Justia Constitutional Law Opinion Summaries

A court of common pleas granted Appellant Noel Montalvo's petition for post-conviction relief by granting a new guilt-phase trial. The Commonwealth appealed the PCRA court’s grant of a new guilt-phase trial; it did not challenge the PCRA court’s grant of a new penalty-phase trial. Appellant cross-appealed to challenge the trial court's rejection of "a myriad of additional bases for granting him a new guilt-phase trial." Appellant was accused of killing, or acting as an accomplice to the killing of his brother's estranged common law wife and the man she may have briefly dated. Appellant's brother was convicted on two counts of first-degree murder and one count of burglary, for which he was sentenced to death. Appellant would be convicted by jury on first-degree murder charges for the death of his brother's wife, the second-degree murder of her companion, conspiracy to commit murder and burglary. The jury determined the aggravating circumstances outweighed the mitigating circumstances in Appellant's case, and recommended a sentence of death. The PCRA court granted appellant's petition for relief on grounds of ineffective assistance of trial counsel. After review, the Pennsylvania Supreme Court agreed with the PCRA court that appellant established his ineffectiveness claim, and therefore, a new guilt-phase trial was warranted. In light of this conclusion, the Court did not address the issues raised by appellant in his cross-appeal. View "Pennsylvania v. Montalvo" on Justia Law

The Pennsylvania Supreme Court granted the Pennsylvania Department of Transportation (“PennDOT”)’s petition seeking review of a Commonwealth Court holding that a de facto taking of an unmined coal estate, owned by Penn Pocahontas and leased to PBS Coals, Inc. (collectively “the Coal Companies”), occurred under the Eminent Domain Code, 26 Pa.C.S. sections 101-1106 (“Code”), when PennDOT’s construction of Highway 219 on an adjoining parcel destroyed options for constructing rights-of-ways to the coal estate’s surface. In reaching that conclusion, the Commonwealth Court held that the feasibility of mining the coal, as measured by the probability of obtaining a legally required permit from the Department of Environmental Protection (“DEP”), was relevant only to damages. The Supreme Court reversed the Commonwealth Court’s decision, agreeing with PennDOT that the legality of extracting the coal went directly to the trial court’s duty to determine whether a taking occurred. Furthermore, the Court held the Commonwealth Court erred by failing to remand the case for consideration of whether consequential damages are available to the Coal Companies. The matter was remanded to the Commonwealth Court with instructions to remand to the trial court with respect to the Coal Companies’ consequential damages claim. View "PBS Coals, et al v. PennDOT" on Justia Law

In September 2014, prior to the request for the records at issue in this case, the Abolitionist Law Center published a report which alleged a causal connection between the ill health of inmates at SCI-Fayette, and the facility’s proximity to a fly ash dumpsite. In response to the report, the Pennsylvania Department of Corrections (DOC) coordinated with the Department of Health (DOH) to investigate the allegations (the No Escape Investigation). Reporter Christine Haines of The Herald Standard (Appellees) sent an e-mail Right-to-Know-Law (RTKL) request to the DOC seeking documentation of inmate illnesses. The DOC denied Appellees' request in its entirety, citing several exceptions under Section 708(b) of the RTKL, as well as attorney-client privilege and deliberative process privilege grounds. Then in December 2014, in-house counsel for the DOC disclosed fifteen pages of records to Appellees. Appellees asked DOC to verify that its December disclosure was a complete response. Several additional records were subsequently released, but implicitly, the records released were the DOC's response. In February 2015, Appellees filed a petition for enforcement with the Commonwealth Court, seeking statutory sanctions and attorney fees alleging DOC demonstrated bad faith in responding to the request for records. The court identified records that the DOC should have provided. But because the panel could not discern the full extent of any non-compliance by DOC, the panel directed the parties to file a stipulation as to the disclosure status of court-identified five classes of records. Appellees' motion was thus denied without prejudice, and the court reserved judgment on the issue of bad faith sanctions. The Pennsylvania Supreme Court granted appeal in this matter to consider the assessment of sanctions and fees based on the Commonwealth Court's finding of bad faith and willful and wanton behavior. The Supreme Court ultimately affirmed, finding that Section 1304(a0(1) of the RTKL “permit[s] recovery of attorney fees when the receiving agency determination is reversed, and it deprived a requester of access to records in bad faith.” View "Uniontown Newspaper, et al v. PA Dept of Cor." on Justia Law

The Pennsylvania Supreme Court granted Appellant Keith Alexander's petition for allowance of appeal asking the Court to overrule or limit Commonwealth v. Gary, 91 A.3d 102 (Pa. 2014) (OAJC), a plurality result announcing that, without limitation, the federal automobile exception to the warrant requirement of the Fourth Amendment to the federal Constitution applied in Pennsylvania. "What Gary did not settle is whether the federal automobile exception is consistent with Article I, Section 8 of the Pennsylvania Constitution." The Court held Article I, Section 8 afforded greater protection than the Fourth Amendment, and reaffirmed prior decisions: the Pennsylvania Constitution required both a showing of probable cause and exigent circumstances to justify a warrantless search of an automobile. View "Pennsylvania v. Alexander" on Justia Law

Mitchell Gregory Peck, Jr. (“Peck”) was convicted of drug delivery resulting in death, and sentenced to twenty to forty years of imprisonment. In this appeal, the Pennsylvania Supreme Court considered the interplay between the territorial application of the Crimes Code, including in particular Section 102, 18 Pa.C.S. section 102, and the sufficiency of the evidence to support a conviction. Specific to this appeal, the Court addressed whether Peck’s conviction was supported by sufficient evidence where the drug delivery occurred in Maryland and the resulting death occurred in Pennsylvania. While the Commonwealth had subject matter jurisdiction to prosecute Peck for DDRD, the Supreme Court determined it could not present evidence to support his conviction. The Superior Court’s decision to the contrary was reversed and Peck’s judgment of sentence was vacated. View "Pennsylvania v. Peck Jr." on Justia Law

A series of appeals presented a question of whether the Pennsylvania Election Code required a county board of elections to disqualify mail-in or absentee ballots submitted by qualified electors who signed the declaration on their ballot’s outer envelope, but did not handwrite their name, their address, and/or a date on the ballot, where no fraud or irregularity has been alleged. Petitioner Donald J. Trump for President, Inc. (the “Campaign”) challenged the decision of multiple County Boards of Elections to count absentee and mail-in ballots. The Campaign did not contest these ballots were all timely received by the respective Boards prior to 8:00 p.m. on November 3, 2020 (election day); that they were cast and signed by qualified electors; and that there was no evidence of fraud associated with their casting. The Campaign instead contended these votes should not have been counted because the voters who submitted them failed to handwrite their name, street address or the date (or some combination of the three) on the ballot-return outer envelope. The Pennsylvania Supreme Court was "guided by well-established interpretive principles" including that where the language of a statute was unambiguous, the language would control. "In the case of ambiguity, we look to ascertain the legislative intent, and in election cases, we adhere to the overarching principle that the Election Code should be liberally construed so as to not deprive, inter alia, electors of their right to elect a candidate of their choice. . . . "Election laws will be strictly enforced to prevent fraud, but ordinarily will be construed liberally in favor of the right to vote." View "In Re: Canvass of Absentee and Mail-In Ballots" on Justia Law

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