Justia Constitutional Law Opinion Summaries

An equally divided en banc panel of the Superior Court resulted in affirmance of appellant Jacob Christine's judgment of sentence for aggravated assault, and recklessly endangering another person. Appellant was alleged to have slashed a fellow inmate's throat. Corrections officer searched appellant's cell and found a shank. Appellant filed a motion in limine to exclude the shank from evidence, arguing it was irrelevant and would cause undue prejudice by confusing the jury, because the Commonwealth agreed the shank was not used in the attack. The trial court ruled the shank admissible under multiple theories. The divided Superior Court held that the shank was properly admitted, but that the trial court erred in refusing to allow appellant to question the victim of the attack about his own conviction for simple assault. Appellant appealed admission of the shank. Finding no reversible error in the trial court's judgment, the Supreme Court affirmed. View "Pennsylvania v. Christine" on Justia Law

On April 6, 2011, Shaun Warrick appeared in the Philadelphia Municipal Court for his preliminary hearing on two homicide charges. Appellees were relatives of the victims, and were seated in the courtroom gallery. Before testimony began, Warrick advised the court his mother had retained private counsel for him and requested a continuance. At the court’s request, his mother, escorted by court officer Richard Brandt, came forward to testify. Appellees thereupon verbally and physically assailed Ms. Warrick, and a general melee erupted in the courtroom. Warrick tried to defend his mother, which led to an expanded struggle that required deputy sheriffs and police reinforcements from outside the courtroom to restore order. The courtroom was locked down for three hours. When court reconvened, the trial court did make an “initial finding” of direct criminal contempt but deferred “final determination as to what the sentence should be” until appellees could meet with counsel. Appellees returned to court and sought to present their own witnesses and cross-examine other witnesses. The court denied the requests, finding that appellees were not entitled to call or cross-examine witnesses, particularly as the contemptuous acts took place “in the presence of the [c]ourt.” Appellees appealed, and the three cases were consolidated. Because the Superior Court erroneously determined the summary-contempt proceedings were improper, it also erred in concluding appellees “should have been permitted to cross-examine the court crier, and to present their own witnesses, in an adversary hearing with full due process protections.” The Supreme Court found the trial court appropriately conducted summary proceedings and appellees were sufficiently represented by counsel prior to sentencing. View "Pennsylvania v. Moody" on Justia Law

On January 13, 2015, as his term was ending, out-going Governor Tom Corbett appointed appellee Erik Arneson as the Executive Director of the Office of Open Records (OOR) for a term of six years, with an optional reappointment for an additional six years. On January 20, 2015, the first day of Governor Wolf’s term, he terminated Appellee’s employment. Appellee filed a complaint for mandamus and declaratory relief in the Commonwealth Court, arguing that Governor Wolf’s termination of his employment violated the Pennsylvania Constitution and the Right to Know Law (RTKL). The Commonwealth Court accepted this argument and reinstated Appellee. The Governor appealed to the Pennsylvania Supreme Court. The Supreme Court, after review, adopted and supplemented the Commonwealth Court’s opinion, and affirmed. View "Arneson v. Wolf" on Justia Law

The issue the Supreme Court addressed in these consolidated appeals centered on the extent of the public’s statutory right of access to discrete information about the implementation of the Medical Assistance Program. In 2011, James Eiseman, Jr. and the Public Interest Law Center of Philadelphia (“Requesters”) tendered requests to the Department of Public Welfare (DPW) seeking records revealing, among other things, the rates that DPW paid to managed care organizations (MCOs) for dental services in the Southeast Zone (the “Capitation Rates”), and the amounts paid by MCOs to provide dental services (the “MCO Rates”). These were submitted per the Right-to-Know Law (RTKL). DPW denied the requests. Pertinent to the Supreme Court’s review of this case, with regard to the MCO Rates, the Department indicated that it had been informed by each of the MCOs that the rates were “trade secrets and/or confidential proprietary information” protected against disclosure. The Department did not deny that it possessed pertinent records; rather, it related that the MCOs had instructed that “DPW is not to disclose” the rates. The Office of Open Records (OOR), however, issued a final determination granting the relevant records requests. Initially, an appeals officer observed that records in the possession of a Commonwealth agency were presumed to be public, unless they qualified for an exemption under the RTKL or other law or are protected by a privilege, judicial order, or decree. In a divided opinion, the Commonwealth Court sustained the portion of the OOR’s determination concerning Capitation Rates, as the members of an en banc panel unanimously agreed that contracts between DPW and the MCOs were financial records under the Law. In the absence of a legislative evaluation, the Supreme Court could not conclude that records which must be submitted to a government agency for approval, were not records “dealing with” the agency’s monetary disbursements and services acquisitions. "[I]f the General Assembly wished for dissemination to be withheld, it would have been a straightforward matter to provide for redaction of trade-secrets information in Section 708(c) of the Law, as was done in relation to eight of the other openness exceptions which are otherwise withheld from financial records." The Court focused upon the conclusion that records which were required to be submitted to and approved by DPW, and which reflected the central means of implementing a core departmental function, were records “dealing with” DPW’s disbursement of public monies and its responsibility to afford access to healthcare services in furtherance of the public interest. The order of the Commonwealth Court holding to the contrary was reversed relative to the MCO Rates, and the matter was remanded for further proceedings. View "Dept. of Public Welfare v. Eiseman" on Justia Law