Justia Constitutional Law Opinion Summaries

In 1985, the Board of Commissioners of Lackawanna County formed the Multi-Purpose Stadium Authority of Lackawanna County. The Stadium Authority subsequently acquired a minor league baseball team, now the "SWB Yankees." Capital was raised via bonds and other public financing, the Authority constructed the Lackawanna County Stadium, now known as PNC Field to serve as the home field for the franchise. From 1989 to 2006, the Authority managed all projects at the Stadium, including the day-to-day operations of the team. The Authority eventually consummated a management agreement with Mandalay Baseball Properties, LLC, a private entity, which vested Mandalay with the overall management and control of the day-to-day operations of the baseball club and the Stadium. Under the contract, Appellant SWB Yankees, LLC became the sole and exclusive manager of all baseball operations and other entertainment activities and events conducted at the Stadium. Gretchen Wintermantel, a reporter for the Scranton Times Tribune (collectively “Appellees”), submitted a request to the Stadium Authority seeking “access to and copies of all names and the bids submitted to [Appellant] for a concessionaire contract at [the Stadium].” Appellees invoked the Right-to-Know Law, which generally provides for access to “public records,” of a Commonwealth or local agency. The Stadium Authority’s solicitor denied the request, stating that the Authority did not possess such information, and that it was not performing a governmental function on behalf of the Stadium Authority. Appellees appealed to the Office of Open Records, taking the position that any action by Appellant as the Stadium Authority’s agent is public business. In its opinion, the court of common pleas initially rejected Appellant’s argument that the bids for a concessionaire contract were not “records” for purposes of the Right-to-Know Law, since Appellees’ request was phrased broadly such that it might be read as subsuming intangible information. After Appellant lodged an appeal, the Commonwealth Court issued its decision in "East Stroudsburg University Foundation v. OOR," (995 A.2d 496 (Pa. Cmwlth. 2010)) determining that “all contracts that governmental entities enter into with private contractors necessarily carry out a ‘governmental function’ [for purposes of Section 506(d)(1)] --because the government always acts as the government.” Having reviewed the relevant statutory scheme, the parties’ arguments, and the record, the Supreme Court agreed with the appeals officer, the court of common pleas, and the Commonwealth Court that the disclosure of any written concessionaire bids is required per Section 506(d)(1) of the Right-to-Know Law.

The Commonwealth asks the Supreme Court to consider whether the materiality requirement of "Brady v. Maryland" (373 U.S. 83 (1963)), is satisfied where the evidence not disclosed by the Commonwealth and would itself not have been admissible at trial. The Commonwealth further requested the Court reconsider, based on more recent decisions by the Pennsylvania Court and the United States Supreme Court, the Court's holding in "Commonwealth v. Green," (640 A.2d 1242 (1994)). After careful consideration, the Pennsylvania Supreme Court held that nondisclosed favorable evidence which is inadmissible at trial may be considered material for purposes of "Brady," as long as there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different. "Mere speculation by a defendant . . . will not be sufficient to meet this standard; rather, he must identify specific evidence or information that would have been uncovered, and explain how that evidence or information would have changed the result of the proceeding." Notwithstanding its holding, because the Court found in this case that Appellee did not establish there was a reasonable probability that, had the evidence withheld by the Commonwealth been disclosed, there would have been a different outcome at trial, the Court reversed the order of the Superior Court remanding for a new trial, and reinstated Appellee's judgment of sentence.

The Supreme Court granted review in this case to determine whether the courts below erred in dismissing criminal charges against Defendant-Appellee David Bradford. The trial court discontinued the case because the Commonwealth failed to bring Defendant to trial within the time required by Pennsylvania's speedy trial rule (Pa.R.Crim.P. 600) when the Magisterial District Judge failed to forward timely the relevant file as required by Pa.R.Crim.P. 547(B). Upon review, the Court determined that dismissal was not appropriate under Rule 600 when the Commonwealth acted with due diligence in relying upon the judicial system to transfer documents in accordance with the Rules of Criminal Procedure. Accordingly, the Court reversed the dismissal of charges and remanded the case to the trial court.

Appellant Alexander Keaton appealed the denial of his application for post-conviction relief; the Commonwealth cross-appealed the grant of a new penalty phase based on trial counsel's ineffectiveness for failing to present mitigating mental health evidence. In 1992, Appellant was charged with rape and related offenses stemming from the sexual assault of Nadine S. One month later, the body of Appellant's ex-girlfriend was found. After waiving his rights, Appellant gave a written statement incriminating himself in the killing, and he was charged with murder. Appellant sexually assaulted two other women, making self-incriminating statements. The Commonwealth moved to consolidate the charges for all victims. Over defense objection, the trial court granted the motion. Prior to trial, Appellant moved to suppress his statements; the motion was denied, and Appellant was tried before a jury and found guilty of first degree murder, rape, and related offenses. At the penalty phase, the Commonwealth sought to prove several aggravating circumstances. The jury found no mitigating circumstances and one aggravating circumstance. Accordingly, Appellant was sentenced to death. Appellant timely filed a pro se PCRA petition and received appointed counsel, who filed an amended petition alleging all prior counsel's ineffectiveness for not raising numerous guilt and penalty phase issues. The PCRA court held a hearing on the sole issue of trial counsel's ineffectiveness for failing to investigate and present mitigating evidence at the penalty phase. The PCRA court rejected Appellant's guilt phase claims, and denied him a new trial. However, the court concluded trial counsel was ineffective for failing to develop and present mitigating evidence, and granted a new penalty hearing. The PCRA court's opinion did not address several of the issues in detail, it merely stated it found Appellant's claims of guilt phase error meritless and would not further discuss them; the only penalty phase issue the court addressed was trial counsel's ineffectiveness. Without conclusive findings regarding whether Appellant was mentally retarded, the Supreme Court could not address his "Atkins" claim; accordingly, the Court remanded for the PCRA court to consider that claim's merits. The PCRA court complied, and rejected Appellant's claim of mental retardation. On appeal of that decision, the Supreme Court determined that there was a factual question regarding whether Appellant invoked his Fifth Amendment right to counsel in 1992 when he made his self-incriminating statements. The Court remanded this issue to the PCRA court for determination of this issue and for the parties to address the applicability of the applicable case law if the court determined Appellant did invoke his right. As to Appellant's remaining guilt phase claims, the Supreme Court affirmed the PCRA court's denial of relief.

Appellant Leroy Thomas (a/k/a John Wayne) appealed an order that denied him post-conviction relief (PCRA). Appellant was convicted by jury of the first degree murder of Kenneth Rankine. At the penalty phase, the jury found one aggravating circumstance: Appellant had been previously convicted of murder. The jury found no mitigating circumstances and sentenced Appellant to death. Appellant filed a direct appeal to the Supreme Court, claiming ineffective assistance of trial counsel and insufficient evidence to support his conviction. The Supreme Court affirmed, finding Appellant failed to establish he received ineffective assistance of counsel, and that the Commonwealth presented sufficient evidence to establish beyond a reasonable doubt he conspired with two others to kill the victim. Appellant then filed a timely pro se PCRA petition, was appointed new counsel, and filed an amended petition. Appellant appealed the denial of his PCRA petition ,raising eight issues. The Supreme Court took each of these issues in turn, and found that Appellant failed to establish the PCRA court abused its discretion in denying Appellant relief.

Appellant Harve Johnson made a direct appeal to the Supreme Court nunc pro tunc following a jury's imposition of the death sentence for his conviction on first degree murder charges. At the penalty phase, the jury found two aggravating circumstances and one mitigating circumstance. The jury further found the aggravating circumstances outweighted the mitigating circumstance, and sentenced Appellant to death. Appellant raised fourteen issues on appeal, all implicating the admission of certain evidence and sufficiency of the admitted evidence presented at trial. Upon review, the Supreme Court determined the Commonwealth provided sufficient evidence to prove each element of first degree murder. Furthermore, the Court found no abuse of discretion by the trial court in admitting the evidence Appellant complained of at trial. Accordingly, the Court affirmed Appellant's conviction and sentence.

The Supreme Court allowed this appeal to review a superior court conclusion that a police-citizen encounter ripened into an investigative detention when an officer requested identification from several occupants in a vehicle. In 2007, Appellee John Au was arrested by a Ferguson Township officer and charged with possession of marijuana. Appellee sought the suppression of that evidence. According to the officer’s testimony, it was unusual to see a car in the location at such time, and he decided to make further inquiry. The officer did not activate the emergency lights of his police cruiser, but he positioned his vehicle at an angle relative to the parked automobile so as to illuminate the passenger side. The officer said that he did so without blocking the egress of the vehicle, which he then approached, "probably with a flashlight." The common pleas court awarded suppression of the drug evidence. The court framed the issue as whether the arresting officer had the legal authority to approach the parked vehicle and ask for identification from the occupants when there was no evidence of any criminal activity or a violation of the Motor Vehicle Code. The superior court affirmed. Upon review of the matter, the Supreme Court concluded that the arresting officer’s request for identification did not transform his encounter with Appellee into an unconstitutional investigatory detention. Accordingly, the Court reversed the superior court's order and remanded the case for further proceedings.

In this case, the Supreme Court addressed whether there was sufficient probable cause for the issuance of an anticipatory search warrant for Appellant Gregory Wallace's home. After review, the Court concluded conclude there was not and, thus, found the warrant, which authorized a search of Appellant's home after the completion of a controlled purchase by a confidential informant, violated the Fourth Amendment to the United States Constitution, as well as Article I, Section 8 of the Pennsylvania Constitution. The Court therefore reversed the order of the Superior Court and reinstated the order of the trial court which suppressed evidence seized from Appellant's home.

The issue before the Supreme Court concerned whether the Commonwealth could use evidence obtained pursuant to a limited Fifth Amendment waiver in light of a mental health defense used in Defendant Adam Rosen's first trial as rebuttal in his subsequent trial. The issue arose after the superior court upheld Defendant's life sentence for first-degree murder following his retrial. Upon review of the lower courts' record, the Supreme Court affirmed the superior court: "a defendant who raises a mental health defense can be compelled to submit to a psychiatric examination ... in submitting to this examination, however, the defendant does 'not categorically waive his Fifth Amendment [rights].' ...When the defendant voluntarily presents a mental health defense that he subsequently abandons, the Commonwealth may, upon retrial, utilize the results of its psychological examination as to those issues that have been implicated by the defendant's own expert."

Law enforcement officers suspected that Appellant Calvin Henderson may have co-perpetrated a violent rape-kidnapping. They sought samples of his DNA for comparison with material obtained from the victim and a vehicle used in the commission of the crimes. A member of a police sexual assault unit prepared an affidavit in support of probable cause; secured a magistrate's approval of a search warrant; and collected samples of Appellant's blood, hair, and saliva. The ensuing DNA analysis implicated Appellant, and he was charged. Appellant moved to suppress the evidence on the grounds that the affidavit was insufficient to establish probable cause, contending that the seizures of evidence from his body violated his constitutional rights under the federal and state constitutions. "The motion apparently raised concerns on the prosecution's part," as a decision was made to secure a second warrant. The strategy was to invoke the "independent source doctrine" as applied under the Pennsylvania constitution. Appellant then filed a second suppression motion, asserting that evidence secured under a second warrant was not the product of an independent source. The suppression court denied Appellant's motions. Upon review, the Supreme Court was "unwilling" to enforce a "true independence" rule in the absence of police misconduct "and on pain of the Commonwealth being forever barred from obtaining non-evanescent evidence connecting Appellant with his crimes." The Court concluded that it was appropriate to limit the independent source requirement to situations in which the rule prevents police from exploiting fruits of their own willful misconduct. "Ultimately, [the Court] believe[s] the 'twin aims' of Article I, Section 8 [of the Pennsylvania Constitution] - namely, the safeguarding of privacy and enforcement of the probable-cause requirement - may be vindicated best, and most stably, by taking a more conservative approach to the departure [the] Court has taken from the established Fourth Amendment jurisprudence."