Justia Constitutional Law Opinion Summaries

In an interlocutory appeal, appellant Gordon Williams appealed the Superior Court's order reversing the trial court's determination that he had the right to present testimony of an expert witness to rebut the Commonwealth's evidence in support of its motion to allow a child victim to testify at a preliminary hearing via contemporaneous alternative method. Finding no reversible error, the Supreme Court affirmed. View "Pennsylvania v. Williams" on Justia Law

The Commonwealth appealed a Superior Court order which reversed an order denying Appellee’s petition pursuant to the Post Conviction Relief Act (PCRA), vacated his judgment of sentence, and remanded for a new trial. Appellee, who was on parole for a robbery conviction at the time, and his brother, Dustin Spotz, got into an argument. The argument began when Dustin’s fiancee's teenage son placed a pet gerbil in front of Appellee’s face while he was watching television, resulting in Appellee yelling at the child and threatening to physically harm him. This angered Dustin, and the argument escalated into a physical confrontation, during which Dustin stabbed Appellee twice in the upper back with a butter knife, slightly wounding him. In response, Appellee threatened to kill Dustin, and he proceeded upstairs, returning with a handgun. Appellee fired eight shots at Dustin, two of which fatally struck Dustin in the chest. Appellee was charged with first degree murder, third degree murder, voluntary manslaughter, aggravated assault, recklessly endangering another person, carrying a firearm without a license, and former convict not to own a firearm. Appellee took the stand at trial, claiming self-defense and defense of others, seeking an outright acquittal of the non-firearms charges. The jury acquitted Appellee of first and third degree murder, but convicted him of voluntary manslaughter (heat of passion), aggravated assault, recklessly endangering another person, and the firearms offenses. No timely direct appeal followed. However, in early 1996, Appellee filed a timely petition for PCRA relief in which he claimed ineffective assistance of trial counsel for failing to file a timely appeal from his judgment of sentence and seeking the restoration of his direct appeal rights nunc pro tunc. Following a hearing, the PCRA court granted Appellee relief, and he later filed a timely nunc pro tunc appeal. The Commonwealth subsequently filed a petition for allowance of appeal challenging the Superior Court’s summary finding trial counsel was ineffective. Appellee filed a protective cross-petition alleging the Superior Court erred in failing to address and resolve his additional ineffective assistance of counsel claims. Upon review, the Supreme Court concluded the Superior Court erred in vacating Appellee’s judgment of sentence and awarding him a new trial due to trial counsel’s ineffectiveness. View "Pennsylvania v. Spotz" on Justia Law

Appellant Francis Lagenella, Jr. argued on appeal to the Supreme Court that the Superior Court erred in affirming the trial court's denial of his motion to suppress evidence seized by a police officer during a warrantless inventory search of his vehicle following a valid traffic stop. Upon careful consideration of the trial court record, the Supreme Court concluded there was no basis for the officer to conduct an inventory search of Appellant's vehicle, therefore that the evidence discovered during the inventory search should have been suppressed. View "Pennsylvania v. Lagenella Jr." on Justia Law

Appellant raped and brutally murdered three women in separate incidents over a one-year span. Prior to the capital murder trial, appellant pled guilty to three counts of burglary, two counts of attempted criminal homicide, and two counts of firearms not to be carried without a license. The jury returned a guilty verdict of first-degree murder for each murder as well as guilty verdicts on all remaining charges. Appellant appealed a Court of Common Pleas order his first petition for relief. Finding that appellant did not meet his burden for relief, the Supreme Court affirmed the PCRA court. View "Pennsylvania v. Robinson" on Justia Law

Appellant Harold Murray, IV, appealed the death sentence he received for his conviction on three counts of first degree murder. Upon review of the facts of this case, the Supreme Court affirmed the convictions, but vacated the death sentence. The case was remanded for a new penalty hearing. View "Pennsylvania v. Murray IV" on Justia Law

Appellant Lebanon Valley Farmers Bank (LVFB) is a Pennsylvania chartered bank, and a subsidiary of Fulton Financial Corporation, which merged with Keystone Heritage Group, Inc. The merger made Fulton the parent company of Lebanon Valley National Bank, which merged with Farmers Bank as part of the transaction, thereby forming LVFB. Prior to the merger, both Farmers Bank and National Bank were "institutions" subject to the Shares Tax. For the 2002 tax year, LVFB filed a Bank Shares Tax return, which included National Bank's pre-merger value in its calculation of its six-year average share value, as required by the combination provision. However, in 2005, LVFB filed a petition with the Board of Appeals, seeking a refund of the portion of its 2002 tax payment attributable to National Bank’s pre-merger share value. It claimed disparate treatment because the combination provision was inapplicable when mergers involved out-of-state banks or banks less than six years old. The Commonwealth Court has held, under the plain language of the statute, the combination provision applied only to combinations of "institutions" (i.e., banks with Pennsylvania locations). The trial court held LVFB, as the survivor of the merger of two Pennsylvania banks, should have reported a taxable share value which averaged the combined share value of each constituent institution over the past six years and was, therefore, not entitled to a refund. However, the court ordered the Commonwealth "to provide meaningful retrospective relief" to cure LVFB’s non-uniform treatment. The Commonwealth Court affirmed the Board of Finance and Revenue's classification of the merged LVFB and the 2002 tax assessment. After careful review, the Supreme Court disagreed with the Commonwealth Court's decision and reversed for further proceedings. View "Lebanon Valley Farmers Bank v. Pennsylvania" on Justia Law

Appellant Guillermo Ramos entered an open guilty plea to charges of Manufacturing of a Controlled Substance (Marijuana) and Possession with Intent to Deliver a Controlled Substance (Marijuana) (PWID) both of which were violations of 35 P.S. 780-113(a)(30). The Commonwealth provided written notice that it intended to proceed under the mandatory sentencing provision of 42 Pa.C.S. 9712.1 and 35 Pa.C.S. 780-113(a)(30) with regard to Ramos’s guilty plea to the PWID count. The trial court sentenced Ramos to an aggregate sentence of five months to ten years in prison. Specifically, Ramos received nine months to five years in prison on the Manufacturing of a Controlled Substance (Marijuana) conviction to run concurrently with a term of five months to ten years in prison on the PWID conviction. In an amended sentencing order after stating its belief that the sentence it had imposed on the PWID count exceeded the allowable statutory maximum, the sentencing court modified the sentence for that conviction to a flat, five year prison term which it deemed to be a mandatory sentence pursuant to 42 Pa.C.S. 9712.1. The Superior Court unanimously affirmed his judgment of sentence in an unpublished memorandum opinion. Ramos challenged on appeal to the Supreme Court the legality of imposing a mandatory minimum sentence pursuant to 42 Pa.C.S. 9712.1. After review, the Supreme Court concluded that as the most recent and the specific statute, 42 Pa.C.S. 9712.1 controlled in this case. Accordingly, under 1 Pa.C.S. 1933, the general provision of 42 Pa.C.S. 9756(b)(1) must yield to the specific sentencing provisions of Section 9712.1(a) and Section 780-113(f)(2), respectively requiring a five-year mandatory minimum sentence and a maximum sentence of no more than five years for a violation of Section 780-113(a)(30). As such, the trial court properly imposed a flat, five-year prison sentence for Ramos’s PWID conviction. View "Pennsylvania v. Ramos" on Justia Law

The issue on appeal before the Supreme Court in this matter involved questions of statutory construction pertaining to the five-year mandatory minimum sentence attaching to the offense of possession of a controlled substance with intent to deliver while in possession or control of a firearm. Specifically, the Supreme Court considered the meaning of the terms "control of a firearm" and "close proximity," as used in Section 9712.1(a), including the interrelationship between "control" and the concept of constructive possession as it appears in several Superior Court decisions. Appellant was charged with PWID, simple possession, possession of drug paraphernalia, and possession of an instrument of crime (the handgun). At a pre-trial conference, Appellant argued that the charge of possession of an instrument of crime should have been quashed, "given [the] lack of nexus between [Appellant] and that weapon and someone else's room." A common pleas judge quashed the charge, without explaining the reasoning underlying such ruling. The Supreme Court remanded the case for resentencing, with the admonition that imposition of the mandatory sentence under Section 9712.1(a) was not foreclosed. Should the lower court determine that the Commonwealth did not establish by a preponderance that Appellant was in constructive control of the firearm, the court should implement individualized sentencing, "per the usual practices." View "Pennsylvania v. Hanson" on Justia Law

Appellant Robert Diamond received two death sentences after pleading guilty to the first degree murders of Angel Guadalupe and Reginald Woodson. Appellant claimed on appeal that the trial court erred in the penalty phase, erred in finding statutory aggravating circumstances, erred in failing to find mitigating circumstances, erred in its weighing of aggravating and mitigating circumstances, and that his sentence was based on arbitrary factors. Finding no merit to appellant's challenges, the Supreme Court affirmed his conviction and judgment of sentence. View "Pennsylvania v. Diamond" on Justia Law

Issues of constitutional import stemming from cross-appeals taken from the Commonwealth Court's ruling on expedited challenges to Act 13 of 2012 were before the Supreme Court in this case. Act 13 contained sweeping legislation affecting Pennsylvania’s environment particularly the exploitation and recovery of natural gas in Marcellus Shale. The litigation was accelerated in part because the legislation itself was designed to take effect quickly and imposed obligations which required the challengers to formulate their legal positions swiftly; and in part in recognition of the economic importance of the legislation to the Commonwealth and its citizens. Following careful deliberation, the Supreme Court's decision found several challenged provisions of Act 13 were unconstitutional. Madame Justice Todd, and Mr. Justice McCaffery, found that several core provisions of Act 13 violated the Commonwealth’s duties as trustee of Pennsylvania’s public natural resources under the Environmental Rights Amendment; other challenges lacked merit; and several issues required further Commonwealth Court proceedings. Mr. Justice Baer, concurred in the mandate, and joined the majority in all but Parts III and VI(C); Justice Baer would have found the "core constitutional infirmity" sounded in substantive due process. Accordingly, the Commonwealth Court was affirmed in part, reversed in part, and the case remanded for further proceedings. View "Robinson Township, et al v. Pa. Public Utility Commission and Attorney General -" on Justia Law