Justia Constitutional Law Opinion Summaries

Robert Anthony Flor petitioned for post-conviction relief, alleging ineffective assistance of counsel at his trial for homicide. After two years of proceedings in the PCRA court, the Commonwealth moved for the production of documents, requesting “access to the complete records” of trial counsel. This file included some 30,000 pages of documents pertaining to Flor’s conviction, sentence, and direct appeal, and filled twelve banker’s boxes. At a hearing on the Commonwealth’s motion, Flor’s PCRA counsel requested several weeks to review the file to allow removal of material protected by attorney-client privilege or constituting attorney work product. The PCRA court granted the Commonwealth’s motion and denied PCRA counsel’s request for time to conduct a privilege review. Flor appealed the discovery order. After review, the Supreme Court concluded that the PCRA court’s discovery order was immediately appealable, and that the PCRA court abused its discretion in affording wholesale discovery without conducting an issue-specific waiver analysis, as required by "Commonwealth v. Harris," (32 A.3d 243 (Pa. 2011)). Accordingly, the Court vacated the discovery order, and remanded for immediate inspection of the file. View "Pennsylvania v. Flor" on Justia Law

Appellant Laquanta Chapman shot and killed his sixteen-year-old neighbor in the basement of Appellant's home. Subsequently, with the assistance of his younger cousin, Bryan Bird, Appellant dismembered the victim’s body and disposed of the remains in the trash. Weeks later, law enforcement officers investigating the sale of illicit drugs from Appellant’s premises obtained a warrant to search them for evidence of drug activity. In the course of the ensuing search, police discovered an abundance of residual, physical evidence from the killing and dismemberment. Appellant was arrested and charged with murder and other crimes. The jury convicted Appellant of first-degree murder and other offenses and returned a death verdict in a separate penalty proceeding. Post-sentence motions were filed and denied, and this direct appeal followed. Appellant presented several claims of trial court error at the penalty stage, arguing primarily that the evidence offered by the Commonwealth in support of the sole aggravating circumstances pursued by the prosecution and found by the jury was insufficient. View "Pennsylvania v. Chapman" on Justia Law

Appellant Kevin Murphy was convicted by jury for the first-degree murder of his mother, sister and aunt. This case went before the Pennsylvania Supreme Court on direct appeal. Three of the five challenges to the judgment of sentence raised by Appellant centered on the adequacy of the Commonwealth’s evidence of his guilt. He also argued that the trial court erred in not suppressing certain evidence from trial. In Appellant’s final argument, he asserted that, because the aggravating circumstances found by the jury in the penalty proceedings overlapped, the jury impermissibly “double-count[ed]” the aggravation. Finding no reversible error as to any of Appellant's claims, the Supreme Court affirmed his death penalty. View "Pennsylvania v. Murphy" on Justia Law

In a discretionary appeal by the Commonwealth, the Supreme Court considered whether Appellee Claude Descardes was entitled to seek review of his ineffectiveness of counsel claim, based on counsel’s failure to advise him of the collateral consequences of his guilty plea, via a petition for writ of coram nobis. Appellee, a Haitian national who held resident alien status in the United States, pled guilty to insurance fraud, a felony, and conspiracy to commit insurance fraud. Appellee was not advised prior to entering his plea that deportation was a collateral consequence of his plea pursuant to the Immigration and Naturalization Act. Appellee was sentenced to one year of probation and a fine, and did not appeal his judgment of sentence. He completed serving his probationary sentence in November 2007. In 2009, Appellee left the United States on personal business and, when he attempted to reenter the country, United States immigration officials denied him reentry due to his felony convictions. After review, the Supreme Court concluded that Appellee was not entitled to seek review of his ineffectiveness of counsel claim, and accordingly vacated the Superior Court's judgment holding to the contrary. Appellee's underlying petition for postconvicton relief was dismissed. View "Pennsylvania v. Descardes" on Justia Law

In July 2004, Appellant James Vandivner fatally shot his fiancee, Michelle Cable, for which he received the death penalty. Appellant appealed the denial of his petition for post-conviction relief, raising claims pertaining to his pre-trial, guilt, and penalty-phase proceedings. The PCRA court, having concluded Appellant’s claim did not have arguable merit, did not fully address Appellant's ineffectiveness of counsel claims. The Supreme Court concluded this omission required further review. It vacated the PCRA court’s order and remanded this matter back to the PCRA court for preparation of a supplemental opinion addressing whether any reasonable basis existed for trial counsel’s failure to investigate certain aspects of Appellant's ineffectiveness claims. View "Pennsylvania v. Vandivner" on Justia Law

The Pennsylvania Supreme Court affirmed the death sentence for Richard Poplawski, convicted in 2011 of killing three Pittsburgh police officers. The officers were killed on April 4, 2009, when they responded to Poplawski's home for a domestic dispute with his mother. Poplawski, armed with multiple weapons, thousands of rounds of ammunition and body armor launched a gunfight with the city that lasted for hours. "The record shows that the jury balanced three aggravating circumstances against two statutory mitigating circumstances and determined that the aggravating circumstances outweighed the mitigating circumstances. Therefore, there exists no ground to vacate the sentence." View "Pennsylvania v. Poplawski" on Justia Law

Appellant Lenwood Mason's convictions arose from the June 1994, stabbing death of Iona Jeffries, for which he received the death penalty. His first Post-Conviction Relief Act petition was dismissed, and he appealed. Appellant contended that the cumulative effect of errors committed by the trial court and trial counsel’s ineffectiveness prevented the jury from hearing important evidence relevant to making its guilt phase and sentencing determinations. He raised eleven claims of error on appeal to the Supreme Court. With respect to issues one through six, and eight through eleven, the Supreme Court affirmed the PCRA court. In issue seven, Appellant's PCRA petition was pending when the U.S. Supreme Court decided "Atkins v. Virginia," (536 U.S. 304 (2002)). With respect to issue seven, Appellant argued that under Atkins, he was ineligible for the death penalty, and that the PCRA court erred in permitting Appellant acting pro se (over trial counsel's objection), to "waive" this claim. The Supreme Court found that, "where confronted with neither a basic, fundamental decision concerning Appellant’s PCRA challenge nor disagreement between counsel and Appellant with respect to the overarching objectives of the challenge, the PCRA court erred in ruling that counsels’ authority to seek an Atkins hearing was subject to Appellant’s veto. Furthermore, by acting directly on Appellant’s pro se letter moving for the court to accept his waiver of the counseled Atkins claim, the PCRA court impermissibly invited hybridized representation." The Supreme Court reversed on issue seven and remanded this case for further proceedings. View "Pennsylvania v. Mason" on Justia Law

In 2011, Heather Forsythe and Appellant Patrick Haney presented at Ruby Memorial Hospital in Morgantown, West Virginia with Forsythe’s four-year-old son, Trenton Lewis St. Clair. When Trenton arrived, he had neither a pulse nor signs of life. Forsythe and Appellant told emergency personnel that Trenton had fallen down a flight of stairs. Attempts to resuscitate the boy were unsuccessful, and he was pronounced dead shortly after arriving at the hospital. An examining physician's testimony at trial stated that it was “immediately evident that the child had been beaten. He was covered in bruises. There was blood around his mouth.” Forsythe gave a written statement to police explaining that she had observed Appellant physically abusing Trenton. Appellant would later be charged with first-degree murder and child endangerment. He ultimately received the death penalty for these crimes. His appeal to the Pennsylvania Supreme Court was automatic. After review, the Court concluded all of appellant's claimed of error at trial were meritless, and it affirmed his conviction and sentence. View "Pennsylvania v. Haney" on Justia Law

The Supreme Court granted certiorari review in this matter to address divergent decisions in the lower courts pertaining to the statutory scheme governing chemical testing of persons suspected of DUI and related traffic offenses. The Commonwealth Court has consistently construed the “Implied Consent Law” at 75 Pa.C.S. 1547 to require a motorist to assent unequivocally to an official request to take whichever statutorily-prescribed chemical test police select "on pain of" automatic license suspension, whereas the Superior Court has determined a motorist’s compliance with the law if he responds to the official request by asking to take a reasonably practicable, prescribed test of his choosing. The issue presented by the lower court analyses for the Supreme Court's review was, specifically, whether a motorist who requests an alternative test to the officer’s preferred test exercises a statutory right or, instead, refuses to submit to chemical testing in violation of the Implied Consent Law so as to incur suspension of his operating privileges. The Supreme Court found no right to alternative chemical testing in Section 1547. In this case, Appellant's request for alternative chemical testing instead of the test offered by the officer at the moment of his arrest constituted a refusal under the Implied Consent law, and the Commonwealth Court was correct in its analysis appellant's DUI conviction under the Law. View "Nardone v. Dept of Transportation" on Justia Law

Appellant Wayne Smith was given a death sentence for his role in the 1994 strangulation of Eileen Jones. Appellant raised several alleged errors by the trial court that warranted reversal of the death sentence and for a new trial. Finding no reversible error, the Supreme Court affirmed appellant's judgment of sentence. View "Pennsylvania v. Smith" on Justia Law