Justia Constitutional Law Opinion Summaries

Melvin Knight appealed the death sentence he received for his role in the 2010 torture and murder of Jennifer Daugherty (“the Victim”), a 30–year-old intellectually disabled woman. On direct appeal, Appellant raised fourteen issues for the Pennsylvania Supreme Court’s review, including a challenge to the jury’s failure to find as a mitigating circumstance Appellant’s lack of a significant history of prior criminal convictions. In addressing this claim, the Court observed that it was undisputed that Appellant had no prior felony or misdemeanor convictions, a fact to which the prosecutor conceded during closing argument. The Supreme Court largely rejected Appellant's contentions of error, finding that Appellant’s sentence of death was not the product of passion, prejudice, or any other arbitrary factor, but, rather, was fully supported by the evidence that Appellant and his co-defendants held the intellectually-disabled victim against her will for several days, during which time they continuously subjected her to myriad forms of physical and emotional torture, eventually stabbing her in the chest, slicing her throat, strangling her, and stuffing her body into a trash can which they left outside under a truck. As the jury found that the aggravating circumstances outweighed the mitigating circumstances, the Court found Appellant’s sentence complied with the statutory mandate for the imposition of a sentence of death. View "Pennsylvania v. Knight" on Justia Law

Appellant Rod Jones, Jr. was charged with rape and various sexual offenses following allegations by his stepdaughter (“the victim”) of repeated sexual abuse over a period of several years. According to the victim, the first instance of abuse occurred when she was thirteen year sold. The victim did not tell anyone about these incidents for many years. because Appellant told her no one would believe her. The victim also feared what Appellant would say about her to her mother. When the victim was seventeen years old, she eventually told her mother about the abuse. Throughout the trial, defense counsel focused on discrepancies in the victim’s recounting of events in an attempt to undermine her credibility. At one point, the Commonwealth called as a witness Detective Scott Holzwarth, who interviewed the victim during the course of the investigation. The jury ultimately found Appellant guilty of rape, involuntary deviate sexual intercourse with a person under sixteen years of age, unlawful contact with a minor, aggravated indecent assault, sexual assault, statutory sexual assault, endangering the welfare of a child, corruption of minors, and indecent assault of a person under sixteen years of age. The trial court sentenced Appellant to an aggregate term of twenty-seven to sixty years’ imprisonment. Appellant filed a post-sentence motion, which the trial court denied. On appeal, Appellant argued, inter alia, that the trial court abused its discretion by allowing Detective Holzwarth to testify that child sexual assault victims were often unable to recall specific details and dates of sexual assaults. The Supreme Court found that expert testimony on the issue of a witness’s credibility was impermissible, as it encroached on the province of the jury to make such determinations. "While some testimony on this topic may be prohibited for impermissibly invading the jury's province of determining credibility, we disagree that all testimony will." The Court held that whether Detective Holzwarth's testimony complied with admissibility considerations was a question for the trial court upon remand. The superior court's judgment was reversed and the matter remanded for a new trial. View "Pennsylvania v. Jones Jr." on Justia Law

The Pennsylvania Supreme Court granted discretionary review in this case to consider the Superior Court’s application of the Independent Source Doctrine as a basis for upholding the trial court’s order denying the suppression motion filed by appellant Dennis Katona. Secondarily, the Court considered the validity of an intercept order issued under Section 5704(2)(iv) of the Wiretapping and Electronic Surveillance Control Act (“Wiretap Act”), which permitted the recording of in-home conversations when only one party consented, so long as the intercept was approved by an authorized prosecutor and the president judge of a court of common pleas finds that probable cause supports the order. In 2009, the Pennsylvania State Police (“PSP”) began working with a confidential informant (“CI”) who was a member of the Pagan Motorcycle Club. The CI, who had previously provided reliable evidence in other criminal investigations, informed Trooper Matthew Baumgard that appellant was also a member of the Pagans. In 2011, the CI contacted Trooper Baumgard to alert him appellant had unexpectedly arrived at his house that evening and offered to sell him three one-half ounce packages of cocaine for $650 per package. The following day, the CI again reached out to Trooper Baumgard, this time to inform him appellant had made a similar unsolicited stop at another Pagan member’s house in an attempt to sell the cocaine. Several weeks later, the CI was invited to appellant's home, and was again offered to purchase cocaine. The CI took the cocaine, left appellant’s home, immediately called Trooper Baumgard and turned it over to the PSP. The Commonwealth applied for a wiretap order allowing the CI to wear a recording device inside of appellant's home. Wearing the device, the CI made various controlled payments to appellant at appellant's home. During each encounter, Trooper Baumgard and his team surveilled the home and, thereafter, met with the CI to retrieve the recording device. Appellant filed an omnibus pre-trial motion seeking suppression of all evidence recovered from his home. The Pennsylvania Supreme Court concluded the Superior Court properly involved the Independent Source Doctrine, and therefor did not reach the various statutory and constitutional challenges appellant raised relative to the Wiretap Act. View "Pennsylvania v. Katona" on Justia Law

The Pennsylvania Supreme Court granted discretionary review in this case of first impression to consider the Constitutional scope of warrants to search cell phones seized incident to arrest, relating to illegal narcotics activity and firearms possession. Upon review of the facts specific to this case, however, the Court determined the search warrant in this matter was "so lacking in probable cause that it failed to justify any search of appellant's cell phone." The Court thus reversed the trial court's order, finding appellant's motion to suppress evidence obtained related to that search warrant should have been granted. The matter was remanded for further proceedings. View "Pennsylvania v. Johnson" on Justia Law

In 1983, after invading the home of three elderly siblings -- James, Angelina, and Victor Lunario -- Appellant David Chmiel stabbed them to death during the course of a robbery. Police found a makeshift mask at the scene that had been fashioned from a sweater sleeve. This distinctive sweater was soon identified as having belonged to Appellant’s brother, Martin Chmiel. Though initially denying involvement, Martin eventually admitted he and Appellant had jointly planned to burglarize the victims' home. Appellant would later be arrested and tried on three counts of first-degree murder (and other crimes on separate occasions), for which he received a death sentence. Martin testified consistent with police interviews in which he incriminated Appellant. Of particular relevance here, investigators attested to having found samples of hair on the sweater mask located at the crime scene. In June 2015, Appellant filed a serial PCRA petition, challenging the validity of expert testimony presented based on microscopic comparison of hair samples. He cited prominently to a joint press release of the FBI, the DOJ, the Innocence Project, and the NACDL, contending his convictions were based upon “unreliable scientific evidence,” and arguing that the press release was confirmatory. The Pennsylvania Supreme Court affirmed the judgment of the PCRA court, which found Appellant failed to demonstrate a reasonable probability the verdict against him would have been different at a trial with different expert testimony. View "Pennsylvania v. Chmiel" on Justia Law

In 2019, the Pennsylvania Supreme Court remanded this capital appeal to the PCRA court for further consideration of Russell Cox’s claim that, due to his intellectual disability, the Eighth Amendment to the United States Constitution and the Supreme Court of the United States’ decision in Atkins v. Virginia, 536 U.S. 304 (2002), precluded him from being sentenced to death. Upon remand, the PCRA court reconsidered the record and again determined Cox failed to establish he was entitled to relief. The Supreme Court vacated that second decision and remanded again for reconsideration. "[T]he Eighth Amendment compels courts applying our definition of intellectual disability to take into account, and to be guided by, current medical practices. The medical standards that we have adopted in Pennsylvania recommend the use of standardized measures, but do not mandate their use as the sole means to ascertain a person’s adaptive behaviors. Nor do current medical practices require clinicians or courts to ignore all other evidence when a standardized measure either is unavailable or incredible. The PCRA court operated under a contrary belief, and erroneously terminated its analysis prematurely upon determining that Dr. Toomer administered and evaluated the standardized test improperly. The court found that, without credible standardized test results, it became effectively impossible for Cox to show that he suffered from significant deficits in adaptive behavior. Our law neither compels nor supports this truncated analysis." View "Pennsylvania v. Cox" on Justia Law

Appellants Fred and Jolene Fouse owned two parcels of land in Huntingdon County, Pennsylvania, identified which they used as their primary residence from the time they acquired the two parcels in 1976 and 1987, respectively. Eventually, the Fouses fell behind in paying their property taxes. As mandated by the Real Estate Tax Sale Law (RETSL), the Huntington County Tax Claim Bureau scheduled an upset tax sale. Appellees Saratoga Partners, LP submitted the highest bid. Three months later, in December 2016, the Fouses filed a “petition to redeem property sold at tax sale,” even though Huntington County, a sixth class county, prohibited post-sale redemptions. Instead, the Fouses asserted, inter alia, a right to redeem under section 7293 of the Municipal Claims and Tax Liens Act (MCTLA), by paying the amount paid by Saratoga at the tax sale. In their brief, the Fouses acknowledged that the MCTLA applied only to first and second class counties, but the absence of a right of redemption provision in the RETSL resulted in citizens of second class A through eighth class counties being treated less favorably than citizens of first and second class counties, in violation of the equal protection provisions of the federal and state constitutions. After review, the Pennsylvania Supreme Court concluded the General Assembly’s decision to omit the right of post-sale redemption from the RETSL was constitutional because it was rationally related to a legitimate state interest. Accordingly, the Court affirmed the Commonwealth Court's order upholding the denial of the Fouses' petition for redemption. View "Fouse v. Saratoga Partners, et al" on Justia Law

Appellant Aquil Johnson claimed he was entitled to a refund of monies deducted from his inmate account pursuant to Act 84 because no procedural safeguards were in place when the deductions began. Recent decisions by the Pennsylvania Supreme Court and the Third Circuit Court of Appeals confirmed that, under the Due Process Clause of the Fourteenth Amendment, certain safeguards had to be applied before the first Act 84 deduction was made in connection with a given criminal sentence. The issue before the Pennsylvania Supreme Court in this case was whether relief was available where the first deduction was made before those decisions were announced. The Supreme Court found that due process mandated the Department of Corrections afford post-deprivation process analogous to the pre-deprivation procedures required by Bundy v. Wetzel, 184 A.3d 551 (2018). Further development was required to determine whether the Department already supplied Appellant with adequate post-deprivation process. The Court found Appellant failed to set forth a valid basis to implicate an administrative ability-to-pay hearing. The Commonwealth Court was affirmed insofar as it dismissed Appellant’s claims relating to negligence and the administrative ability-to-pay hearing; it was vacated to the extent it dismissed Appellant’s claim relating to due process. The matter is remanded for further proceedings. View "Johnson v. Wetzel" on Justia Law

Ordinarily, a petitioner seeking relief under the Pennsylvania Post Conviction Relief Act (“PCRA”), has to file the petition within one year of the date upon which his or her judgment of sentence becomes final. The PCRA set forth three exceptions to this one-year limitation. Among these is the “newly discovered fact” exception, which rendered a petition timely when the petitioner establishes that “the facts upon which the claim is predicated were unknown to the petitioner and could not have been ascertained by the exercise of due diligence.” Interpreting this provision, the Pennsylvania Supreme Court has held that the newly discovered fact exception was limited by a presumption relating to matters of public record, pursuant to which a court may find that information available to the public is not a fact that is “unknown” to the petitioner. In this case, the superior court reversed the PCRA court’s order granting relief to Appellant Elwood Small, reasoning, inter alia, that the Supreme Court's holding in Commonwealth v. Burton, 158 A.3d 618 (Pa. 2017) did not apply to Small because he was represented by counsel some years earlier, in separate post-conviction proceedings, and thus could not be considered pro se for purposes of Burton. Although the Supreme Court ultimately concluded Small was not entitled to relief, it nonetheless was persuaded by Small’s frontal challenge to the public record presumption: "Small’s assertion of newly discovered facts is not foreclosed pursuant to a categorical presumption regarding matters of public record. However, because the Commonwealth has established that the factual record does not support Small’s position on the statutory requirements, Small nonetheless cannot establish the applicability of an exception to the PCRA’s time bar, and the PCRA court accordingly lacked jurisdiction to award him relief upon his substantive claims." View "Pennsylvania v. Small" on Justia Law

This case arose out of an altercation over a debt, during which Appellant Christopher Weir struck and damaged Jacob Korimko's motorcycle. Weir was charged with one count each of burglary, criminal mischief, harassment, and disorderly conduct. He proceeded to a non-jury trial in October 2017. Concerning the damage to his motorcycle, Korimko testified at trial that he paid $2492 to repair his vehicle: $1492 for new parts and $1000 to paint the new parts. Korimko testified that he could not afford the painting expense, so the new parts remained unpainted. The trial court found Weir guilty, and sentenced him to probate for two years and ninety days. The trial court also ordered restitution totaling $2000, noting it was "splitting the paint job cost only because we don’t have accurate detailed information in that regard." Weir filed a timely post-sentence motion, raising a challenge to the weight of the evidence supporting the verdict and a non-specified challenge to the restitution order, claiming the latter “exceeds the amount of loss suffered by [Korimko] in repairing the damage to his bike.” The Pennsylvania Supreme Court granted discretionary review to determine whether a challenge to the amount of restitution imposed pursuant to Section 1106 of the Pennsylvania Crimes Code implicated the discretionary aspects of sentencing or the legality of the sentence, "a dichotomy relevant to the need for issue preservation." Upon review, the Court concluded that a challenge to the sentencing court’s determination as to the amount of restitution sounded in sentencing discretion and, therefore, had to be preserved. The Superior Court’s ruling was affirmed; Weir’s restitution challenge implicated a discretionary aspect of the sentence that was not properly preserved and, therefore, was waived. View "Pennsylvania v. Weir" on Justia Law