Justia Constitutional Law Opinion Summaries

Appellant Paul Taylor appealed the denial of his fifth petition for post-conviction relief. In 1991, Taylor brutally murdered his wife, two of his minor children, his mother-in-law, and his mother-in-law’s minor son. Taylor pled guilty to five counts of criminal homicide generally. Following a degree-of-guilt hearing, the trial court convicted Taylor of first-degree murder on all five counts. The matter proceeded to a penalty phase hearing, following which the trial court determined that the imposition of the death penalty was appropriate for four of Taylor’s murder convictions and that a penalty of life imprisonment was appropriate for the remaining murder conviction. The trial court formally imposed Taylor’s sentences on January 23, 1992. Petitioner premised his fourth PCRA petition upon the well-publicized scandal involving the exchange of inappropriate emails between employees of the OAG and members of the judiciary, including former Justices Eakin and McCaffery. Petitioner alleged that emails exchanged during the pendency of "Taylor IV" reflected partiality on the part of the Pennsylvania Supreme Court in disposing of his appeal, in violation of Taylor’s due process rights. The PCRA court dismissed Taylor’s fourth petition, concluding that the PCRA court lacked the authority to grant the relief that Taylor sought. Taylor then appealed. On November 6, 2019, with its participating members being equally divided on the matter, the Pennsylvania Supreme Court affirmed the PCRA court’s order by operation of law. In his fifth PCRA petition, Appellant reasserted his due process claim premised upon the alleged partiality of the Supreme Court in Taylor IV arising out of the email scandal, as well as a request for a new appeal in that matter nunc pro tunc. The Supreme Court agreed with the conclusion of the PCRA court that Appellant untimely filed his fifth petition, therefore denial was affirmed. View "Pennsylvania v. Taylor" on Justia Law

Charlestown Township, Chester County, Pennsylvania, enacted a zoning ordinance that permitted outdoor billboards in a particular district. A statewide regulation concerning roadside billboards promulgated by the Pennsylvania Department of Transportation (“PennDOT”) had the practical effect of barring that use. Charlestown Outdoor, LLC, (“Outdoor”) sought nonetheless to erect a billboard on property it leased in that zoning district. In pursuit of that objective, Outdoor filed a substantive-validity challenge to Charlestown Township’s ordinance, asserting that it was de facto exclusionary. The Pennsylvania Supreme Court found it wasn't the zoning ordinance, but rather the statewide regulation, that precluded the proposed use. Accordingly, the Supreme Court held that the challenged zoning ordinance was not de facto exclusionary. It therefore affirmed the Commonwealth Court’s rejection of Outdoor’s validity challenge. View "In Re Charlestown Outdoor, LLC" on Justia Law

Appellant Albert Reid was convicted by jury on two counts of first-degree murder for the killings of his estranged wife, Carla Reid, and her fourteen-year-old daughter, D.M. He received two death sentences, and the Pennsylvania Supreme Court affirmed the judgment of sentence. Appellant subsequently filed a petition pursuant to the Post Conviction Relief Act (“PCRA”). The PCRA court denied the petition, and Appellant appealed to the Supreme Court, which affirmed in part the PCRA court’s order but remanded, while retaining jurisdiction, directing the PCRA court to provide a supplemental opinion addressing: why it denied relief on the whether appellant was incompetent to proceed to trial and represent himself; and whether prior counsel was ineffective for failing to investigate and effectively this issue before trial and for failing to raise it on appeal. Upon return from the PCRA court to the Supreme Court, the Supreme Court found the PCRA court erred in the manner in which it assessed Appellant’s claim that he was incompetent to stand trial, as the court’s reasoning, inter alia, failed to account for new, post-conviction evidence that potentially demonstrated that Appellant was incompetent to stand trial. Accordingly, the Court vacated in part the PCRA court’s order and remanded for further proceedings. View "Pennsylvania v. Reid" on Justia Law

The Pennsylvania Supreme Court granted discretionary review to consider whether Pennsylvania Rule of Criminal Procedure 706(C) required a trial court to consider a defendant’s ability to pay prior to imposing mandatory court costs at sentencing. In 2015, appellant Alexis Lopez entered a negotiated guilty plea to possession with intent to deliver a controlled substance. The trial court sentenced him to eleven and one-half to twenty-three months’ imprisonment, followed by three years’ probation. Six months later, the trial court granted Lopez’s motion for early release on parole. Thereafter, Lopez violated the terms of his supervision three times. Prior to resentencing for his third violation, Lopez filed a “Motion for Ability-to-Pay Hearing at Sentencing to Waive Costs.” His motion contended “Pennsylvania statutes and the Rules of Criminal Procedure require that this [c]ourt consider [his] ability to pay and waive court costs due to his indigence and the burden the costs would impose on him.” The Supreme Court found that Rule 706(C) did not have a requirement as Lopez suggested, and affirmed the Superior Court. View "Pennsylvania v. Lopez" on Justia Law

The Pennsylvania Environmental Defense Foundation (“PEDF”) challenged for the third time, the use of proceeds from oil and gas leasing on the Commonwealth’s forest and park lands as violative of Article I, Section 27 of the Pennsylvania Constitution, also known as the Environmental Rights Amendment. (“Section 27” or “ERA”). In previous trips before the Pennsylvania Supreme Court, PEDF challenged several 2009-2025 budgetary provisions enacted challenging the use of proceeds from oil and gas leasing on the Commonwealth’s forest and park lands as violative of Article I, Section 27 of the Pennsylvania Constitution, also known as the Environmental Rights Amendment. (“Section 27” or “ERA”). In the first two cases, PEDF challenged several 2009-2015 budgetary provisions enacted in the wake of dramatic increases in oil and gas revenue resulting from Marcellus Shale exploration in Pennsylvania. Applying trust principles, the Pennsylvania Supreme Court held that the budgetary provisions violated Section 27 by utilizing the oil and gas revenue for non-trust purposes via transfers to the General Fund. PEDF v. Commonwealth, 161 A.3d 911 (Pa. 2017) (“PEDF II”); PEDF v. Commonwealth, 255 A.3d 289 (Pa. 2021) (“PEDF V”). The underlying case here was one for a declaratory judgment, and named the Commonwealth and Governor as parties. Here, PEDF raised numerous constitutional challenges to provisions of the General Appropriations Act of 2017 and 2018, as well as the 2017 Fiscal Code amendments, all of which were enacted after the Supreme Court’s decision in PEDF II. After review , the Supreme Court affirmed the Commonwealth Court, whilst rejecting that court;s analysis derived from PEDF III. View "PA Enviro Defense Fdn, Aplt. v. Commonwealth" on Justia Law

The Pennsylvania Supreme Court considered a question of whether the General Assembly overstepped its constitutional authority by enacting legislation that allowed for universal mail-in voting. Among other things, "Act 77" effected major amendments to the Pennsylvania Election Code, including universal, state-wide mail-in voting. On November 21, 2020, eight petitioners – including a Republican congressman and Republican candidates for the United States House of Representatives and the Pennsylvania House of Representatives – filed a petition for review with the Commonwealth Court seeking to halt the certification of the 2020 General Election, and including a facial challenge to the portions of Act 77 that established universal mail-in voting. The Supreme Court exercised extraordinary jurisdiction over the matter, and found a “complete failure to act with due diligence in commencing [the] facial constitutional challenge, which was ascertainable upon Act 77’s enactment[,]” as the petitioners waited until the ballots from the General Election were in the process of being tallied, and the results were becoming apparent, to raise their claim. Thus, the Court found the claim barred by the doctrine of laches. The Court found no restriction in the Pennsylvania Constitution on the General Assembly's ability to create universal mail-in voting. View "McLinko v. Penna. Dept. of State, et al." on Justia Law

On July 5, 2014, at around 4:42 p.m., Appellee Akim Jones-Williams drove his car at approximately two miles per hour across train tracks. An approaching train collided with the car and pushed it nearly one-quarter mile before it stopped. Upon arriving at the scene, emergency personnel found Appellee outside the vehicle. Appellee’s fiance, Cori Sisti, and their daughter, S.J., were still inside the car. Medics declared Sisti dead at the scene, but transported Appellee and S.J. to York Hospital for medical treatment. Several individuals told the investigating lieutenant that they smelled burnt marijuana coming from Appellee and the car. Therefore, at approximately 6:00 p.m., the lieutenant asked a sergeant to interview Appellee at the hospital and obtain a “legal blood draw.” When the sergeant arrived at the hospital, Appellee was restrained in a hospital bed fading in and out of consciousness and unable to respond to basic questions. As such, the sergeant could not communicate to Appellee the consent of the form. Nevertheless, the sergeant later learned that hospital personnel drew Appellee’s blood at 5:56 p.m. The record did not establish why that blood was drawn, but it is clear that it was drawn prior to the sergeant's arrival. The sergeant completed paperwork requesting the hospital's lab to transfer Appellee's blood sample to a police lab for testing for controlled substances or alcohol. The resulting toxicology report revealed that Appellee’s blood contained Delta-9 THC, the active ingredient in marijuana. Appellee was arrested in April 2015, and ultimately convicted of homicide by vehicle while driving under the influence; homicide by vehicle; endangering the welfare of a child (“EWOC”); recklessly endangering another person (“REAP”); and related charges. Appellee filed an omnibus pre-trial motion, in which he moved to suppress the blood test results. He argued that police lacked probable cause that he was driving under the influence, that his blood was seized without a warrant and without satisfying the exigency exception, and that 75 Pa.C.S. § 3755 did not justify the seizure in the absence of exigent circumstances. The Pennsylvania Supreme Court concurred with the superior court that evidence from the blood sample should have been suppressed at trial. The matter was remanded for a new trial. View "Pennsylvania v. Jones-Williams" on Justia Law

This matter began with a challenge to the nomination petition of Robert Jordan, a candidate for the Republican Party’s nomination for the office of State Representative of the 165th Legislative District. Objector Fred Runge sought to remove Jordan from the ballot for the May 17, 2022 primary election on the ground that Jordan had moved into the district less than a year before the November 8 general election and therefore could not satisfy the residency requirements set forth in Article II, Section 5 of the Pennsylvania Constitution. The Commonwealth Court found Objector’s claim non-justiciable and dismissed his challenge for lack of subject matter jurisdiction. Given the need to resolve the appeal expeditiously to provide notice to the parties and election administrators, the Pennsylvania Supreme Court reversed the lower court’s decision in a per curiam Order dated April 19, 2022. The Court also directed the Secretary of the Commonwealth to remove Jordan's name from the ballot, finding that by a preponderance of the evidence, Jordan had not lived in the 165th Legislative District for at least one year preceding the general election. The Court published this opinion to explain its ruling. View "In Re: Nom. Robert Jordan" on Justia Law

Appellee Ryan Pownall, a former Philadelphia Police Officer was charged with killing David Jones by gunfire while on duty in his capacity as a police officer. Anticipating Pownall might pursue at trial a peace officer justification defense under 18 Pa.C.S. §508, the Philadelphia District Attorney’s Office (“DAO”), on behalf of the Commonwealth, filed a pretrial motion in limine seeking to preclude the trial court from using Suggested Standard Jury Instruction (Crim) §9.508B, which largely tracked Section 508. The DAO argued that since the justification statute supposedly violated the Fourth Amendment to the United States Constitution as interpreted by the Supreme Court in Tennessee v. Garner, 471 U.S. 1 (1985), so too must the standard jury instruction based on the statute. The trial court disagreed, concluding the DAO’s pretrial motion, by itself, was “insufficient to establish the unconstitutionality of Section 508[.]” Moreover, the court believed the DAO’s suggested remedy — proposing that it rewrite several disjunctive “ors” within the statute to conjunctive “ands” — was an “inappropriate” request for it to “judicially usurp the legislative function of the Pennsylvania General Assembly and rewrite Section 508 out of whole cloth.” For those reasons it denied the DAO’s request to certify the case for interlocutory appeal. When the DAO appealed anyway, the superior court quashed, reasoning the trial court’s order was not collateral and did not substantially handicap or terminate the DAO’s prosecution. The Pennsylvania Supreme Court granted review to determine whether the superior court erred in quashing the appeal. Because the Supreme Court concluded it did not, the judgment was affirmed. View "Pennsylvania v. Pownall" on Justia Law

Appellant Mark Prinkey caimed his sentence resulted from a prosecutor’s unconstitutionally vindictive decision to pursue a mandatory minimum term of years. Proceeding from the general principle that a sentence was unlawful if the sentencing court lacks the legal authority to impose that sanction, Pennyslvania law recognized four broad types of legality challenges. The issue this appeal presented for the Pennsylvania Supreme Court’s review was whether a particular type of claim constituted a challenge to the legality of the sentence, such that it was cognizable under the Post-Conviction Relief Act (PCRA): (1) a claim that a sentence was imposed pursuant to a facially unconstitutional sentencing statute; (2) an assertion that statutory preconditions to the court’s sentencing authority were not present; (3) a challenge alleging a violation or nonfulfillment of a substantive, constitutional restriction upon the court’s authority to impose the sentence; and (4) an argument that the statutory support for the conviction is void ab initio. In this case, the Court held that a challenge to a sentence as presumptively vindictive fell within the third category of legality challenges and, thus, was cognizable under the PCRA. View "Pennsylvania v. Prinkey" on Justia Law