Justia Constitutional Law Opinion Summaries

The Supreme Court granted allowance of appeal to determine whether: (1) the repeal of an ordinance mooted any challenges to that ordinance; (2) whether the Commonwealth Court may issue an opinion on the merits of certain issues where it subsequently remands the case for a determination of mootness on another issue; and (3) whether parties to a hearing can continue a challenge to a zoning ordinance once the original challenger has withdrawn. Because “parties to a hearing” are distinct from “party appellants,” unless the former have taken steps to become party appellants, the Supreme Court found they cannot continue the challenge. Accordingly, the Commonwealth Court’s decision permitting parties to the hearing to continue the challenge brought by the original party appellant was reversed, and the attempted challenge was dismissed. View "Stuckley v. ZHB of Newtown Twp." on Justia Law

The Superior Court reversed a Court of Common Pleas order, which granted appellant's motion to dismiss. In 2006, police conducted a controlled cocaine buy from appellant using a confidential informant. Appellant and the informant met at a convenience store then drove to a bar parking lot. The informant then dropped appellant off at a nearby plaza and later gave police the cocaine he purchased. Appellant was not then arrested. In 2007, appellant was kidnapped and robbed. At the interview about the incident, Detective Charles Shoemaker (one of the officers who assisted in the 2006 controlled buy), informed appellant he was under investigation in connection with the 2006 incident. Appellant confessed he was in the business of selling cocaine. Appellant was arrested and charged with possession with intent to deliver (PWID) in connection with the 2006 sale; he later pled guilty to that charge. In a separate investigation, a state grand jury began investigating drug distribution activities in the area of the 2006 incident, targeting certain individuals, including appellant. In its 2009 presentment, the grand jury implicated appellant as one of the organization's distributors. Specifically, the grand jury found that between 2006 and 2007, appellant sold cocaine at his home and various bars. The presentment did not mention the 2007 case, or any controlled buys involving appellant. Appellant filed an omnibus pre-trial motion to dismiss the 2010 case pursuant to the compulsory joinder rule, claiming the 2010 case arose from the same criminal episode as the 2007 case. The trial court granted the motion, and the Commonwealth appealed. A panel of the Superior Court reversed and remanded, instructing the trial court to reinstate the 2010 charges. Upon review, the Supreme Court concluded there was no substantial duplication of issues of fact or law; thus, the two prosecutions did not arise from the same criminal episode. View "Pennsylvania v. Reid" on Justia Law

In a direct appeal, the issue before the Supreme Court in this case was the constitutionality of legislation mandating a one-time transfer of money from the Medical Care Availability and Reduction of Error Fund to Pennsylvania's General Fund. The Commonwealth faced a budget impasse for the 2009-10 fiscal year that lasted approximately 100 days. An interim budget was passed, and impasse was resolved when the Governor approved a supplemental appropriations bill, as well as implementing legislation making amendments to Pennsylvania's Fiscal Code. One of Act provisions designed to balance the budget directed that $100 million be transferred from the MCARE Fund to the General Fund. Appellees sought a declaration that: (1) the transfer of $100 million from the MCARE Fund to the General Fund extinguished vested rights or constituted an illegal taking in violation of the due process guarantees contained the Commonwealth and federal constitutions; and (2) the transfer violated the Uniformity Clause of the Pennsylvania Constitution. Concerned that the Commonwealth might effectuate the transfer and dissipate the funds, Appellees filed an application for preliminary injunctive relief (a temporary restraining order). After review, the Supreme Court concluded that the October 2009 amendment to the Fiscal Code transferring $100 million from the MCARE Fund to the General Fund implicated the providers' due process rights, but that the question of whether the legislation was finally unconstitutional requires further factual development. Accordingly, the Court reversed the Commonwealth Court's order granting summary relief. View "Geisinger Health System, et al v. Pennsylvania" on Justia Law

The Supreme Court granted certiorari to determine whether the superior court in this matter erred in determining that police officers, when seeking consent to administer a blood test for the presence of drugs or alcohol following a traffic accident, must tell the person that the results of the test could be used for criminal or prosecutorial purposes. To the extent the court held that an officer must inform a person that a positive result in a blood test may have criminal repercussions, and such failure renders any consent to the blood test invalid, the court erred. The Supreme Court held that the totality of the circumstances presented in this case supported the trial court’s conclusion that the suppression of blood test results was not warranted. View "Pennsylvania v. Smith" on Justia Law

In a direct appeal, appellant Michael Parrish appealed two death sentences he received after a jury found him guilty for the shooting deaths of his girlfriend Victoria Adams and their 19-month-old son Sidney. Based upon its thorough review of the record, the Supreme Court concluded the evidence was fully sufficient to sustain both of Appellant’s first-degree murder convictions and death sentences: Appellant confessed to killing both Victoria and Sidney, and, on the night of the incident, Appellant was witnessed at the crime scene with a gun; multiple individuals heard gunshots coming from Appellant’s apartment; Appellant fired his gun at Adams, Ahern, and Ramos; and a .357 Glock semi-automatic handgun was recovered during Appellant’s arrest that matched the thirteen .357 shell casings found at the crime scene. View "Pennsylvania v. Parrish" on Justia Law

Appellee Pamela Vukman appealed a superior court order that affirmed the Allegheny County Court of Common Pleas. That order granted appellees motion to set aside judgment and sheriff's sale, and dismissed appellant Beneficial Consumer Discount Company's praecipe without prejudice. Beneficial moved to foreclose appellee for being in default of her mortgage. The parties agreed to a settlement whereby Beneficial received judgment for the accelerated amount due on the mortgage as long as appellee made regular payments. Appellee eventually defaulted according to the terms of the settlement; Beneficial filed for a writ of execution. The property was sold at a sheriff's sale, and Beneficial was the successful bidder. Appellee then moved to set aside the sale, arguing Beneficial failed to comply with the requirements under the Homeowner's Emergency Mortgage Act. The court concluded that Beneficial did not follow the Act's requirements, and as a result, it id not have jurisdiction. Therefore the court set aside the sale and dismissed Beneficial's original complaint. Beneficial appealed; the superior court affirmed. Upon review, the Supreme Court concluded that the Act's notice requirement did not implicate subject matter jurisdiction of the trial court, it reversed and remanded the case for further proceedings. View "Beneficial Consumer Discount Company v. Vukman" on Justia Law

The Supreme Court granted review to determine whether the admission of accuracy and calibration certificates for breath test machines without testimony from the individual who performed the testing and prepared the certificates violated appellant's Sixth Amendment right to confrontation. Under the circumstances of this case, the Court held that appellant's Sixth Amendment right was not violated, and affirmed the order of the Superior Court. View "Commonwealth v. Dyarman" on Justia Law

The Supreme Court granted certiorari to determined the standard and scope of review that applies when a court reviews a final determination of the Office of Open Records (OOR) under the Right-to-Know Law (RTKL). Appellee, an employee of the Pittsburgh Tribune-Review, requested access to records from the Pennsylvania Emergency Management Agency (PEMA). PEMA determined that disclosure of identities on the requested documents was critical information that revealed gaps, vulnerabilities and emergency response capabilities in the Commonwealth, and that disclosure would be reasonably likely to jeopardize or threaten public safety or preparedness or public protection activities, and redacted portions. Appellee appealed, and an OOR appeals officer, without holding a hearing, but after requesting and receiving memoranda of law from Appellee and PEMA, issued a final written determination that redaction of the information was proper. Upon review, the Supreme Court held that the Commonwealth Court correctly held that its standard of review was de novo and that its scope of review is broad or plenary when it hears appeals from determinations made by appeals officers under the RTKL. View "Bowling v. Office of Open Records" on Justia Law

Petitioners claimed that Article V, Section 16(b) of the state charter was unconstitutional. They argued that section 16(b) deprived them of their inherent right to be free of age-based discrimination, particularly because the section mandates that jurists retire the year they turn 70 years old. In prior decisions, the Pennsylvania Supreme Court concluded that Article V, Section 16(b) was not so irrational as to be considered unconstitutional. The Court denied petitioners' application for relief and dismissed the case with prejudice. View "Friedman v. Corbett" on Justia Law

Described as a "frequent flier of frivolous litigation," Appellee Alton Brown sought a writ of mandamus to force the Montgomery County Prothonotary to accept his complaint against various prison and state government officials. The complaint was rejected multiple times for being incomplete. The prothonotary moved to dismiss under the "three strikes" rule, and the trial court granted the motion. The Commonwealth Court overturned the trial court's dismissal with prejudice of Appellee's request for the writ. The issue on appeal to the Supreme Court was whether appellee's mandamus action constituted "prison conditions litigation" and would have therefore been subject to the "three strikes rule." Appellee argued his complaint was not subject to three strikes because in this case, the writ of mandamus was a procedural mechanism for an appellate court to review certain categories of lower court orders. The Supreme Court agreed with the prothonotary that a petition for writ of mandamus against the prothonotary may constitute prison conditions litigation and thus may be subject to three strikes: "Appellee [demanded that the Court] force the prothonotary to accept his complaint . . . just so the court may dismiss the complaint as prison conditions litigation. This is a clear waste of judicial resources, and in the interest of judicial economy, [the Court held] this mandamus petition to force acceptance of a complaint about prison conditions is itself prison condition litigation within the meaning of the statute. . . . An individual may not skirt the legislature's intent to preclude him from filing frivolous litigation merely by filing for an extraordinary writ." View "Brown v. Prothonotary of Montgomery County" on Justia Law