Justia Constitutional Law Opinion Summaries

The issue before the Supreme Court in this case centered on whether county commissioners could place an ordinance-generated referendum question on the primary election ballot seeking to amend a home rule charter without first seeking election of a commissioned study when the question adopted by the ordinance attempted to abolish certain row offices. In 2013, the Lackawanna County Board of Commissioners sought to direct that a referendum question be placed on the May 21, 2013, municipal primary election ballot proposing to abolish the elected offices of Sheriff, Clerk of Judicial Records, Recorder of Deeds and Register of Wills, and to redefine the duties that had been assigned to those positions as legislative powers under its Charter. Appellant Joseph Pilchesky filed a pro se petition requesting that the trial court strike the ballot question or, in the alternative, that the Board of Elections separate the single ballot question into four queries, one for each of the offices to be abolished. In his petition, Pilchesky also asserted that Ordinance 224 directed a ballot question that proposed a change in the form of government rather than an amendment to the Charter and that such a change can be effected only by petition or ordinance seeking election of a government study commission under 53 Pa.C.S. 2911. The trial court denied the challenge seeking to bar Ordinance 224 from appearing on the primary ballot, and rejeted Pilchesky's argument that the changes to the existing form of government proffered by Ordinance 224 could be accomplished by the statutorily mandated government study commission. In an unpublished memorandum opinion, the Commonwealth Court unanimously affirmed. Upon review, the Supreme Court found that in light of the plain language of the Home Rule Law and the considerations Pilchesky raised, the amendment proposed by the Commissioners constituted a change in the form of government that could have been accomplished only by following the procedure outlined in Subchapter B of the Home Rule Law. The decision of the Commonwealth Court was Reversed. View "Pilchesky v. Lackawanna County" on Justia Law

In this case, the trial and intermediate courts determined that a general contractor was not a statutory employer relative to an employee of its subcontractor. The issue before the Supreme Court centered on the tension between such rulings and the Supreme Court’s longstanding jurisprudence that conventional subcontract scenarios serve as paradigm instances in which the statutory-employment concept applies. Appellant Worthington Associates, Inc., was hired as the general contractor for an addition to a Levittown church. Worthington, in turn, entered into a standard-form subcontract with Patton Construction, Inc., of which Appellee Earl Patton was the sole shareholder and an employee, to perform carpentry. While working at the construction site, Mr. Patton fell and sustained injuries to his back. Subsequently, the Pattons commenced a civil action against Worthington contending that the company failed to maintain safe conditions at the jobsite. Worthington moved for summary judgment on the basis that it was Mr. Patton’s statutory employer and, accordingly, was immune from suit. After the motion was denied, trial proceeded during which Worthington reasserted its claim to immunity in unsuccessful motions for a nonsuit and a directed verdict. "Having set up an errant dichotomy for the jurors, the [trial] court proceeded to instruct them concerning the differences between independent contractors and employees at common law. In doing so, the trial court compounded the underlying conceptual difficulties it had engendered, because [the Supreme] Court has long held that, for the salient purposes under Sections 203 and 302(b) of the WCA, the term 'independent contractor' carries a narrower meaning than it does at common law." The jury returned a verdict in favor of the Pattons in the amount of $1.5 million in the aggregate. Post-trial motions were denied, and Worthington appealed. A Superior Court panel affirmed. The Supreme Court reversed, finding that Mr. Patton’s relationship with the owner here was undeniably a derivative one, arising per a conventional subcontract with a general contractor (Worthington). "[U]nder longstanding precedent, neither Patton Construction, Inc., nor Mr. Patton was an 'independent contractor' relative to Worthington." View "Patton v. Worthington Associates" on Justia Law

Appellant Lance Arrington appealed the death sentence he received after a jury convicted him of first-degree murder and for violating the Uniform Firearms Act. While appellant raised numerous claims of error to challenge the sentence, the Supreme Court found none and affirmed his conviction and sentence. View "Pennsylvania v. Arrington" on Justia Law

The Pennsylvania Turnpike Commission filed a petition for review of an order of the supervising judge of the Thirty-Third Statewide Investigating Grand Jury (Dauphin County) which denied the Commission’s motion for a protective order seeking to prohibit the Office of Attorney General from reviewing allegedly privileged or protected communications between the Commission and its counsel. Finding no reversible error, the Supreme Court affirmed the denial of the Commission's petition. View "In Re: 33rd Statewide Investigating Grand Jury" on Justia Law

The Commonwealth appealed a Superior Court order that held a trial court was required to determine whether a child victim was competent to testify prior to admitting to her out-of-court statements into evidence under the Tender Years Hearsay Act (TYHA). Upon review of the facts of this case, the Supreme Court reversed the Superior Court, holding that a determination of a child's competency under the rules of evidence is not a prerequisite to the admission of hearsay statements under TYHA. View "Pennsylvania v. Walter" on Justia Law

The issue before the Supreme Court in this case was whether the Superior Court erred in affirming the trial court's suppression of physical evidence seized incident to arrest based on an expired arrest warrant where the arresting officer reasonably believed the warrant was valid. Upon review of the particular circumstances of this case, the Supreme Court concluded the trial court was correct in suppressing the evidence in question here. Accordingly, the Court affirmed the Superior Court. View "Pennsylvania v. Johnson" on Justia Law

Appellant Imanuel Bassil Ali appealed the dismissal of his second petition for collateral relief under the Post Conviction Relief Act as untimely filed. Appellant argued he suffered from mental incompetency at relevant times during his first PCRA proceedings so as to qualify his second PCRA petition for the newly-discovered evidence exception to the PCRA time-bar. Because he failed to establish his claim by a preponderance of the evidence, the Supreme Court affirmed the dismissal. View "Pennsylvania v. Ali" on Justia Law

In a medical malpractice case, the issue presented for the Supreme Court's review centered on whether the trial court properly gave an "error in judgment" jury instruction. The underlying case arose out of the death of a two-month-old child while under the care of his pediatricians. Appellees sued the pediatricians. Their experts testified that the doctors deviated from the standard of care by failing to refer the child for further testing. The trial judge held a charging conference and stated that all of the doctors' proposed points for charge would "either be read or covered." The judge, however, did not say which (if any) proposed changes would actually be read to the jury. Appellees did not object at the time. The judge then proceeded to discuss one of the doctors' proposed "error in judgment" charge. Counsel for Appellees objected that the instruction was inappropriate for this case. The judge ultimately included the "error in judgment" charge when instructing the jury. The jury later ruled in the doctors' favor. Appellees filed timely post-trial motions arguing, among other things, the trial court erred in giving the "error in judgment" charge. Approximately one month after Appellees filed their post-trial motions (and before the trial court ruled on those motions), the Superior Court filed its decision in "Pringle v. Rapaport," (980 A.2d 159 (Pa.Super. 2009)). In that case, the trial court had given a charge very similar to the one given here. Approximately one year later, the Superior Court decided Pringle, holding: "such an instruction should never be given because it 'wrongly suggests to the jury that a physician is not culpable for one type of negligence, namely the negligent exercise of his or her judgment.'" The trial court here denied Appellees' post-trial motions and entered judgment in the doctors' favor. The Supreme Court concluded the Superior Court applied Pringle correctly to the circumstances of this case. The case was remanded to the trial court for further proceedings. View "Passarello v. Grumbine" on Justia Law

Appellant Patrick Stollar was convicted for the murder of an elderly Upper Saint Clair woman in 2003. Appellant received the death penalty for the murder, as well as a ten to twenty year sentence for predicate robbery and burglary charges. Appellant appealed the denial of his post-sentence motions, raising three issues for the Supreme Court's consideration. After review of those issues, the Supreme Court concluded the arguments appellant raised were without merit and affirmed his convictions and sentences. View "Pennsylvania v. Stollar" on Justia Law

Appellant Kenneth Hairston was convicted of two counts of murder and sentenced to death for each count. He failed to file a timely post-conviction motion or appeal, and thereby waived any claims of error. The Supreme Court automatically reviewed the case, evaluated the sufficiency of the evidence supporting the convictions, and the sentences appellants receive. The Supreme Court affirmed appellant's convictions and sentence. Appellant thereafter moved for reinstatement of his appellate rights nunc pro tunc. After the trial court granted appellant's motion, he raised numerous claims of error at trial relating to his convictions. Upon consideration of those claims, the Supreme Court found no reversible error and reaffirmed his convictions and death sentence. View "Pennsylvania v. Hairston" on Justia Law