Justia Constitutional Law Opinion Summaries

Following the death of a college student in Shippensburg, Hearst Television, Inc., d/b/a WGAL-TV and its reporter, Daniel O'Donnell (Requester), filed a Right to Know Law (RTKL) request with Michael Norris, the Coroner of Cumberland County (Coroner), seeking the student's manner of death. The Coroner rejected the request, and the Pennsylvania Office of Open Records (OOR) upheld the Coroner's decision. On appeal, the trial court and the Commonwealth Court affirmed. The Supreme Court reversed, holding that under Section 1236.1(c) of the Coroner's Act and the under the RTKL, the record indicating the manner of death was immediately available to Requester. View "Hearst Television Inc. v. Norris" on Justia Law

The issue on appeal in this case was one of first impression: whether a medical general practitioner who provides incidental mental health treatment to a patient, with whom he then engages in a sexual affair, may be held to a particularized "specialist duty," applicable to mental health professionals, that prohibits consensual sexual contact with patients, such that the defendant general practitioner may be subject to medical malpractice liability in tort. Upon review of the trial court record, the Supreme Court declined to impose such a duty as a matter of Pennsylvania common law. Accordingly, the Court vacated the Superior Court's decision and remanded the case for further proceedings on any preserved issues remain that were not addressed as a result of the Superior Court's disposition. View "Thierfelder v. Wolfert" on Justia Law

This appeal presented a discrete issue of post-trial procedure governed by Rule 227.1 of the Pennsylvania Rules of Civil Procedure, which requires a party to file posttrial motions with the trial judge within ten days of certain enumerated events, with the failure to so file resulting in the significant consequence of a waiver of issues on appeal. The specific question presented was whether a party must file post-trial motions in a remand scenario -- here, a circumstance where, on remand from the Superior Court, the trial court recalculated a damage award without receiving any additional evidence from the parties. The Superior Court quashed appellants' appeal from the trial court's recalculated damages order, holding that appellants had waived all claims by failing to file a second round of post-trial motions. This implicated the question of whether a trial occurred on remand, thereby triggering the post-trial motion procedure contemplated by Rule 227.1. Upon review, the Supreme Court concluded that the panel erred in deeming appellants' claims to be waived for non-compliance with Rule 227.1. Accordingly, the Court vacated the quashal order below and remanded the case for consideration of the merits. View "Newman Development Group of Pottstown v. Genuardi's Family Markets" on Justia Law

Appellant Aaron Jones' third petition for PCRA relief was denied as untimely, and he appealed to the Supreme Court. Appellant was convicted of first degree murder and sentenced to death for ordering the murder of a rival gang member. After multiple unsuccessful attempts to get PCRA relief, Appellant filed an unsuccessful petition for the writ of habeas corpus. When that too was denied, Appellant filed a third PCRA petition, alleging that he received newly-discovered evidence and that his untimely petition should be excepted from the PCRA's timeliness requirement. Upon review, the Supreme Court found no merit to Appellant's arguments, and ruled that his petition was clearly untimely and properly dismissed by the PCRA court. View "Pennsylvania v. Jones" on Justia Law

The Supreme Court granted review of this case to address the applicability of Section 9543(b) of the Post Conviction Relief Act (PCRA) to delays in filing amended post-conviction petitions, and the related issue of what obligation (if any) a petitioner had to move the litigation of his petition forward. In 1988, Petitioner filed a pro se application for post-conviction relief. A public defender was appointed to serve as his counsel upon remand to the PCRA court, but no further docket entries appeared in Petitioner's case until 2003 when Petitioner acting pro se filed a document seeking "extension of post-conviction relief petition." The extension was treated as an untimely and successive PCRA petition. On remand, the case was again assigned counsel, and that counsel filed an amended PCRA petition, raising numerous claims regarding Petitioner's trial counsel's ineffective assistance. The PCRA court issued an opinion dismissing the matter with prejudice. The court cited that too much time as passed to be able to mount a defense as fifteen witnesses were no longer available: "the absence of witnesses as well as the likelihood that memories would be poor twenty-four years after trial… would severely prejudice the Commonwealth's ability to retry" Petitioner. Accordingly, the PCRA court dismissed the matter; the Superior Court affirmed. Upon review the Supreme Court affirmed, concluding that the Legislature balanced policy concerns implicated by protracted litigation of PCRA claims and determined that in certain instances of substantial delay, the prejudice suffered by the Commonwealth as a result of that delay, as demonstrated at an evidentiary hearing, justifies dismissal of an original or amended petition. View "Pennsylvania v. Renchenski" on Justia Law

In 1996, the Pennsylvania Supreme Court granted mandamus relief and ordered the General Assembly to enact laws to provide funding for the support of judicial system. In 1999, the General Assembly enacted legislation which effectuated the first phase of an appointed master's recommendations for implementation of the Court's directive. In late 2008, the Petitioners in this case filed a "Motion to Enforce Grant of Petition for Mandamus and Order" requesting that the Court enforce the 1996 order. Upon review of the years' of litigation since 1996 in this matter, the Supreme Court elected not to grant further mandamus relief, "and neither [was the Court] inclined to go backward and overrule [its] prior decisions rendered in light of the realities of time." The Court denied the motion to enforce and relinquished jurisdiction. View "PA State Association of County Commissioners v. Pennsylvania" on Justia Law

At issue before the Supreme Court was whether the common pleas court appropriately decertified a class based on its conclusion that a necessary element of the plaintiffs' proof (the presence of a confidential relationship) was not amenable to class treatment. In 1993, Sandra J. Basile commenced a civil action against H&R Block, Inc., H&R Block Eastern Tax Services, Inc. and Mellon Bank. She alleged, among other things, that the Block companies maintained maintained and breached fiduciary duties in connection with their "Rapid Refund" program. Basile sought to assert claims on behalf of herself and others who were similarly situated. However, summary judgment subsequently was awarded in Block's favor on the ground that it had no fiduciary relationship with the plaintiffs. The common pleas court's conclusion, in this respect, was based on the premises that Block was not the plaintiffs' agent and that no confidential relationship otherwise existed between the parties. In the ensuing appellate litigation, the court's decision on the agency score ultimately was conclusively sustained. In 2001, the Superior Court overturned the common pleas court's summary-judgment award, finding that Ms. Basile had proffered sufficient evidence to establish a prima facie case of a confidential relationship. In 2003, upon consideration of the appellate rulings, the common pleas court determined that class treatment was no longer appropriate. The common pleas court found that the need for individualized inquiries on the dispositive question of trust precluded a finding that common issues predominated. Upon review of the matter, the Supreme Court held that that the common pleas court did not err in decertifying the class based on its conclusion that the presence of a confidential relationship was not amenable to class treatment. The order of the Superior Court was reversed, the common pleas court's decertification order was reinstated, and the matter was remanded for further proceedings.

In this appeal by allowance, the issue before the Supreme Court was whether the Superior Court improperly reversed a revocation of probation, when the revocation was premised upon the conclusion that a probationer violated restrictions contained within a document entitled "Standard Special Conditions for Sex Offenders," which was authored by the Pennsylvania Board of Probation and Parole (the Board), rather than a judge of the court of common pleas. Upon review, the Court held that the Superior Court erred in reversing the revocation of probation. The Superior Court's order was vacated and the case remanded for further proceedings.

This appeal by the Commonwealth, the prevailing party at trial which was aggrieved by the Superior Court's grant of a new trial, centered on principles of self-defense for purposes of assessing whether the trial court abused its discretion in excluding evidence of the murder victim's nine-year-old conviction for robbery. The Commonwealth contended, among other points, that the Superior Court's assessment of the evidentiary ruling misapprehended the law governing self-defense. Upon review of the trial court record and the briefs submitted on appeal, the Supreme Court agreed with the Commonwealth and reversed the Superior Court, reinstating the judgment of sentence for first-degree murder, aggravated assault and related offenses in the underlying case.

In this appeal, the Supreme Court was presented with two questions: (1) whether a defendant's convictions for first-degree murder and other crimes which rest solely on subsequently recanted out-of-court statements given to police violates the due process guarantees of either the United States or Pennsylvania Constitutions; and (2) whether the confessions of a former co-defendant should have been admitted as evidence as statements against interest under Pa.R.E. 804(b)(3). After careful consideration, the Court held that the recanting witnesses' out-of-court statements to the police were sufficient to sustain Appellant's convictions against a due process challenge. However, because the Court also found that the trial court erred by not allowing other portions of the co-defendant's confessions to be entered into evidence as statements against interest, the Court was "constrained" to vacate Appellant's convictions and remand the case for a new trial.