriety checkpoint at which Appellee was arrested. View "Pennsylvania v. Marconi" on Justia Law