State Supreme Court Data Tracker
Use this data to spot trends, anticipate what’s next, and supercharge your advocacy.
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Commonwealth v. Knight, 241 A.3d 620 (Pa. 2020)
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Pennsylvania | 2020 | Criminal Justice, Death Penalty |
State:
Pennsylvania
Year:
2020
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Supreme Court held that the Defendant waived his appellate argument alleging the death penalty in Pennsylvania constituted cruel punishment and should be abolished. The Supreme Court reasoned that Defendant's brief was devoid of original argument regarding the constitutionality of Pennsylvania's death penalty statute, and instead consisted of a near verbatim reproduction of the argument of the county district attorney's office set forth in its response to petitions in two unrelated cases, which the Supreme Court denied. Defendant failed to establish that he was entitled to an Atkins jury instruction, in prosecution for first degree murder. (In Atkins, the U.S. Supreme Court held that the Eighth Amendment prohibits the imposition of death penalty upon individuals with intellectual disabilities. Atkins v. Virginia, 122 S.Ct. 2242 (2002)). The Supreme Court held that Defendant failed to present evidence of a test demonstrating that his IQ was in the range of 65 to 75 prior to the age of 18. The Supreme Court also noted that Defendant's own experts conceded that his IQ score did not meet the criteria for a determination that Defendant was intellectually disabled under Atkins. The Supreme Court held that in capital cases where a jury is empaneled only for the penalty phase of trial, photographs have essential evidentiary value if they help inform the jury about the history and natural development of the facts of the case, or if they potentially rebut mitigation evidence. The Supreme Court reasoned in this case that the trial court's decision to allow four color photographs of murder victim to be in the jury room during deliberations was not an abuse of discretion. The Supreme Court stated that the victim was subjected to a lengthy period of torture before she was killed, the photographs demonstrated the restraint and humiliation that was inflicted upon her in that regard, and the photographs illustrated the steps that Defendant and Co-Defendants took to hide the victim's body.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The Supreme Court held that the Defendant waived his appellate argument alleging the death penalty in Pennsylvania constituted cruel punishment and should be abolished. The Supreme Court reasoned that Defendant's brief was devoid of original argument regarding the constitutionality of Pennsylvania's death penalty statute, and instead consisted of a near verbatim reproduction of the argument of the county district attorney's office set forth in its response to petitions in two unrelated cases, which the Supreme Court denied. Defendant failed to establish that he was entitled to an Atkins jury instruction, in prosecution for first degree murder. (In Atkins, the U.S. Supreme Court held that the Eighth Amendment prohibits the imposition of death penalty upon individuals with intellectual disabilities. Atkins v. Virginia, 122 S.Ct. 2242 (2002)). The Supreme Court held that Defendant failed to present evidence of a test demonstrating that his IQ was in the range of 65 to 75 prior to the age of 18. The Supreme Court also noted that Defendant's own experts conceded that his IQ score did not meet the criteria for a determination that Defendant was intellectually disabled under Atkins. The Supreme Court held that in capital cases where a jury is empaneled only for the penalty phase of trial, photographs have essential evidentiary value if they help inform the jury about the history and natural development of the facts of the case, or if they potentially rebut mitigation evidence. The Supreme Court reasoned in this case that the trial court's decision to allow four color photographs of murder victim to be in the jury room during deliberations was not an abuse of discretion. The Supreme Court stated that the victim was subjected to a lengthy period of torture before she was killed, the photographs demonstrated the restraint and humiliation that was inflicted upon her in that regard, and the photographs illustrated the steps that Defendant and Co-Defendants took to hide the victim's body.
Link to Opinion
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Commonwealth v. Johnson, 289 A.3d 959 (Pa. 2023)
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Pennsylvania | 2023 | Criminal Justice, Death Penalty |
State:
Pennsylvania
Year:
2023
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingAny deficiency in trial counsel's interactions with retained mental health expert as part of investigation of penalty-phase mitigation evidence did not prejudice defendant under Strickland in capital murder trial arising from beating death of two-year-old victim, where victim's murder was brutal and shocking, and there was overwhelming record support for death sentence, including 150 injuries inflicted over approximately 45 to 60 minutes in the horrifying torture-murder of a child. The Strickland test is used to demonstrate ineffective counsel, which defendant must show (1) that the trial lawyer's performance fell below an objective standard of reasonableness; and (2) a reasonable probability that but for counsel's unprofessional errors, the result of the proceeding would have been different. Strickland v. Washington, 466 U.S. 668 (1984). The Supreme Court found trial counsel were not deficient under Strickland in not retaining a mitigation specialist as part of their investigation of penalty-phase mitigation evidence in capital murder prosecution, where prevailing local norms did not involve use of mitigation specialists, and counsel employed an investigator and mental health expert to supplement their investigative efforts. The Supreme Court also found that trial counsel's investigation of penalty-phase mitigation evidence in capital murder prosecution was far more than perfunctory, and thus was constitutionally reasonable under Strickland, where counsel engaged in in-person meeting with Defendant's mother and sisters, counsel prepared mother and sister to testify at penalty hearing, counsel engaged in eight personal meetings with Defendant in prison, counsel attended Defendant's mental health evaluation by Commonwealth's expert, counsel retained an investigator, a mental health expert, and a forensic pathologist, counsel reviewed various reports, counsel engaged in numbers meetings and phone calls with witnesses, and counsel drafted memoranda about meetings and an opinion of defense forensic pathologist.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Any deficiency in trial counsel's interactions with retained mental health expert as part of investigation of penalty-phase mitigation evidence did not prejudice defendant under Strickland in capital murder trial arising from beating death of two-year-old victim, where victim's murder was brutal and shocking, and there was overwhelming record support for death sentence, including 150 injuries inflicted over approximately 45 to 60 minutes in the horrifying torture-murder of a child. The Strickland test is used to demonstrate ineffective counsel, which defendant must show (1) that the trial lawyer's performance fell below an objective standard of reasonableness; and (2) a reasonable probability that but for counsel's unprofessional errors, the result of the proceeding would have been different. Strickland v. Washington, 466 U.S. 668 (1984). The Supreme Court found trial counsel were not deficient under Strickland in not retaining a mitigation specialist as part of their investigation of penalty-phase mitigation evidence in capital murder prosecution, where prevailing local norms did not involve use of mitigation specialists, and counsel employed an investigator and mental health expert to supplement their investigative efforts. The Supreme Court also found that trial counsel's investigation of penalty-phase mitigation evidence in capital murder prosecution was far more than perfunctory, and thus was constitutionally reasonable under Strickland, where counsel engaged in in-person meeting with Defendant's mother and sisters, counsel prepared mother and sister to testify at penalty hearing, counsel engaged in eight personal meetings with Defendant in prison, counsel attended Defendant's mental health evaluation by Commonwealth's expert, counsel retained an investigator, a mental health expert, and a forensic pathologist, counsel reviewed various reports, counsel engaged in numbers meetings and phone calls with witnesses, and counsel drafted memoranda about meetings and an opinion of defense forensic pathologist.
Link to Opinion
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Commonwealth v. Johnson, 139 A.3d 1257 (Pa. 2016)
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Pennsylvania | 2016 | Criminal Justice, Access to Justice, Death Penalty |
State:
Pennsylvania
Year:
2016
Topics:
Criminal Justice, Access to Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPetitioner filed post-conviction request based on a number of grounds, including the alleged discriminatory intent in the prosecutor's use of peremptory strikes. The Supreme Court held that the prosecutor's use of peremptory strikes in the Defendant's case failed to demonstrate purposeful discrimination in violation of Batson v. Kentucky, 476 U.S. 79 (1986) (holding while a defendant is not entitled to have a jury completely or partially composed of people of his own race, the state is not permitted to use its peremptory challenges to automatically exclude potential members of the jury because of their race) even though the prosecutor rejected a higher percentage of African-American potential jurors than non-African-American potential jurors. The Supreme Court found that the jury, which was composed of seven African-Americans and one Hispanic-American after the prosecutor had six peremptory challenges that went unused was an important factor.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Petitioner filed post-conviction request based on a number of grounds, including the alleged discriminatory intent in the prosecutor's use of peremptory strikes. The Supreme Court held that the prosecutor's use of peremptory strikes in the Defendant's case failed to demonstrate purposeful discrimination in violation of Batson v. Kentucky, 476 U.S. 79 (1986) (holding while a defendant is not entitled to have a jury completely or partially composed of people of his own race, the state is not permitted to use its peremptory challenges to automatically exclude potential members of the jury because of their race) even though the prosecutor rejected a higher percentage of African-American potential jurors than non-African-American potential jurors. The Supreme Court found that the jury, which was composed of seven African-Americans and one Hispanic-American after the prosecutor had six peremptory challenges that went unused was an important factor.
Link to Opinion
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Commonwealth v. Johnson, 107 A.3d 52 (Pa. 2014)
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Pennsylvania | 2014 | Criminal Justice, Death Penalty |
State:
Pennsylvania
Year:
2014
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIn penalty phase of first-degree murder trial, admission of Defendant's seven-year-old prior conviction for endangering the welfare of a child, who was toddler at time of endangerment and eight years old at time of murder trial, was relevant response to Defendant's evidence for the purpose of establishing applicability of a broad mitigator in Pennsylvania statute that encompasses a wide range of evidence, including life history, mental health statutes, physical or psychological abuse, neglect and substance abuse. The Supreme Court concluded the evidence was offered to show Defendant as a loving and caring father throughout child's life and the Defendant's presentation of mitigation evidence was not confined to his current relationship with child but extended well back to a time proximate to his prior conviction, including testimony referring to his parenting through the years and describing child as having been “daddy's girl since the day she was born.” Further, the Supreme Court concluded that Defendant, who was convicted of first-degree murder of wildlife conservation officer and sentenced to death, waived on appeal his arguments challenging jury instruction that same standard applicable in guilt-phase determination of whether intoxication diminished his capacity to form the specific intent to kill officer also applied in the penalty-phase determination of whether his voluntary intoxication served as a mitigating circumstance, where defense counsel declined the trial court's invitation to clarify his ambiguous objection to the jury instruction, leaving the precise basis for his objection indeterminable. The Supreme Court also held testimony from Defendant's friends and family regarding defendant's purported statements of remorse for killing wildlife conservation officer was not admissible in penalty phase of first-degree murder trial under state-of-mind exceptions to the hearsay rule for present sense impression and then-existing mental, emotional, or physical condition, absent additional measures of trustworthiness.
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Justice Vote Breakdown
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Summary of Case Context & Holding
In penalty phase of first-degree murder trial, admission of Defendant's seven-year-old prior conviction for endangering the welfare of a child, who was toddler at time of endangerment and eight years old at time of murder trial, was relevant response to Defendant's evidence for the purpose of establishing applicability of a broad mitigator in Pennsylvania statute that encompasses a wide range of evidence, including life history, mental health statutes, physical or psychological abuse, neglect and substance abuse. The Supreme Court concluded the evidence was offered to show Defendant as a loving and caring father throughout child's life and the Defendant's presentation of mitigation evidence was not confined to his current relationship with child but extended well back to a time proximate to his prior conviction, including testimony referring to his parenting through the years and describing child as having been “daddy's girl since the day she was born.” Further, the Supreme Court concluded that Defendant, who was convicted of first-degree murder of wildlife conservation officer and sentenced to death, waived on appeal his arguments challenging jury instruction that same standard applicable in guilt-phase determination of whether intoxication diminished his capacity to form the specific intent to kill officer also applied in the penalty-phase determination of whether his voluntary intoxication served as a mitigating circumstance, where defense counsel declined the trial court's invitation to clarify his ambiguous objection to the jury instruction, leaving the precise basis for his objection indeterminable. The Supreme Court also held testimony from Defendant's friends and family regarding defendant's purported statements of remorse for killing wildlife conservation officer was not admissible in penalty phase of first-degree murder trial under state-of-mind exceptions to the hearsay rule for present sense impression and then-existing mental, emotional, or physical condition, absent additional measures of trustworthiness.
Link to Opinion
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Commonwealth v. Jacoby, 170 A.3d 1065 (Pa. 2017)
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Pennsylvania | 2017 | Criminal Justice, Death Penalty |
State:
Pennsylvania
Year:
2017
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant appealed death penalty, which Defendant argued was based on insufficient evidence. The Supreme Court held that the evidence was sufficient to support imposition of death sentence upon Defendant convicted of first-degree murder, burglary, tampering with physical evidence, and robbery, where the only aggravating factor that was submitted to the jury was that the Defendant committed a killing while in the perpetration of a felony. The Supreme Court reasoned that the Defendant's convictions for burglary and robbery were supported by proof beyond a reasonable doubt, and the death sentence was not the product of passion, prejudice, or any other arbitrary factor.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant appealed death penalty, which Defendant argued was based on insufficient evidence. The Supreme Court held that the evidence was sufficient to support imposition of death sentence upon Defendant convicted of first-degree murder, burglary, tampering with physical evidence, and robbery, where the only aggravating factor that was submitted to the jury was that the Defendant committed a killing while in the perpetration of a felony. The Supreme Court reasoned that the Defendant's convictions for burglary and robbery were supported by proof beyond a reasonable doubt, and the death sentence was not the product of passion, prejudice, or any other arbitrary factor.
Link to Opinion
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Commonwealth v. Housman, 226 A.3d 1249 (Pa. 2020)
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Pennsylvania | 2020 | Criminal Justice, Death Penalty |
State:
Pennsylvania
Year:
2020
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant appealed imposition of the death penalty claiming ineffective assistance of counsel. The Defendant argued that his penalty phase attorney did not pursue all potential mitigation strategies. The Supreme Court affirmed the Post-Conviction Relief Act grant of new penalty phase trial on the basis of ineffective assistance of counsel. The Supreme Court reasoned that an attorney has a duty in a capital case to pursue all statutory mitigators of which he is aware or reasonably should be aware, unless there is some reasonable ground not to pursue the circumstance, such as when it might open the door to harmful evidence. However, if counsel's investigation of a capital defendant's mitigation case is deemed unreasonable, the defendant is not entitled to relief on a claim of ineffective assistance of counsel unless the defendant demonstrates that prejudice resulted from counsel's conduct. In addressing claims that counsel was ineffective for failing to present mitigation evidence in a capital case, a court may not conflate the roles and professional obligations of experts and lawyers by demanding that counsel spot red flags when the mental health expert they hired failed to do so. The Supreme Court found in this case that Defendant's attorney did not meet these high standards.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant appealed imposition of the death penalty claiming ineffective assistance of counsel. The Defendant argued that his penalty phase attorney did not pursue all potential mitigation strategies. The Supreme Court affirmed the Post-Conviction Relief Act grant of new penalty phase trial on the basis of ineffective assistance of counsel. The Supreme Court reasoned that an attorney has a duty in a capital case to pursue all statutory mitigators of which he is aware or reasonably should be aware, unless there is some reasonable ground not to pursue the circumstance, such as when it might open the door to harmful evidence. However, if counsel's investigation of a capital defendant's mitigation case is deemed unreasonable, the defendant is not entitled to relief on a claim of ineffective assistance of counsel unless the defendant demonstrates that prejudice resulted from counsel's conduct. In addressing claims that counsel was ineffective for failing to present mitigation evidence in a capital case, a court may not conflate the roles and professional obligations of experts and lawyers by demanding that counsel spot red flags when the mental health expert they hired failed to do so. The Supreme Court found in this case that Defendant's attorney did not meet these high standards.
Link to Opinion
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Commonwealth v. Hitcho, 123 A.3d 731 (Pa. 2015)
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Pennsylvania | 2015 | Criminal Justice, Death Penalty |
State:
Pennsylvania
Year:
2015
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant appealed from a death sentence imposed after a conviction of first degree murder. The Defendant appealed arguing that the jury improperly weighed the three mitigating circumstances found to exist against the single aggravating circumstance. The PA Supreme Court previously held that there is no mechanism by which a sentence of death may be reversed by the Supreme Court on the basis of an improper weighing of aggravating and mitigating circumstances because the Court's authority to vacate a sentence is prescribed by statute, which requires the Court to affirm the sentence of death unless the sentence of death was the product of passion, prejudice or any other arbitrary factor or the evidence fails to support the finding of at least one aggravating circumstance. Commonwealth v. Reyes, 963 A.2d 436 (2009). The Supreme Court held that the fact that the jury in a capital murder case concluded the aggravating circumstance outweighed any mitigating circumstances did not render its verdict the product of passion, prejudice or any other arbitrary factor.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant appealed from a death sentence imposed after a conviction of first degree murder. The Defendant appealed arguing that the jury improperly weighed the three mitigating circumstances found to exist against the single aggravating circumstance. The PA Supreme Court previously held that there is no mechanism by which a sentence of death may be reversed by the Supreme Court on the basis of an improper weighing of aggravating and mitigating circumstances because the Court's authority to vacate a sentence is prescribed by statute, which requires the Court to affirm the sentence of death unless the sentence of death was the product of passion, prejudice or any other arbitrary factor or the evidence fails to support the finding of at least one aggravating circumstance. Commonwealth v. Reyes, 963 A.2d 436 (2009). The Supreme Court held that the fact that the jury in a capital murder case concluded the aggravating circumstance outweighed any mitigating circumstances did not render its verdict the product of passion, prejudice or any other arbitrary factor.
Link to Opinion
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Commonwealth v. Hannibal, 156 A.3d 197 (Pa. 2016)
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Pennsylvania | 2016 | Criminal Justice, Death Penalty |
State:
Pennsylvania
Year:
2016
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant appealed arguing ineffective counsel during the penalty phase for failing to challenge the evidence on grounds it violated the Eighth Amendment. Specifically, the Appellant claimed the sentencing determination was not reliable because the jury was free to consider his involvement in the murder, which the prosecutor commented upon in summation, as a non-statutory aggravating circumstance. The Supreme Court held that the Defendant was not denied reliable sentencing determination in violation of Eighth Amendment based on jury being free to consider Defendant's alleged involvement in killing a witness to underlying murder as non-statutory aggravating circumstance. The Supreme Court reasoned that even if prior testimony implicating Defendant's involvement in witness's killing was recanted, trial court properly instructed jury it could consider evidence of witness's killing only for limited purpose of showing Defendant's consciousness of guilt in underlying murder, and recantations, which involved admissions of lying under oath, would not have compelled different verdict.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant appealed arguing ineffective counsel during the penalty phase for failing to challenge the evidence on grounds it violated the Eighth Amendment. Specifically, the Appellant claimed the sentencing determination was not reliable because the jury was free to consider his involvement in the murder, which the prosecutor commented upon in summation, as a non-statutory aggravating circumstance. The Supreme Court held that the Defendant was not denied reliable sentencing determination in violation of Eighth Amendment based on jury being free to consider Defendant's alleged involvement in killing a witness to underlying murder as non-statutory aggravating circumstance. The Supreme Court reasoned that even if prior testimony implicating Defendant's involvement in witness's killing was recanted, trial court properly instructed jury it could consider evidence of witness's killing only for limited purpose of showing Defendant's consciousness of guilt in underlying murder, and recantations, which involved admissions of lying under oath, would not have compelled different verdict.
Link to Opinion
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Commonwealth v. Hale, 128 A.3d 781 (Pa. 2015)
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Pennsylvania | 2015 | Criminal Justice, Juvenile Justice |
State:
Pennsylvania
Year:
2015
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Appellee was convicted of a Section 6105 Pennsylvania Uniform Firearms Act offense, which prohibits individuals from possessing firearms if they have been convicted of certain crimes listed in the statute. Normally, a Section 6105 violation is considered a first-degree misdemeanor. However, if the Defendant was "convicted" of any felony offense listed in the statute, the offense grade is elevated to a second-degree felony. One of the enumerated offences specified in Pennsylvania Uniform Firearms Act is aggravated assault. As a juvenile, the Appellee was adjudicated delinquent of conduct which, if tried as an adult, would encompass aggravated assault. The Supreme Court held that juvenile adjudications are not "convictions" and cannot be substituted for convictions in such proceedings and affirmed the superior court's decision to vacate and remand for further proceedings.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The Appellee was convicted of a Section 6105 Pennsylvania Uniform Firearms Act offense, which prohibits individuals from possessing firearms if they have been convicted of certain crimes listed in the statute. Normally, a Section 6105 violation is considered a first-degree misdemeanor. However, if the Defendant was "convicted" of any felony offense listed in the statute, the offense grade is elevated to a second-degree felony. One of the enumerated offences specified in Pennsylvania Uniform Firearms Act is aggravated assault. As a juvenile, the Appellee was adjudicated delinquent of conduct which, if tried as an adult, would encompass aggravated assault. The Supreme Court held that juvenile adjudications are not "convictions" and cannot be substituted for convictions in such proceedings and affirmed the superior court's decision to vacate and remand for further proceedings.
Link to Opinion
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Commonwealth v. Hairston, 84 A.3d 657 (Pa. 2014)
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Pennsylvania | 2014 | Criminal Justice, Death Penalty |
State:
Pennsylvania
Year:
2014
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Defendant appealed a conviction after he was found guilty of murdering his wife and teenage son. The Defendant argued that his wife visiting him in jail was information that served as a mitigating factor in his post-trial appeal. The Supreme Court held, in part, that evidence showing that Defendant's wife visited him in jail following his arrest for the sexual assault of his step-daughter was not admissible for the purpose of establishing applicability of a broad mitigator in Pennsylvania statute that encompasses a wide range of evidence, including life history, mental health statutes, physical or psychological abuse, neglect and substance abuse. The Supreme Court reasoned that the information, in a first-degree murder prosecution in which the death sentence was sought, did not render any material fact about Defendant's character and the circumstances of his offense more or less probable, and the evidence was not relevant to rebut the Commonwealth's evidence of the statutory aggravating factor that Defendant had a “significant history of felony convictions involving the use or threat of violence to the person.”
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Justice Vote Breakdown
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Summary of Case Context & Holding
The Defendant appealed a conviction after he was found guilty of murdering his wife and teenage son. The Defendant argued that his wife visiting him in jail was information that served as a mitigating factor in his post-trial appeal. The Supreme Court held, in part, that evidence showing that Defendant's wife visited him in jail following his arrest for the sexual assault of his step-daughter was not admissible for the purpose of establishing applicability of a broad mitigator in Pennsylvania statute that encompasses a wide range of evidence, including life history, mental health statutes, physical or psychological abuse, neglect and substance abuse. The Supreme Court reasoned that the information, in a first-degree murder prosecution in which the death sentence was sought, did not render any material fact about Defendant's character and the circumstances of his offense more or less probable, and the evidence was not relevant to rebut the Commonwealth's evidence of the statutory aggravating factor that Defendant had a “significant history of felony convictions involving the use or threat of violence to the person.”
Link to Opinion
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Commonwealth v. Hairston, 249 A.3d 1046 (Pa. 2021)
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Pennsylvania | 2021 | Criminal Justice, Death Penalty |
State:
Pennsylvania
Year:
2021
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant who had been convicted of capital murder and sentenced to death filed a petition for postconviction relief based on the unconstitutionality of death penalty and the ineffective assistance of counsel that he allegedly received. The Supreme Court held that death penalty is a permissible punishment under the Eighth Amendment and is not unconstitutionally cruel and unusual in all cases. The Supreme Court also said that capital punishment is not a per se violation of the State Constitutional prohibition against “cruel punishments.” The Supreme Court described the evidence that the capital murder Defendant presented of the allegedly discriminatory nature in which death penalty was imposed was insufficient to support an as-applied challenge to constitutionality of his capital sentence. In addition, the Defendant argued that his counsel was ineffective because he did not object to statements made by the Commonwealth's expert. The Supreme Court held that even assuming that defense counsel performed deficiently in not objecting to statement made by the Commonwealth's psychiatry expert, Defendant failed to show that he was prejudiced by any such deficiency which is required to win an appeal.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant who had been convicted of capital murder and sentenced to death filed a petition for postconviction relief based on the unconstitutionality of death penalty and the ineffective assistance of counsel that he allegedly received. The Supreme Court held that death penalty is a permissible punishment under the Eighth Amendment and is not unconstitutionally cruel and unusual in all cases. The Supreme Court also said that capital punishment is not a per se violation of the State Constitutional prohibition against “cruel punishments.” The Supreme Court described the evidence that the capital murder Defendant presented of the allegedly discriminatory nature in which death penalty was imposed was insufficient to support an as-applied challenge to constitutionality of his capital sentence. In addition, the Defendant argued that his counsel was ineffective because he did not object to statements made by the Commonwealth's expert. The Supreme Court held that even assuming that defense counsel performed deficiently in not objecting to statement made by the Commonwealth's psychiatry expert, Defendant failed to show that he was prejudiced by any such deficiency which is required to win an appeal.
Link to Opinion
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Commonwealth v. Green, 291 A.3d 317 (Pa. 2023)
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Pennsylvania | 2023 | Criminal Justice, Juvenile Justice |
State:
Pennsylvania
Year:
2023
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingJuvenile was charged as an adult with second-degree murder and petitioned to decertify and transfer his case to juvenile court. The court of common pleas failed to issue its order within the time required by the Juvenile Act. As a result, despite an eventual order stating that the juvenile had met his burden of proof, his case was not transferred. The Supreme Court held that the decertification petition was correctly denied by operation of law because the statutory construction of the Juvenile Act left no ambiguity about deadlines.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Juvenile was charged as an adult with second-degree murder and petitioned to decertify and transfer his case to juvenile court. The court of common pleas failed to issue its order within the time required by the Juvenile Act. As a result, despite an eventual order stating that the juvenile had met his burden of proof, his case was not transferred. The Supreme Court held that the decertification petition was correctly denied by operation of law because the statutory construction of the Juvenile Act left no ambiguity about deadlines.
Link to Opinion
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Commonwealth v. Felder, 269 A.3d 1232 (Pa. 2022)
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Pennsylvania | 2022 | Criminal Justice, Juvenile Justice |
State:
Pennsylvania
Year:
2022
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was convicted as a juvenile of first-degree murder and aggravated assault for shooting two individuals during a basketball game when Defendant was seventeen-and-a-half years old and received a mandatory sentence of life without parole. Defendant was resentenced after Miller v. Alabama, 567 U.S. 460 (2012), (holding that mandatory life imprisonment without parole for those under the age of 18 at the time of their crimes violates the Eighth Amendment's prohibition on cruel and unusual punishments) to a discretionary sentence of 50 years to life. The Supreme Court concluded that Jones v. Mississippi, 593 U.S. 98 (2021) (which held that a finding of permanent incorrigibility was not required before imposing such a sentence on a juvenile murderer), was dispositive. Here, records showed that the sentencing court considered the Miller factors (such as a juvenile's chronological age with its characteristic features of immaturity, impulsivity, and failure to grasp risks and consequences, a juvenile's family and home environment, which they often cannot control, even in cases of extreme dysfunction, and the circumstances surrounding the offense, including the extent of the juvenile's involvement and the influence of familial and peer pressures) in its decision. The court thoroughly reviewed the parties’ presentence memoranda, psychological reports, school records, and victim impact statements. Additionally, the court heard testimony from the Defendant and his mother, and it carefully read a letter from his cousin. The court also took into account the arguments and evidentiary presentations presented during the resentencing hearing. The Supreme Court concluded that this comprehensive process was more than enough to meet the constitutional standard. The Supreme Court held that imposition of a term of years sentence which is effectively life without parole does not violate the 8th Amendment so long as the sentence is discretionary and considers the juvenile's youth.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was convicted as a juvenile of first-degree murder and aggravated assault for shooting two individuals during a basketball game when Defendant was seventeen-and-a-half years old and received a mandatory sentence of life without parole. Defendant was resentenced after Miller v. Alabama, 567 U.S. 460 (2012), (holding that mandatory life imprisonment without parole for those under the age of 18 at the time of their crimes violates the Eighth Amendment's prohibition on cruel and unusual punishments) to a discretionary sentence of 50 years to life. The Supreme Court concluded that Jones v. Mississippi, 593 U.S. 98 (2021) (which held that a finding of permanent incorrigibility was not required before imposing such a sentence on a juvenile murderer), was dispositive. Here, records showed that the sentencing court considered the Miller factors (such as a juvenile's chronological age with its characteristic features of immaturity, impulsivity, and failure to grasp risks and consequences, a juvenile's family and home environment, which they often cannot control, even in cases of extreme dysfunction, and the circumstances surrounding the offense, including the extent of the juvenile's involvement and the influence of familial and peer pressures) in its decision. The court thoroughly reviewed the parties’ presentence memoranda, psychological reports, school records, and victim impact statements. Additionally, the court heard testimony from the Defendant and his mother, and it carefully read a letter from his cousin. The court also took into account the arguments and evidentiary presentations presented during the resentencing hearing. The Supreme Court concluded that this comprehensive process was more than enough to meet the constitutional standard. The Supreme Court held that imposition of a term of years sentence which is effectively life without parole does not violate the 8th Amendment so long as the sentence is discretionary and considers the juvenile's youth.
Link to Opinion
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Commonwealth v. Eichinger, 108 A.3d 821 (Pa. 2014)
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Pennsylvania | 2014 | Criminal Justice, Death Penalty |
State:
Pennsylvania
Year:
2014
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDuring exhaustive colloquy in the lower court, the judge explained among other things, that waiver would result in Defendant being found guilty of four counts of first degree murder and that Defendant would be exposed to death penalty, and Defendant stated that he understood the rights he was waiving and declined to ask further questions. Defendant nevertheless challenged the waiver and the Supreme Court held that the Defendant validly waived his rights to jury trial and to contest evidence at guilt phase of capital murder trial. The Defendant also challenged the jury instruction for the penalty phase of his trial claiming the judge failed to appropriate explain the applicable standard. At the penalty phase of a capital murder trial, although in some sense there is a “presumption of life” arising from the fact that the prosecution is limited to specific aggravating circumstances which must be proven beyond a reasonable doubt, while the Defendant is permitted great latitude in demonstrating mitigating circumstances, and then by the lesser preponderance standard, a specific jury instruction containing the words “presumption of life” is not required. The Supreme Court held that an explanation of the deliberately disparate treatment of the aggravating and mitigating circumstances under the applicable standards of proof and a clear indication that life in prison is the sentence for capital murder unless the Commonwealth meets its high burden is sufficient to convey the fact that life is presumed.
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Justice Vote Breakdown
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Summary of Case Context & Holding
During exhaustive colloquy in the lower court, the judge explained among other things, that waiver would result in Defendant being found guilty of four counts of first degree murder and that Defendant would be exposed to death penalty, and Defendant stated that he understood the rights he was waiving and declined to ask further questions. Defendant nevertheless challenged the waiver and the Supreme Court held that the Defendant validly waived his rights to jury trial and to contest evidence at guilt phase of capital murder trial. The Defendant also challenged the jury instruction for the penalty phase of his trial claiming the judge failed to appropriate explain the applicable standard. At the penalty phase of a capital murder trial, although in some sense there is a “presumption of life” arising from the fact that the prosecution is limited to specific aggravating circumstances which must be proven beyond a reasonable doubt, while the Defendant is permitted great latitude in demonstrating mitigating circumstances, and then by the lesser preponderance standard, a specific jury instruction containing the words “presumption of life” is not required. The Supreme Court held that an explanation of the deliberately disparate treatment of the aggravating and mitigating circumstances under the applicable standards of proof and a clear indication that life in prison is the sentence for capital murder unless the Commonwealth meets its high burden is sufficient to convey the fact that life is presumed.
Link to Opinion
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Commonwealth v. Diamond, 83 A.3d 119 (Pa. 2013)
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Pennsylvania | 2013 | Criminal Justice, Death Penalty |
State:
Pennsylvania
Year:
2013
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIn a capital sentencing proceeding, sufficient evidence exists to support aggravating circumstance of creating a grave risk of harm to persons other than the murder victim only where there is a nexus connecting the other persons to the zone of danger created by the defendant's actions in killing the victim. In this case, the Defendant was convicted pursuant to guilty pleas of two counts of first degree murder. The Supreme Court held that the evidence supported finding, as an aggravating circumstance supporting imposition of death penalty, that Defendant knowingly created a grave risk of death to another person in addition to the victim of the offense. Specifically, at the time when Defendant shot two victims in a parking lot outside Defendant's former workplace, several bystanders were in immediate vicinity of the victims, and Defendant shot second victim from a distance of 29 yards, so as to place bystanders in danger.
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Justice Vote Breakdown
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Summary of Case Context & Holding
In a capital sentencing proceeding, sufficient evidence exists to support aggravating circumstance of creating a grave risk of harm to persons other than the murder victim only where there is a nexus connecting the other persons to the zone of danger created by the defendant's actions in killing the victim. In this case, the Defendant was convicted pursuant to guilty pleas of two counts of first degree murder. The Supreme Court held that the evidence supported finding, as an aggravating circumstance supporting imposition of death penalty, that Defendant knowingly created a grave risk of death to another person in addition to the victim of the offense. Specifically, at the time when Defendant shot two victims in a parking lot outside Defendant's former workplace, several bystanders were in immediate vicinity of the victims, and Defendant shot second victim from a distance of 29 yards, so as to place bystanders in danger.
Link to Opinion
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Commonwealth v. Davido, 106 A.3d 611 (Pa. 2014)
|
Pennsylvania | 2014 | Criminal Justice, Death Penalty |
State:
Pennsylvania
Year:
2014
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Supreme Court held that trial counsel's decision to request a competency examination of Defendant after the trial court's penalty phase colloquy had been conducted to determine if Defendant's waiver of his right to counsel and to present mitigation evidence was knowing and voluntary, rather than before the colloquy, did not constitute deficient performance, during murder prosecution because there was no evidence that if counsel had requested a competency examination earlier the request would have been granted. The Supreme Court also held that trial counsel's decision to decline from presenting penalty phase mitigation evidence related to gypsy culture and the effect of gypsy culture on Defendant's upbringing was a reasonable trial strategy, and therefore did not constitute ineffective assistance of counsel, during murder prosecution where Defendant continuously expressed a desire against presenting mitigating evidence, and counsel determined that the testimony as to the effect of gypsy culture on Defendant's upbringing would not be well received by jurors in county.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The Supreme Court held that trial counsel's decision to request a competency examination of Defendant after the trial court's penalty phase colloquy had been conducted to determine if Defendant's waiver of his right to counsel and to present mitigation evidence was knowing and voluntary, rather than before the colloquy, did not constitute deficient performance, during murder prosecution because there was no evidence that if counsel had requested a competency examination earlier the request would have been granted. The Supreme Court also held that trial counsel's decision to decline from presenting penalty phase mitigation evidence related to gypsy culture and the effect of gypsy culture on Defendant's upbringing was a reasonable trial strategy, and therefore did not constitute ineffective assistance of counsel, during murder prosecution where Defendant continuously expressed a desire against presenting mitigating evidence, and counsel determined that the testimony as to the effect of gypsy culture on Defendant's upbringing would not be well received by jurors in county.
Link to Opinion
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Commonwealth v. Daniels, 104 A.3d 267 (Pa. 2014)
|
Pennsylvania | 2014 | Criminal Justice, Death Penalty |
State:
Pennsylvania
Year:
2014
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Supreme Court found that the Strickland test (to demonstrate ineffective counsel, defendant must show (1) that the trial lawyer's performance fell below an objective standard of reasonableness and (2) a reasonable probability that but for counsel's unprofessional errors, the result of the proceeding would have been different. Strickland v. Washington, 466 U.S. 668 (1984)). Here, the Supreme Court held that the Defendant was not prejudiced by trial counsel's alleged failure to adequately investigate and present mitigation evidence relating to Defendant's family background, history of mental and physical abuse, and diagnosis of mixed personality disorder, with drug and alcohol dependency, as required to support claim of ineffective assistance of counsel, in sentencing phase of capital murder trial. Trial counsel presented evidence of Defendant's troubled background together with evidence of successes, acceptance of responsibility for killing, apology, and his religious conversion in prison. The Defendant's school records did not suggest any significant mental health history that warranted further investigation, supplemental testimony of Defendant's mother about Defendant's upbringing would have been cumulative of testimony of Defendant's great-grandmother at trial. During trial, aggravating circumstances demonstrated that Defendant actively participated in a plan to kidnap minor victim for ransom, and that victim died after having been bound, gagged, and confined in trunk of car for 24 hours, such that there was not reasonable probability that, while weighing aggravating and mitigating factors, jury would have voted against imposition of death penalty.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The Supreme Court found that the Strickland test (to demonstrate ineffective counsel, defendant must show (1) that the trial lawyer's performance fell below an objective standard of reasonableness and (2) a reasonable probability that but for counsel's unprofessional errors, the result of the proceeding would have been different. Strickland v. Washington, 466 U.S. 668 (1984)). Here, the Supreme Court held that the Defendant was not prejudiced by trial counsel's alleged failure to adequately investigate and present mitigation evidence relating to Defendant's family background, history of mental and physical abuse, and diagnosis of mixed personality disorder, with drug and alcohol dependency, as required to support claim of ineffective assistance of counsel, in sentencing phase of capital murder trial. Trial counsel presented evidence of Defendant's troubled background together with evidence of successes, acceptance of responsibility for killing, apology, and his religious conversion in prison. The Defendant's school records did not suggest any significant mental health history that warranted further investigation, supplemental testimony of Defendant's mother about Defendant's upbringing would have been cumulative of testimony of Defendant's great-grandmother at trial. During trial, aggravating circumstances demonstrated that Defendant actively participated in a plan to kidnap minor victim for ransom, and that victim died after having been bound, gagged, and confined in trunk of car for 24 hours, such that there was not reasonable probability that, while weighing aggravating and mitigating factors, jury would have voted against imposition of death penalty.
Link to Opinion
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Commonwealth v. Cunningham, 81 A.3d 1 (Pa. 2013), overruling, Commonwealth v. Cobbs, 256 A.3d 1192 (Pa. 2021)
|
Pennsylvania | 2013 | Criminal Justice, Juvenile Justice |
State:
Pennsylvania
Year:
2013
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant, who was a juvenile at the time of his conviction for second degree murder, sought retroactive application of Miller v. Alabama's (567 U.S. 460 (2012)) prohibition against mandatory life sentences without parole for juvenile offenders. The Supreme Court rejected Defendant's appeal and held that Miller's prohibition against mandatory life-without-parole sentencing for juvenile offenders did not apply retroactively. Teague v. Lane, 489 U.S. 288 (1989) established a general rule of non-retroactivity for new procedural, constitutional rules announced by the court, with two narrow exceptions. The exceptions apply to rules that prohibit a certain category of punishment based on a defendant's status or offense, as well as "watershed rules of criminal procedure" that impact the fundamental fairness and accuracy of the criminal proceeding. The current practice of the Supreme Court is to follow the Teague rule and not apply new constitutional rules retroactively, except for certain narrow exceptions. Here, the first Teague exception did not apply to Miller because it did not categorically bar a penalty for a class of offenders and was procedural, not substantive. The Defendant had not developed arguments in the terms of the second Teague exception. While some Justices may view Miller as a watershed rule, the Supreme Court doubted that a majority would broaden the exception beyond narrowly defined parameters. The Supreme Court emphasized its limited role in establishing social policy and finds no persuasive arguments to extend Miller's application retroactively.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant, who was a juvenile at the time of his conviction for second degree murder, sought retroactive application of Miller v. Alabama's (567 U.S. 460 (2012)) prohibition against mandatory life sentences without parole for juvenile offenders. The Supreme Court rejected Defendant's appeal and held that Miller's prohibition against mandatory life-without-parole sentencing for juvenile offenders did not apply retroactively. Teague v. Lane, 489 U.S. 288 (1989) established a general rule of non-retroactivity for new procedural, constitutional rules announced by the court, with two narrow exceptions. The exceptions apply to rules that prohibit a certain category of punishment based on a defendant's status or offense, as well as "watershed rules of criminal procedure" that impact the fundamental fairness and accuracy of the criminal proceeding. The current practice of the Supreme Court is to follow the Teague rule and not apply new constitutional rules retroactively, except for certain narrow exceptions. Here, the first Teague exception did not apply to Miller because it did not categorically bar a penalty for a class of offenders and was procedural, not substantive. The Defendant had not developed arguments in the terms of the second Teague exception. While some Justices may view Miller as a watershed rule, the Supreme Court doubted that a majority would broaden the exception beyond narrowly defined parameters. The Supreme Court emphasized its limited role in establishing social policy and finds no persuasive arguments to extend Miller's application retroactively.
Link to Opinion
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Commonwealth v. Crispell, 193 A.3d 919 (Pa. 2018)
|
Pennsylvania | 2018 | Criminal Justice, Death Penalty |
State:
Pennsylvania
Year:
2018
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Supreme Court held that access to discovery materials in a post-conviction case involving the death penalty requires good cause and more than a generic request. Counsel's Sixth Amendment duty in a capital case to conduct a reasonably thorough investigation for mitigating evidence encompasses the obligation to pursue all statutory mitigators of which counsel is aware or reasonably should be aware, unless there is some reasonable ground not to pursue the circumstance, such as when it might open the door to harmful evidence. Commonwealth v. Tharp, 101 A.3d 736 (2014). The Supreme Court's consideration of counsel's allegedly ineffective penalty phase investigation and presentation includes a number of factors, including (1) the reasonableness of counsel's investigation' (2) the mitigation evidence that was actually presented; and (3) the additional or different mitigation evidence that could have been presented. However, these factors are not dispositive, because even if counsel's investigation and presentation is deficient, the Defendant is not entitled to relief unless the Defendant was prejudiced by the deficient performance. Counsel cannot satisfy his or her obligation in a capital case to investigate thoroughly and to prepare mental health and other mitigation evidence by relying upon "only a rudimentary knowledge of the Defendant's history from a narrow set of sources." Wiggins v. Smith, 539 U.S. 510 (2003). In this case, the Supreme Court held that trial counsel's failure to investigate and present available mitigation efforts may have caused harm to the Defendant and affirmed the lower court's grant of a new penalty phase on that basis.
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Justice Vote Breakdown
|
Summary of Case Context & Holding
The Supreme Court held that access to discovery materials in a post-conviction case involving the death penalty requires good cause and more than a generic request. Counsel's Sixth Amendment duty in a capital case to conduct a reasonably thorough investigation for mitigating evidence encompasses the obligation to pursue all statutory mitigators of which counsel is aware or reasonably should be aware, unless there is some reasonable ground not to pursue the circumstance, such as when it might open the door to harmful evidence. Commonwealth v. Tharp, 101 A.3d 736 (2014). The Supreme Court's consideration of counsel's allegedly ineffective penalty phase investigation and presentation includes a number of factors, including (1) the reasonableness of counsel's investigation' (2) the mitigation evidence that was actually presented; and (3) the additional or different mitigation evidence that could have been presented. However, these factors are not dispositive, because even if counsel's investigation and presentation is deficient, the Defendant is not entitled to relief unless the Defendant was prejudiced by the deficient performance. Counsel cannot satisfy his or her obligation in a capital case to investigate thoroughly and to prepare mental health and other mitigation evidence by relying upon "only a rudimentary knowledge of the Defendant's history from a narrow set of sources." Wiggins v. Smith, 539 U.S. 510 (2003). In this case, the Supreme Court held that trial counsel's failure to investigate and present available mitigation efforts may have caused harm to the Defendant and affirmed the lower court's grant of a new penalty phase on that basis.
Link to Opinion
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Commonwealth v. Cosby, 252 A.3d 1092 (Pa. 2021), cert. denied sub nom., Pennsylvania v. Cosby, 142 S. Ct. 1230 (2022)
|
Pennsylvania | 2021 | Criminal Justice, Access to Justice |
State:
Pennsylvania
Year:
2021
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant appealed a decision denying motions seeking a new trial and modification of his sentence. One of the allegations raised by Defendant was that a prosecutor made a promise of nonprosecution and Defendant relied on that promise before testifying. The Supreme Court held that when a prosecutor makes an unconditional promise of nonprosecution and when the Defendant relies on that promise before taking the stand, fundamental fairness dictates that the promise be enforced.
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Justice Vote Breakdown
|
Summary of Case Context & Holding
Defendant appealed a decision denying motions seeking a new trial and modification of his sentence. One of the allegations raised by Defendant was that a prosecutor made a promise of nonprosecution and Defendant relied on that promise before testifying. The Supreme Court held that when a prosecutor makes an unconditional promise of nonprosecution and when the Defendant relies on that promise before taking the stand, fundamental fairness dictates that the promise be enforced.
Link to Opinion
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||||
|
Commonwealth v. Cobbs, 256 A.3d 1192 (Pa. 2021)
|
Pennsylvania | 2021 | Criminal Justice, Juvenile Justice |
State:
Pennsylvania
Year:
2021
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingAppellant was convicted of felony murder at 17 years old and sentenced to a mandatory sentence of life imprisonment without the possibility of parole. While serving his life sentence, he stabbed another inmate and was convicted of assault by a life prisoner. After the court of common pleas resentenced Appellant in light of Miller v. Alabama, 567 U.S. 460 (2012) (holding that mandatory life without parole for juveniles violates Eight Amendment) and Montgomery v. Louisiana, 577 U.S. 190 (2016) (holding that Miller applies retroactively), the Supreme Court held that because his prior life sentence was void, his assault by a life prisoner charger was also void.
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Justice Vote Breakdown
|
Summary of Case Context & Holding
Appellant was convicted of felony murder at 17 years old and sentenced to a mandatory sentence of life imprisonment without the possibility of parole. While serving his life sentence, he stabbed another inmate and was convicted of assault by a life prisoner. After the court of common pleas resentenced Appellant in light of Miller v. Alabama, 567 U.S. 460 (2012) (holding that mandatory life without parole for juveniles violates Eight Amendment) and Montgomery v. Louisiana, 577 U.S. 190 (2016) (holding that Miller applies retroactively), the Supreme Court held that because his prior life sentence was void, his assault by a life prisoner charger was also void.
Link to Opinion
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Commonwealth v. Clemons, 200 A.3d 441 (Pa. 2019)
|
Pennsylvania | 2019 | Criminal Justice, Death Penalty |
State:
Pennsylvania
Year:
2019
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was convicted of first-degree murder and was sentenced to death. The Supreme Court held that there was no basis upon which to reject decision to impose death penalty in first-degree murder trial. The Supreme Court reasoned that the imposition of death sentence was not the product of passion, prejudice, or any other arbitrary factor, but rather the sentence resulted from substantial evidence proving Defendant deliberately and maliciously killed victim. In addition, the jury found the required aggravating circumstances, which were supported by ample evidence and the jury performed its duties under the relevant death penalty statute.
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Justice Vote Breakdown
|
Summary of Case Context & Holding
Defendant was convicted of first-degree murder and was sentenced to death. The Supreme Court held that there was no basis upon which to reject decision to impose death penalty in first-degree murder trial. The Supreme Court reasoned that the imposition of death sentence was not the product of passion, prejudice, or any other arbitrary factor, but rather the sentence resulted from substantial evidence proving Defendant deliberately and maliciously killed victim. In addition, the jury found the required aggravating circumstances, which were supported by ample evidence and the jury performed its duties under the relevant death penalty statute.
Link to Opinion
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Commonwealth v. Cash, 137 A.3d 1262 (Pa. 2016)
|
Pennsylvania | 2016 | Criminal Justice, Death Penalty |
State:
Pennsylvania
Year:
2016
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant appealed a conviction arguing that the judge impermissibly allowed testimony during the penalty phase of his trial. The judge permitted a witness to say that he was robbed by the Defendant, when, in fact, the Defendant was never convicted of robbing the witness. The trial judge promptly and emphatically directed the jury to disregard the witness' testimony. The Supreme Court held that the Defendant was not entitled to a new trial as a result. The Supreme Court also said that there was substantial evidence regarding defendant's prior murder conviction and multiple rape and robbery convictions, which were offered in support of the significant history of violent felony aggravator.
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Justice Vote Breakdown
|
Summary of Case Context & Holding
Defendant appealed a conviction arguing that the judge impermissibly allowed testimony during the penalty phase of his trial. The judge permitted a witness to say that he was robbed by the Defendant, when, in fact, the Defendant was never convicted of robbing the witness. The trial judge promptly and emphatically directed the jury to disregard the witness' testimony. The Supreme Court held that the Defendant was not entitled to a new trial as a result. The Supreme Court also said that there was substantial evidence regarding defendant's prior murder conviction and multiple rape and robbery convictions, which were offered in support of the significant history of violent felony aggravator.
Link to Opinion
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Commonwealth v. Burton, 158 A.3d 618 (Pa. 2017)
|
Pennsylvania | 2017 | Criminal Justice, Access to Justice |
State:
Pennsylvania
Year:
2017
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingAn inmate filed an appeal based on "new evidence," which consisted of public court records. Typically, an appeal cannot be based on public information. However, in this case, the Supreme Court held that "the presumption that information which is of public record cannot be deemed 'unknown' for purposes of [the rules] does not apply to pro se prisoner petitioners." The application of the public record presumption to pro se prisoners is contrary to the plain language of subsection 9545(b)(1)(ii) and was imposed without any apparent consideration of a pro se prisoner’s actual access to information of public record; therefore, in this case the Supreme Court held the inmate should not be barred from filing the appeal.
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Justice Vote Breakdown
|
Summary of Case Context & Holding
An inmate filed an appeal based on "new evidence," which consisted of public court records. Typically, an appeal cannot be based on public information. However, in this case, the Supreme Court held that "the presumption that information which is of public record cannot be deemed 'unknown' for purposes of [the rules] does not apply to pro se prisoner petitioners." The application of the public record presumption to pro se prisoners is contrary to the plain language of subsection 9545(b)(1)(ii) and was imposed without any apparent consideration of a pro se prisoner’s actual access to information of public record; therefore, in this case the Supreme Court held the inmate should not be barred from filing the appeal.
Link to Opinion
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Commonwealth v. Burno, 154 A.3d 764 (Pa. 2017)
|
Pennsylvania | 2017 | Criminal Justice, Death Penalty |
State:
Pennsylvania
Year:
2017
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant challenged the admissibility of his confessions to two murders. The Supreme Court found that Defendant's second confession was made in course of plea negotiations and, thus, was inadmissible. The Supreme Court reasoned that the Defendant had reasonable subjective expectation that he was confessing as part of plea negotiations since the detective stated that Defendant believed, with his cooperation, that death penalty would be off table and that he would receive life sentence. The Supreme Court, however, ultimately concluded that the erroneous admission of the confession at trial was harmless because the untainted evidence was indisputable. Therefore, the plea statement was merely cumulative of the same incriminating statements that he made in other contexts and the trial court's error was harmless.
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Justice Vote Breakdown
|
Summary of Case Context & Holding
Defendant challenged the admissibility of his confessions to two murders. The Supreme Court found that Defendant's second confession was made in course of plea negotiations and, thus, was inadmissible. The Supreme Court reasoned that the Defendant had reasonable subjective expectation that he was confessing as part of plea negotiations since the detective stated that Defendant believed, with his cooperation, that death penalty would be off table and that he would receive life sentence. The Supreme Court, however, ultimately concluded that the erroneous admission of the confession at trial was harmless because the untainted evidence was indisputable. Therefore, the plea statement was merely cumulative of the same incriminating statements that he made in other contexts and the trial court's error was harmless.
Link to Opinion
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Commonwealth v. Bryant, 67 A.3d 716 (Pa. 2013)
|
Pennsylvania | 2013 | Criminal Justice, Death Penalty |
State:
Pennsylvania
Year:
2013
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Supreme Court has a self-imposed duty in all capital cases to conduct an independent review of the sufficiency of the evidence to sustain a conviction for first-degree murder, a duty that is not abrogated when a defendant has pled guilty to first-degree murder. Admission of evidence, including victim impact evidence, rests within the sound discretion of the trial court, which must balance evidentiary value against the potential dangers of unfairly prejudicing the accused, inflaming the passions of the jury, or confusing the jury. The Supreme Court held that the trial court did not abuse its discretion in permitting the Commonwealth to show the jury during the victim impact portion of capital murder prosecution a photograph of each of victim's two children, as the children did not testify themselves, and their photographs constituted the only means by which the Commonwealth could show the jury the individuals who were arguably most affected by Defendant's offense, and thus put a human face on the harm it caused. The Supreme Court explained that a prosecutor is permitted to address a defendant's lack of remorse during penalty phase of a capital murder trial.
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Justice Vote Breakdown
|
Summary of Case Context & Holding
The Supreme Court has a self-imposed duty in all capital cases to conduct an independent review of the sufficiency of the evidence to sustain a conviction for first-degree murder, a duty that is not abrogated when a defendant has pled guilty to first-degree murder. Admission of evidence, including victim impact evidence, rests within the sound discretion of the trial court, which must balance evidentiary value against the potential dangers of unfairly prejudicing the accused, inflaming the passions of the jury, or confusing the jury. The Supreme Court held that the trial court did not abuse its discretion in permitting the Commonwealth to show the jury during the victim impact portion of capital murder prosecution a photograph of each of victim's two children, as the children did not testify themselves, and their photographs constituted the only means by which the Commonwealth could show the jury the individuals who were arguably most affected by Defendant's offense, and thus put a human face on the harm it caused. The Supreme Court explained that a prosecutor is permitted to address a defendant's lack of remorse during penalty phase of a capital murder trial.
Link to Opinion
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Commonwealth v. Blakeney, 193 A.3d 350 (Pa. 2018)
|
Pennsylvania | 2018 | Criminal Justice, Access to Justice |
State:
Pennsylvania
Year:
2018
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was convicted of first degree murder and sentenced to death. After his initial appeal was denied, he filed a second post-conviction petition alleging, in part, that the justice sitting on the Supreme Court had exchanged offensive e-mails with members of the prosecution. He alleged that the discovery of those e-mails constituted newly discovered evidence within the meaning of the one-year limitation bar on post-conviction reviews. The Supreme Court held that the discovery of the offensive e-mails suggested a relationship of significant closeness that threatened the justice's objectivity. Specifically, the justice's e-mails denigrated African-Americans and Muslims, which revealed the potential for judicial bias because the petitioner was an African-American Muslim. The Supreme Court held that the Petitioner could not have exercised due diligence to make that factual finding about the sitting justice and therefore, the revelations constituted newly discovered facts.
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Justice Vote Breakdown
|
Summary of Case Context & Holding
Defendant was convicted of first degree murder and sentenced to death. After his initial appeal was denied, he filed a second post-conviction petition alleging, in part, that the justice sitting on the Supreme Court had exchanged offensive e-mails with members of the prosecution. He alleged that the discovery of those e-mails constituted newly discovered evidence within the meaning of the one-year limitation bar on post-conviction reviews. The Supreme Court held that the discovery of the offensive e-mails suggested a relationship of significant closeness that threatened the justice's objectivity. Specifically, the justice's e-mails denigrated African-Americans and Muslims, which revealed the potential for judicial bias because the petitioner was an African-American Muslim. The Supreme Court held that the Petitioner could not have exercised due diligence to make that factual finding about the sitting justice and therefore, the revelations constituted newly discovered facts.
Link to Opinion
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|
Commonwealth v. Baumhammers, 92 A.3d 708 (Pa. 2014)
|
Pennsylvania | 2014 | Criminal Justice, Death Penalty |
State:
Pennsylvania
Year:
2014
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPennsylvania's capital sentencing statute lists as an aggravating circumstance a defendant who has been convicted of another murder in any jurisdiction and committed either before or at the time of the offense at issue. The Defendant challenged the statute arguing that it was impermissibly vague under the Eighth Amendment. The Supreme Court held that the statute's recognition of multiple-murders death penalty aggravator was not impermissibly vague, in violation of right of protection against cruel and unusual punishment, in its use of “conviction” in referencing multiple offenses. The Supreme Court said that by including offenses committed contemporaneously with the offense in issue, the Legislature clearly indicated its intention that the term “convicted” not require final imposition of sentence, but cover determinations of guilt as well. To survive an Eighth Amendment challenge vagueness, an aggravating circumstance must genuinely narrow the class of persons eligible for the death penalty and must reasonably justify the imposition of a more severe sentence on the defendant compared to others found guilty of murder. Commonwealth v. Fletcher, 861 A.2d 898 (2004).
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Justice Vote Breakdown
|
Summary of Case Context & Holding
Pennsylvania's capital sentencing statute lists as an aggravating circumstance a defendant who has been convicted of another murder in any jurisdiction and committed either before or at the time of the offense at issue. The Defendant challenged the statute arguing that it was impermissibly vague under the Eighth Amendment. The Supreme Court held that the statute's recognition of multiple-murders death penalty aggravator was not impermissibly vague, in violation of right of protection against cruel and unusual punishment, in its use of “conviction” in referencing multiple offenses. The Supreme Court said that by including offenses committed contemporaneously with the offense in issue, the Legislature clearly indicated its intention that the term “convicted” not require final imposition of sentence, but cover determinations of guilt as well. To survive an Eighth Amendment challenge vagueness, an aggravating circumstance must genuinely narrow the class of persons eligible for the death penalty and must reasonably justify the imposition of a more severe sentence on the defendant compared to others found guilty of murder. Commonwealth v. Fletcher, 861 A.2d 898 (2004).
Link to Opinion
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Commonwealth v. Batts, 66 A.3d 286 (Pa. 2013) (Batts I)
|
Pennsylvania | 2013 | Criminal Justice, Juvenile Justice |
State:
Pennsylvania
Year:
2013
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was convicted as a juvenile of first degree murder, attempted murder, and aggravated assault, and was sentenced to life in prison without the possibility of parole. The superior court affirmed the court of common pleas' sentence. The superior court made a distinction between the current case and Roper v. Simmons, 543 U.S. 551 (2005). In Roper, it was established that giving the death penalty to juveniles under eighteen violated the Eighth Amendment's ban on cruel and unusual punishment. However, the superior court reasoned that Roper's decision only applies to cases involving the death penalty for juvenile offenders. It does not impact the imposition of a life sentence without the possibility of parole. The Supreme Court held that in the aftermath of Miller v. Alabama, 567 U.S. 460 (2012), which held that mandatory life imprisonment without parole for those under the age of 18 at the time of their crimes violates the Eighth Amendment's prohibition on cruel and unusual punishments, the appropriate remedy for defendants sentenced as juveniles to mandatory life without parole was a resentencing hearing, as the Pennsylvania Constitution did not support a categorical ban on life-without-parole sentences for juveniles. The Supreme Court vacated the superior court's decision and remanded the case for resentencing.
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Justice Vote Breakdown
|
Summary of Case Context & Holding
Defendant was convicted as a juvenile of first degree murder, attempted murder, and aggravated assault, and was sentenced to life in prison without the possibility of parole. The superior court affirmed the court of common pleas' sentence. The superior court made a distinction between the current case and Roper v. Simmons, 543 U.S. 551 (2005). In Roper, it was established that giving the death penalty to juveniles under eighteen violated the Eighth Amendment's ban on cruel and unusual punishment. However, the superior court reasoned that Roper's decision only applies to cases involving the death penalty for juvenile offenders. It does not impact the imposition of a life sentence without the possibility of parole. The Supreme Court held that in the aftermath of Miller v. Alabama, 567 U.S. 460 (2012), which held that mandatory life imprisonment without parole for those under the age of 18 at the time of their crimes violates the Eighth Amendment's prohibition on cruel and unusual punishments, the appropriate remedy for defendants sentenced as juveniles to mandatory life without parole was a resentencing hearing, as the Pennsylvania Constitution did not support a categorical ban on life-without-parole sentences for juveniles. The Supreme Court vacated the superior court's decision and remanded the case for resentencing.
Link to Opinion
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||||
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Commonwealth v. Batts, 163 A.3d 410 (2017), abrogated by, Jones v. Mississippi, 141 S. Ct. 1307 (Pa. 2021) (Batts II)
|
Pennsylvania | 2017 | Criminal Justice, Juvenile Justice |
State:
Pennsylvania
Year:
2017
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was convicted as a juvenile of first degree murder, attempted murder, and aggravated assault, and was sentenced to life in prison without the possibility of parole. Following Miller v. Alabama, 567 U.S. 460 (2012), which held that mandatory life imprisonment without parole for those under the age of 18 at the time of their crimes violates the Eighth Amendment's prohibition on cruel and unusual punishments, Defendant appealed and was resentenced to life in prison without the possibility of parole. The Supreme Court held that Defendant's new sentence was also illegal and in so doing, recognized a presumption against life without parole for juvenile offenders which the Commonwealth bears the burden of rebutting through proving beyond a reasonable doubt that the juvenile is incapable of rehabilitation. The Supreme Court reversed and remanded for further proceedings.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was convicted as a juvenile of first degree murder, attempted murder, and aggravated assault, and was sentenced to life in prison without the possibility of parole. Following Miller v. Alabama, 567 U.S. 460 (2012), which held that mandatory life imprisonment without parole for those under the age of 18 at the time of their crimes violates the Eighth Amendment's prohibition on cruel and unusual punishments, Defendant appealed and was resentenced to life in prison without the possibility of parole. The Supreme Court held that Defendant's new sentence was also illegal and in so doing, recognized a presumption against life without parole for juvenile offenders which the Commonwealth bears the burden of rebutting through proving beyond a reasonable doubt that the juvenile is incapable of rehabilitation. The Supreme Court reversed and remanded for further proceedings.
Link to Opinion
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Commonwealth v. Bardo, 105 A.3d 678 (Pa. 2014)
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Pennsylvania | 2014 | Criminal Justice, Death Penalty |
State:
Pennsylvania
Year:
2014
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Defendant argued that his counsel was ineffective because he failed to present certain mitigation evidence. When assessing prejudice in the context of a claim of trial counsel ineffectiveness for failure to present additional evidence of mitigation in death penalty case, post-conviction court must directly compare mitigation case offered at trial with credited mitigation evidence offered on post-conviction review. The goal of this comparison is to determine whether it is or is not reasonably probable that, had additional evidence of mitigation been presented at trial, at least one juror would have concluded that mitigating circumstances outweighed or were as weighty as aggravating circumstances, and thus would have voted for sentence of life imprisonment rather than death. The Supreme Court held that the claim of ineffective counsel failed, because it reweighed the evidence in aggravation against totality of the evidence of mitigation, which includes both evidence presented at penalty phase hearing and credited evidence on post-conviction review, and found that the purported mitigation evidence was not reasonably probably to change the decision of at least one juror.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The Defendant argued that his counsel was ineffective because he failed to present certain mitigation evidence. When assessing prejudice in the context of a claim of trial counsel ineffectiveness for failure to present additional evidence of mitigation in death penalty case, post-conviction court must directly compare mitigation case offered at trial with credited mitigation evidence offered on post-conviction review. The goal of this comparison is to determine whether it is or is not reasonably probable that, had additional evidence of mitigation been presented at trial, at least one juror would have concluded that mitigating circumstances outweighed or were as weighty as aggravating circumstances, and thus would have voted for sentence of life imprisonment rather than death. The Supreme Court held that the claim of ineffective counsel failed, because it reweighed the evidence in aggravation against totality of the evidence of mitigation, which includes both evidence presented at penalty phase hearing and credited evidence on post-conviction review, and found that the purported mitigation evidence was not reasonably probably to change the decision of at least one juror.
Link to Opinion
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Commonwealth v. Arrington, 86 A.3d 831 (Pa. 2014)
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Pennsylvania | 2014 | Criminal Justice, Death Penalty |
State:
Pennsylvania
Year:
2014
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDuring a post-evidentiary hearing, a co-author of an article testified that pervasive racial discrimination affected death penalty trials conducted in county in which capital murder defendant was tried. The co-author had added Defendant's case to the cross-section of cases he analyzed for the defense, but the Supreme Court found that Defendant had failed to establish that racial discrimination occurred at defendant's trial, because the Defendant made only generalized allegations of discrimination or statistics showing a disproportionate application of the death penalty to members of certain groups, and there was no evidence that Defendant's jury imposed death penalty in a discriminatory manner. The Supreme Court also concluded that a capital murder Defendant's prior felony convictions, including arson; assault with intent to cause serious injury; and attempted murder, were adequate to establish aggravating circumstance that Defendant had a significant history of felony convictions involving the use or threat of violence to the person, as necessary to support death sentence imposed on him.
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Justice Vote Breakdown
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Summary of Case Context & Holding
During a post-evidentiary hearing, a co-author of an article testified that pervasive racial discrimination affected death penalty trials conducted in county in which capital murder defendant was tried. The co-author had added Defendant's case to the cross-section of cases he analyzed for the defense, but the Supreme Court found that Defendant had failed to establish that racial discrimination occurred at defendant's trial, because the Defendant made only generalized allegations of discrimination or statistics showing a disproportionate application of the death penalty to members of certain groups, and there was no evidence that Defendant's jury imposed death penalty in a discriminatory manner. The Supreme Court also concluded that a capital murder Defendant's prior felony convictions, including arson; assault with intent to cause serious injury; and attempted murder, were adequate to establish aggravating circumstance that Defendant had a significant history of felony convictions involving the use or threat of violence to the person, as necessary to support death sentence imposed on him.
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Commonwealth v. Armolt, 294 A.3d 364 (Pa. 2023)
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Pennsylvania | 2023 | Criminal Justice, Juvenile Justice |
State:
Pennsylvania
Year:
2023
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingAppellant was prosecuted as an adult for and convicted of sexual offenses he committed as a juvenile several decades after the fact. From the late 1980s until the early 1990s, Appellant committed hundreds of sexual offenses against the victim, during which time, Appellant was ten through seventeen years old. The Supreme Court held that Defendant who committed crimes while he was juvenile, but was not charged until he was adult, was subject to criminal court's jurisdiction. The Supreme Court examined the language of the Juvenile Act, which explicitly limits the jurisdiction of juvenile courts to proceedings involving delinquent or dependent children. A child is defined as someone under eighteen years of age or under twenty-one if they committed an offense before turning eighteen. As Appellant was charged in his forties, he did not qualify as a child under the Juvenile Act, and therefore, the adult criminal court had jurisdiction over him. The Supreme Court did not reach a conclusion regarding Appellant's constitutional challenges.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Appellant was prosecuted as an adult for and convicted of sexual offenses he committed as a juvenile several decades after the fact. From the late 1980s until the early 1990s, Appellant committed hundreds of sexual offenses against the victim, during which time, Appellant was ten through seventeen years old. The Supreme Court held that Defendant who committed crimes while he was juvenile, but was not charged until he was adult, was subject to criminal court's jurisdiction. The Supreme Court examined the language of the Juvenile Act, which explicitly limits the jurisdiction of juvenile courts to proceedings involving delinquent or dependent children. A child is defined as someone under eighteen years of age or under twenty-one if they committed an offense before turning eighteen. As Appellant was charged in his forties, he did not qualify as a child under the Juvenile Act, and therefore, the adult criminal court had jurisdiction over him. The Supreme Court did not reach a conclusion regarding Appellant's constitutional challenges.
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Columbia/CSA-HS Greater Columbia Healthcare Sys., L.P. v. S.C. Med. Malpractice Liab. Joint Underwriting Ass’n, 713 S.E.2d 639 (S.C. 2014)
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South Carolina | 2014 | Health Care, Health Care Access/Funding |
State:
South Carolina
Year:
2014
Topics:
Health Care, Health Care Access/Funding
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingProvidence Hospital sought equitable indemnification (when a person who pays for damage or loss—even though it was not their fault— can ask the actual wrongdoer to indemnify them) from Dr. Michael Taillon and his medical malpractice insurer for a 2004 settlement the hospital paid in a lawsuit arising from the misdiagnosis of a heart attack in 1997. The patient, Arthur Sharpe originally sued only Providence and a different physician. In 2007, Providence filed its indemnification claim, alleging that Dr. Taillon’s negligence caused the injury and that Providence paid damages for which he was responsible. The circuit court granted summary judgment to the Defendants, holding that the six-year statute of repose for medical malpractice actions barred the indemnity claim. The court of appeals affirmed. On review, the South Carolina Supreme Court also affirmed holding that Providence’s indemnification claim fell within the scope of the medical malpractice statute of repose because it necessarily relied on proving Taillon's liability for medical malpractice. Since more than six years had passed from the date of the alleged negligence in 1997, the indemnification claim filed in 2007 was barred by the statute of repose.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Providence Hospital sought equitable indemnification (when a person who pays for damage or loss—even though it was not their fault— can ask the actual wrongdoer to indemnify them) from Dr. Michael Taillon and his medical malpractice insurer for a 2004 settlement the hospital paid in a lawsuit arising from the misdiagnosis of a heart attack in 1997. The patient, Arthur Sharpe originally sued only Providence and a different physician. In 2007, Providence filed its indemnification claim, alleging that Dr. Taillon’s negligence caused the injury and that Providence paid damages for which he was responsible. The circuit court granted summary judgment to the Defendants, holding that the six-year statute of repose for medical malpractice actions barred the indemnity claim. The court of appeals affirmed. On review, the South Carolina Supreme Court also affirmed holding that Providence’s indemnification claim fell within the scope of the medical malpractice statute of repose because it necessarily relied on proving Taillon's liability for medical malpractice. Since more than six years had passed from the date of the alleged negligence in 1997, the indemnification claim filed in 2007 was barred by the statute of repose.
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Coleman v. Mariner Health Care, Inc., 755 S.E.2d 450 (S.C. 2014)
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South Carolina | 2014 | Health Care, Health Care Access/Funding |
State:
South Carolina
Year:
2014
Topics:
Health Care, Health Care Access/Funding
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe estate of Mary Brinson, through her sister Ann Coleman, brought a wrongful death and survival action against a nursing home and affiliated entities, alleging negligent care. Brinson was admitted to the facility in a non-responsive state and Coleman signed admission documents on her behalf, including arbitration agreements. Defendants moved to compel arbitration, asserting that Coleman had authority under South Carolina’s Adult Health Care Consent Act to bind Brinson to the agreement to arbitrate. The circuit court denied the motion, holding that Coleman lacked authority to execute the arbitration agreement. Defendants appealed directly to the South Carolina Supreme Court. The Supreme Court affirmed, holding that the Adult Health Care Consent Act permits surrogates to make (1) medical decisions and (2) financial decisions for incapacitated patients, but does not extend to executing arbitration agreements, which are legal—not medical or financial—decisions. The Court also rejected the argument that Coleman should be equitably estopped from contesting the arbitration agreement, finding no evidence that she acted in a way that would make enforcement fair or appropriate.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The estate of Mary Brinson, through her sister Ann Coleman, brought a wrongful death and survival action against a nursing home and affiliated entities, alleging negligent care. Brinson was admitted to the facility in a non-responsive state and Coleman signed admission documents on her behalf, including arbitration agreements. Defendants moved to compel arbitration, asserting that Coleman had authority under South Carolina’s Adult Health Care Consent Act to bind Brinson to the agreement to arbitrate. The circuit court denied the motion, holding that Coleman lacked authority to execute the arbitration agreement. Defendants appealed directly to the South Carolina Supreme Court. The Supreme Court affirmed, holding that the Adult Health Care Consent Act permits surrogates to make (1) medical decisions and (2) financial decisions for incapacitated patients, but does not extend to executing arbitration agreements, which are legal—not medical or financial—decisions. The Court also rejected the argument that Coleman should be equitably estopped from contesting the arbitration agreement, finding no evidence that she acted in a way that would make enforcement fair or appropriate.
Link to Opinion
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Coates v. State, 818 S.E.2d 622 (Ga. 2018)
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Georgia | 2018 | Criminal Justice |
State:
Georgia
Year:
2018
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was convicted of four counts of possession of a firearm by a convicted felon and was sentenced on each count. Defendant appealed. The court of appeals affirmed his convictions and sentences, concluding that O.C.G.A. § 16-11-131(b) permitted a defendant to be separately convicted and sentenced for each of the multiple firearms in his possession. The Supreme Court contemplated whether a single course of conduct could result in multiple convictions and sentences under the same statute, whether the doctrine of substantive double jeopardy was implicated, and whether the “unit of prosecution,” or the precise act criminalized by the statute, must be identified. The Supreme Court held that the statute prohibiting possession of firearms by convicted felons permits only one prosecution and conviction for the simultaneous possession of multiple firearms. Therefore, the Supreme Court concluded that the court of appeals erred and reversed Defendant's convictions and sentences for the four counts of possession of a firearm by a convicted felon, and remanded the case to the trial court to convict and resentence Defendant on only one of those counts.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was convicted of four counts of possession of a firearm by a convicted felon and was sentenced on each count. Defendant appealed. The court of appeals affirmed his convictions and sentences, concluding that O.C.G.A. § 16-11-131(b) permitted a defendant to be separately convicted and sentenced for each of the multiple firearms in his possession. The Supreme Court contemplated whether a single course of conduct could result in multiple convictions and sentences under the same statute, whether the doctrine of substantive double jeopardy was implicated, and whether the “unit of prosecution,” or the precise act criminalized by the statute, must be identified. The Supreme Court held that the statute prohibiting possession of firearms by convicted felons permits only one prosecution and conviction for the simultaneous possession of multiple firearms. Therefore, the Supreme Court concluded that the court of appeals erred and reversed Defendant's convictions and sentences for the four counts of possession of a firearm by a convicted felon, and remanded the case to the trial court to convict and resentence Defendant on only one of those counts.
Link to Opinion
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Cnty. of Will v. Pollution Control Bd., 135 N.E.3d 49 (Ill. 2019)
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Illinois | 2019 | Environment, Pollution/Contamination, Actions Against Government |
State:
Illinois
Year:
2019
Topics:
Environment, Pollution/Contamination, Actions Against Government
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Illinois legislature passed a law requiring the Illinois Environmental Protection Agency (IEPA) to submit a plan to the Pollution Control Board (PCB) for how to protect groundwater from contamination at construction sites. The PCB rejected one term of IEPA's plan, which required continual groundwater monitoring. The Attorney General sued the PCB arguing its rejection of groundwater monitoring was arbitrary and capricious. The Court held that the Board’s decision satisfied reasonable standards in part because the PCB is accorded significant deference. The Board considered a lack of evidence that groundwater monitoring was necessary, minimal analysis of the economic impact, and whether certain sites were considered waste. The legislature granted the PCB the final decision in how to regulate groundwater, and the PCB considered all the evidence and issued a plausible decision in light of the evidence.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The Illinois legislature passed a law requiring the Illinois Environmental Protection Agency (IEPA) to submit a plan to the Pollution Control Board (PCB) for how to protect groundwater from contamination at construction sites. The PCB rejected one term of IEPA's plan, which required continual groundwater monitoring. The Attorney General sued the PCB arguing its rejection of groundwater monitoring was arbitrary and capricious. The Court held that the Board’s decision satisfied reasonable standards in part because the PCB is accorded significant deference. The Board considered a lack of evidence that groundwater monitoring was necessary, minimal analysis of the economic impact, and whether certain sites were considered waste. The legislature granted the PCB the final decision in how to regulate groundwater, and the PCB considered all the evidence and issued a plausible decision in light of the evidence.
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Cnty. of Volusia v. Detzner, 253 So. 3d 507 (Fla. 2018) (per curiam)
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Florida | 2018 | Democracy & Voting |
State:
Florida
Year:
2018
Topics:
Democracy & Voting
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Court approved a ballot initiative seeking to amend the Florida Constitution in order to remove the ability of counties to abolish, transfer duties, or change the terms of specific offices through their county charters (specifically, the initiative concerned the constitutionally mandated roles of county sheriff, tax collector, property appraiser, supervisor of elections, and clerk of the circuit court). The Court reviewed the ballot initiative to determine whether it was “clearly and conclusively defective," and concluded that it was not. The Court rejected the suing counties' argument that the language was flawed for not mentioning a loss of rights, deciding that "there is no need to explain ramifications that are implicit." The Court also rejected the counties' arguments that the ballot language failed to state the current state of the law and erroneously grouped together separate measures, finding the ballot initiative's language to be "clear" and "not misleading." Finally, the Court declined to decide whether the ballot language should discuss retroactive application of the changes, as it found that "the question of whether an amendment operates retroactively should be resolved in a post-election action."
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Justice Vote Breakdown
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Summary of Case Context & Holding
The Court approved a ballot initiative seeking to amend the Florida Constitution in order to remove the ability of counties to abolish, transfer duties, or change the terms of specific offices through their county charters (specifically, the initiative concerned the constitutionally mandated roles of county sheriff, tax collector, property appraiser, supervisor of elections, and clerk of the circuit court). The Court reviewed the ballot initiative to determine whether it was “clearly and conclusively defective," and concluded that it was not. The Court rejected the suing counties' argument that the language was flawed for not mentioning a loss of rights, deciding that "there is no need to explain ramifications that are implicit." The Court also rejected the counties' arguments that the ballot language failed to state the current state of the law and erroneously grouped together separate measures, finding the ballot initiative's language to be "clear" and "not misleading." Finally, the Court declined to decide whether the ballot language should discuss retroactive application of the changes, as it found that "the question of whether an amendment operates retroactively should be resolved in a post-election action."
Link to Opinion
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Cmty. Success Initiative v. Moore, 886 S.E.2d 16 (N.C. 2023)
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North Carolina | 2023 | Democracy & Voting, Voting Rights, Criminal Justice |
State:
North Carolina
Year:
2023
Topics:
Democracy & Voting, Voting Rights, Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingNonprofit organizations and felons who were unable to vote while on felony supervision brought an action for declaratory judgement against North Carolina legislators. The Plaintiffs stated that the law preventing felons from voting violated the equal protection clause and free elections clauses of North Carolina's Constitution by discriminating against African Americans, by depriving felons of the fundamental right to vote, by conditioning rights on ability to pay court costs, and by producing elections that do not represent the full will of the people. The Supreme Court first noted that the law does not violate the fundamental right to vote because the North Carolina Constitution expressly divests felons of the right to vote upon their conviction. Next the Supreme Court said that a violation of equal protection through racial discrimination occurs when the motivating factor for passing a given law is racial bias. The Supreme Court found that there is insufficient evidence to prove the General Assembly was motivated by racial discrimination in passing the law and legislature decisions should be presumed to be made in good faith. Next, the Supreme Court found the claim of an equal protection violation for conditioning payment of court costs lacks merit because even though a statute may operate unconstitutionally in certain circumstances, it does not make the statute wholly invalid and the court finds it rational to assume felons who have satisfied sentences and paid all fines are more likely to vote responsibly and incentivize them to take financial responsibility to be able to vote. Finally, the Supreme Court also held the law does not violate the free elections clause because the clause was designed to protect elections from interference, intimidation, and fraud and excluding felons who have no right to vote as defined by the North Carolina Constitution cannot cause such interference.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Nonprofit organizations and felons who were unable to vote while on felony supervision brought an action for declaratory judgement against North Carolina legislators. The Plaintiffs stated that the law preventing felons from voting violated the equal protection clause and free elections clauses of North Carolina's Constitution by discriminating against African Americans, by depriving felons of the fundamental right to vote, by conditioning rights on ability to pay court costs, and by producing elections that do not represent the full will of the people. The Supreme Court first noted that the law does not violate the fundamental right to vote because the North Carolina Constitution expressly divests felons of the right to vote upon their conviction. Next the Supreme Court said that a violation of equal protection through racial discrimination occurs when the motivating factor for passing a given law is racial bias. The Supreme Court found that there is insufficient evidence to prove the General Assembly was motivated by racial discrimination in passing the law and legislature decisions should be presumed to be made in good faith. Next, the Supreme Court found the claim of an equal protection violation for conditioning payment of court costs lacks merit because even though a statute may operate unconstitutionally in certain circumstances, it does not make the statute wholly invalid and the court finds it rational to assume felons who have satisfied sentences and paid all fines are more likely to vote responsibly and incentivize them to take financial responsibility to be able to vote. Finally, the Supreme Court also held the law does not violate the free elections clause because the clause was designed to protect elections from interference, intimidation, and fraud and excluding felons who have no right to vote as defined by the North Carolina Constitution cannot cause such interference.
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Clean Wis., Inc. v. Wis. Dep't of Nat. Res., 961 N.W.2d 611 (Wis. 2021)
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Wisconsin | 2021 | Environment, Actions Against Government, Water Rights |
State:
Wisconsin
Year:
2021
Topics:
Environment, Actions Against Government, Water Rights
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Wisconsin Department of Natural Resources (DNR) evaluates applications to operate high capacity groundwater wells. For some wells, there is a specific evaluation process that the DNR must follow, but for others, there is no formal process. When there is no formal process prescribed, the DNR is still permitted to consider multiple factors in its review, including the potential environmental effects of a proposed well. Clean Wisconsin, Inc. (an environmental advocacy organization) and the Pleasant Lake Management District (together, "Clean Wisconsin") appealed the DNR's decision to approve eight well applications that fell into the latter category (no formal evaluation process required). DNR approved the eight well applications after it received information that the wells would negatively impact the environment, and concluded that, because there was no formal process required for the approval of these wells, it had no authority to consider the proposed wells' environmental effects. The Supreme Court concluded that the DNR does have authority to consider the environmental effects of proposed high capacity wells, because in Wis. Stat. Sect. 281.12 the legislature grants the DNR broad and explicit authority to consider the environmental effects of any proposed high capacity well. Just because the wells in question weren't required to undergo a specific evaluation process, does not mean that they should not be evaluated with respect to their effect on the environment. The Supreme Court relied on both the explicit authority in the statute, and the public trust doctrine, pursuant to which the DNR is entrusted with preserving and protecting Wisconsin's navigable waters, to reach its conclusion.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The Wisconsin Department of Natural Resources (DNR) evaluates applications to operate high capacity groundwater wells. For some wells, there is a specific evaluation process that the DNR must follow, but for others, there is no formal process. When there is no formal process prescribed, the DNR is still permitted to consider multiple factors in its review, including the potential environmental effects of a proposed well. Clean Wisconsin, Inc. (an environmental advocacy organization) and the Pleasant Lake Management District (together, "Clean Wisconsin") appealed the DNR's decision to approve eight well applications that fell into the latter category (no formal evaluation process required). DNR approved the eight well applications after it received information that the wells would negatively impact the environment, and concluded that, because there was no formal process required for the approval of these wells, it had no authority to consider the proposed wells' environmental effects. The Supreme Court concluded that the DNR does have authority to consider the environmental effects of proposed high capacity wells, because in Wis. Stat. Sect. 281.12 the legislature grants the DNR broad and explicit authority to consider the environmental effects of any proposed high capacity well. Just because the wells in question weren't required to undergo a specific evaluation process, does not mean that they should not be evaluated with respect to their effect on the environment. The Supreme Court relied on both the explicit authority in the statute, and the public trust doctrine, pursuant to which the DNR is entrusted with preserving and protecting Wisconsin's navigable waters, to reach its conclusion.
Link to Opinion
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Clean Wis., Inc. v. Wis. Dep't of Nat. Res., 961 N.W.2d 346 (Wis. 2021)
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Wisconsin | 2021 | Environment, Pollution/Contamination, Actions Against Government |
State:
Wisconsin
Year:
2021
Topics:
Environment, Pollution/Contamination, Actions Against Government
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Wisconsin Department of Natural Resources (DNR) approved a dairy farm's (Kinnard's) application to expand its operation to build a second site and add 3,000 dairy cows. The application required that Kinnard also apply for a reissuance of its Wisconsin Pollutant Discharge Elimination Permit System (WPDES) permit for the expanded operation. The DNR approved both. The petitioners-environmental advocacy organizations in this appeal (collectively "Clean Wisconsin") sought review of the issuance of the WPDES permit because they lived near the dairy operation, had private drinking wells, and were concerned that the expansion would increase the risk of groundwater contamination issues. Clean Wisconsin alleged that the reissued permit was inadequate because it did not set a "maximum number of animal units" or "require monitoring to evaluate impacts to groundwater." The petition was initially heard before an administrative law judge (ALJ), who heard testimony from community members who spoke to the preexisting contamination issues from the Kinnard farm and its impact on their businesses, homes, and lives. The community members all cited the farm as the source of the contamination. Experts also testified on contamination in the community, including that 50% of the private wells in the town were contaminated, 30% had tested positive for E. coli bacteria, and that the land of the Kinnard operation was extremely susceptible to groundwater contamination. Based on this evidence, the ALJ concluded that DNR should have imposed an "animal unit maximum" to cap the number of animals allowed at the dairy operation, and imposed a groundwater monitoring plan to ensure that the Kinnard farm was meeting its legal obligation under Wis. Admin. Code Sect. NR 243.14(2)(b) to not contaminate well water with manure. The ALJ ordered that the DNR modify the permit with these two measures, the DNR implemented them, and Kinnard farm appealed the implementation. The Supreme Court considered whether the DNR had the explicit authority to implement each of these standards. Kinnard argued that Wisc. Stat. Sect. 227.10(2m) did not explicitly authorize the DNR to impose the two modifications to the WPDES permit, but the DNR and Clean Wisconsin argued that Wisc. Stat. Sect. 283.31(3) allowed the DNR to issue permits for "the discharge of any pollutant, or combination of pollutants..." such that the permit complied with "groundwater protection standards." Because both the animal unit maximum and the groundwater monitoring plan were imposed to protect the town's groundwater, the Supreme Court found that under Wisc. Stat. Sect. 283.31, the DNR had explicit authority to impose both modifications to the reissued permit.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The Wisconsin Department of Natural Resources (DNR) approved a dairy farm's (Kinnard's) application to expand its operation to build a second site and add 3,000 dairy cows. The application required that Kinnard also apply for a reissuance of its Wisconsin Pollutant Discharge Elimination Permit System (WPDES) permit for the expanded operation. The DNR approved both. The petitioners-environmental advocacy organizations in this appeal (collectively "Clean Wisconsin") sought review of the issuance of the WPDES permit because they lived near the dairy operation, had private drinking wells, and were concerned that the expansion would increase the risk of groundwater contamination issues. Clean Wisconsin alleged that the reissued permit was inadequate because it did not set a "maximum number of animal units" or "require monitoring to evaluate impacts to groundwater." The petition was initially heard before an administrative law judge (ALJ), who heard testimony from community members who spoke to the preexisting contamination issues from the Kinnard farm and its impact on their businesses, homes, and lives. The community members all cited the farm as the source of the contamination. Experts also testified on contamination in the community, including that 50% of the private wells in the town were contaminated, 30% had tested positive for E. coli bacteria, and that the land of the Kinnard operation was extremely susceptible to groundwater contamination. Based on this evidence, the ALJ concluded that DNR should have imposed an "animal unit maximum" to cap the number of animals allowed at the dairy operation, and imposed a groundwater monitoring plan to ensure that the Kinnard farm was meeting its legal obligation under Wis. Admin. Code Sect. NR 243.14(2)(b) to not contaminate well water with manure. The ALJ ordered that the DNR modify the permit with these two measures, the DNR implemented them, and Kinnard farm appealed the implementation. The Supreme Court considered whether the DNR had the explicit authority to implement each of these standards. Kinnard argued that Wisc. Stat. Sect. 227.10(2m) did not explicitly authorize the DNR to impose the two modifications to the WPDES permit, but the DNR and Clean Wisconsin argued that Wisc. Stat. Sect. 283.31(3) allowed the DNR to issue permits for "the discharge of any pollutant, or combination of pollutants..." such that the permit complied with "groundwater protection standards." Because both the animal unit maximum and the groundwater monitoring plan were imposed to protect the town's groundwater, the Supreme Court found that under Wisc. Stat. Sect. 283.31, the DNR had explicit authority to impose both modifications to the reissued permit.
Link to Opinion
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Clean Air Council v. Dep't of Env't Prot., 289 A.3d 928 (Pa. 2023).
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Pennsylvania | 2023 | Environment, Pollution/Contamination, Actions Against Government |
State:
Pennsylvania
Year:
2023
Topics:
Environment, Pollution/Contamination, Actions Against Government
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThis case involved a challenge to the Environmental Hearing Board's (Board) rule that a private party to an appeal before the Board may not be compelled to reimburse another party unless it pursued or defended the appeal in bad faith or for an improper purpose. The Supreme Court held that this rule was incompatible with Pennsylvania's Clean Streams Law. This decision makes it easier for members of the public to get reimbursed for legal costs when they are harmed by polluters and bring successful lawsuits.
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Justice Vote Breakdown
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Summary of Case Context & Holding
This case involved a challenge to the Environmental Hearing Board's (Board) rule that a private party to an appeal before the Board may not be compelled to reimburse another party unless it pursued or defended the appeal in bad faith or for an improper purpose. The Supreme Court held that this rule was incompatible with Pennsylvania's Clean Streams Law. This decision makes it easier for members of the public to get reimbursed for legal costs when they are harmed by polluters and bring successful lawsuits.
Link to Opinion
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Clarke v. Fine Hous., Inc., 882 S.E.2d 763 (S.C. 2023)
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South Carolina | 2023 | Housing, Landlord Rights |
State:
South Carolina
Year:
2023
Topics:
Housing, Landlord Rights
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingBarry Clarke sued Fine Housing, Inc. for specific performance of a right of first refusal (ROFR). Clarke, who owned a strip club, had a recorded lease with Group Investment Company, Inc. for half the parking spaces at 2028 Pittsburgh Avenue. Section 1.1 of the Lease states the Lessee rents the property described in Exhibit A. Section 2.1, in turn, defines the premises as unimproved parking spaces for shared use by both parties. Section 7.1 grants each party use of half the parking spaces, and Clarke admitted his rights were limited to the parking spaces during the Lease term. However, Clarke argued Section 5.2 of the Lease provided him with a ROFR to buy the entire Subject Property. Section 5.2 states, “Right of First Refusal: Lessor grants the Lessee the right of first refusal should it wish to sell." Section 5.2 did not specify whether the ROFR applied to the parking spaces or the entire Subject Property, nor did the Lease outline the purchase price or procedures for exercising the right. In 2007, Group Investment transferred the property to RRJR, LLC (RRJR) for $5. Clarke did not exercise his ROFR, claiming both entities were "the same people." In 2013, RRJR sold the property to Fine Housing for $150,000 without notifying Clarke. Clarke leaned of the sale in 2014 and filed an action for specific performance in 2015. The district court upheld the ROFR, but the court of appeals overturned the decision. Here, the South Carolina Supreme Court explained that the South Carolina common law right of first refusal requires the property owner, when they decide to sell, to first offer the property to the holder of the ROFR. This restrains an owner's power of alienation. There is a restatement factor test to determine whether a right of first refusal unreasonably restrains alienation. The factors include: (1) the legitimacy of the purpose of the right; (2) the price at which the right may be exercised; and (3) the procedures for exercising the right. Here, the Court held that the ROFR is an unreasonable restraint on alienation. First, the Court found that the Lease is unclear as to whether the ROFR encumbers all of the Subject Property or only the leased parking spaces, and this uncertainty as to what property is encumbered by the ROFR supports the conclusion that the ROFR is an unreasonable restraint on alienation. Second, the Court held that the complete absence of any method for determining price weighs in favor of a finding that the ROFR is an unreasonable restraint on alienation, because where a ROFR provides no price terms, a dispute may arise as to whether the holder of the right may purchase the property by matching a third-party offer or only after participating in a bidding war with other prospective buyers. Lastly, the Court held that the ROFR does not provide satisfactory procedures governing the exercise of the right.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Barry Clarke sued Fine Housing, Inc. for specific performance of a right of first refusal (ROFR). Clarke, who owned a strip club, had a recorded lease with Group Investment Company, Inc. for half the parking spaces at 2028 Pittsburgh Avenue. Section 1.1 of the Lease states the Lessee rents the property described in Exhibit A. Section 2.1, in turn, defines the premises as unimproved parking spaces for shared use by both parties. Section 7.1 grants each party use of half the parking spaces, and Clarke admitted his rights were limited to the parking spaces during the Lease term. However, Clarke argued Section 5.2 of the Lease provided him with a ROFR to buy the entire Subject Property. Section 5.2 states, “Right of First Refusal: Lessor grants the Lessee the right of first refusal should it wish to sell." Section 5.2 did not specify whether the ROFR applied to the parking spaces or the entire Subject Property, nor did the Lease outline the purchase price or procedures for exercising the right. In 2007, Group Investment transferred the property to RRJR, LLC (RRJR) for $5. Clarke did not exercise his ROFR, claiming both entities were "the same people." In 2013, RRJR sold the property to Fine Housing for $150,000 without notifying Clarke. Clarke leaned of the sale in 2014 and filed an action for specific performance in 2015. The district court upheld the ROFR, but the court of appeals overturned the decision. Here, the South Carolina Supreme Court explained that the South Carolina common law right of first refusal requires the property owner, when they decide to sell, to first offer the property to the holder of the ROFR. This restrains an owner's power of alienation. There is a restatement factor test to determine whether a right of first refusal unreasonably restrains alienation. The factors include: (1) the legitimacy of the purpose of the right; (2) the price at which the right may be exercised; and (3) the procedures for exercising the right. Here, the Court held that the ROFR is an unreasonable restraint on alienation. First, the Court found that the Lease is unclear as to whether the ROFR encumbers all of the Subject Property or only the leased parking spaces, and this uncertainty as to what property is encumbered by the ROFR supports the conclusion that the ROFR is an unreasonable restraint on alienation. Second, the Court held that the complete absence of any method for determining price weighs in favor of a finding that the ROFR is an unreasonable restraint on alienation, because where a ROFR provides no price terms, a dispute may arise as to whether the holder of the right may purchase the property by matching a third-party offer or only after participating in a bidding war with other prospective buyers. Lastly, the Court held that the ROFR does not provide satisfactory procedures governing the exercise of the right.
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Clark v. State, 883 S.E.2d 317 (Ga. 2023)
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Georgia | 2023 | Criminal Justice, Juvenile Justice |
State:
Georgia
Year:
2023
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingA jury found the Defendant guilty of felony murder and other crimes in connection with a shooting death of one individual and the aggravated assault of another. On appeal, the Defendant contented that the trial court applied the wrong standard when it admitted an audio recording of the Defendant’s interview with the lead investigator. The Defendant was 16 at the time of the recording and argued that because of his age, the trial court was required to consider the nine factors set out in Riley v. State to analyze whether the juvenile Defendant knowingly and voluntarily waived his Miranda rights. Riley v. State, 226 S.E.2d 922 (Ga. 1976). The factors that must be considered are as follows: (1) age of the accused; (2) education of the accused; (3) knowledge of the accused as to both the substance of the charge . . . and the nature of his rights to consult with an attorney and remain silent; (4) whether the accused is held incommunicado or allowed to consult with relatives, friends or an attorney; (5) whether the accused was interrogated before or after formal charges had been filed; (6) methods used in interrogations; (7) length of interrogations; (8) whether vel non the accused refused to voluntarily give statements on prior occasions; and (9) whether the accused has repudiated an extra judicial statement at a later date." Riley, 226 S.E.2d at 926. Taking this as an opportunity to clarify Riley and its progeny, the Supreme Court explained how the nine-factor framework is in tension with the totality-of-the-circumstances test for juvenile waiver set forth in Fare v. Michael C., 442 U.S. 707 (1979). Fare and Riley, taken together, stand for the proposition that, when a juvenile is involved, “the question of whether there was a knowing and intelligent waiver of constitutional rights depends on the totality of the circumstances surrounding a police interrogation.” Norris v. State, 651 S.E.2d 40, 41 (Ga. 2007). Because the proper application of a totality of the circumstances test requires inquiry into matters that may fall outside of Riley’s 9 factors, the Court disapproved decisions post-Riley that indicated the framework is required for the analysis. Going forward, Georgia courts will no longer be required to consider Riley's framework. Instead, the issue of whether a juvenile voluntarily and knowingly waived his or her Miranda rights depends on the totality of the circumstances. Because the trial court applied that approach, the Defendant’s claim failed on appeal.
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Justice Vote Breakdown
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Summary of Case Context & Holding
A jury found the Defendant guilty of felony murder and other crimes in connection with a shooting death of one individual and the aggravated assault of another. On appeal, the Defendant contented that the trial court applied the wrong standard when it admitted an audio recording of the Defendant’s interview with the lead investigator. The Defendant was 16 at the time of the recording and argued that because of his age, the trial court was required to consider the nine factors set out in Riley v. State to analyze whether the juvenile Defendant knowingly and voluntarily waived his Miranda rights. Riley v. State, 226 S.E.2d 922 (Ga. 1976). The factors that must be considered are as follows: (1) age of the accused; (2) education of the accused; (3) knowledge of the accused as to both the substance of the charge . . . and the nature of his rights to consult with an attorney and remain silent; (4) whether the accused is held incommunicado or allowed to consult with relatives, friends or an attorney; (5) whether the accused was interrogated before or after formal charges had been filed; (6) methods used in interrogations; (7) length of interrogations; (8) whether vel non the accused refused to voluntarily give statements on prior occasions; and (9) whether the accused has repudiated an extra judicial statement at a later date." Riley, 226 S.E.2d at 926. Taking this as an opportunity to clarify Riley and its progeny, the Supreme Court explained how the nine-factor framework is in tension with the totality-of-the-circumstances test for juvenile waiver set forth in Fare v. Michael C., 442 U.S. 707 (1979). Fare and Riley, taken together, stand for the proposition that, when a juvenile is involved, “the question of whether there was a knowing and intelligent waiver of constitutional rights depends on the totality of the circumstances surrounding a police interrogation.” Norris v. State, 651 S.E.2d 40, 41 (Ga. 2007). Because the proper application of a totality of the circumstances test requires inquiry into matters that may fall outside of Riley’s 9 factors, the Court disapproved decisions post-Riley that indicated the framework is required for the analysis. Going forward, Georgia courts will no longer be required to consider Riley's framework. Instead, the issue of whether a juvenile voluntarily and knowingly waived his or her Miranda rights depends on the totality of the circumstances. Because the trial court applied that approach, the Defendant’s claim failed on appeal.
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Clark Fork Coal. v. Mont. Dep’t of Nat. Res. and Conservation, 481 P.3d 198 (Mont. 2021)
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Montana | 2021 | Environment, Water Rights, Actions against the government |
State:
Montana
Year:
2021
Topics:
Environment, Water Rights, Actions against the government
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Montana Supreme Court upheld a Montana Department of Natural Resources and Conservation (DNRC) decision to grant RC Resources, Inc. (RCR) a water use permit under the Montana Water Use Act (MWUA), which governs who, how much, and for what purpose persons may use water in Montana. In doing so, the Supreme Court reversed the decision of the district court striking down the permit thereby rejecting the district court's conclusion that the "legal demands" language of the MWUA required the DNRC to evaluate consumer classification-based nondegredation standards under the Montana Water Quality Act (MWQA), given such were relevant to water quality rather than water availability, which was the subject of the MWUA. The Supreme Court further rejected arguments by the objectors to the permit that the MWUA violated their right to a clean and healthful environment under the state constitution, by denying them an opportunity for advance MWQA compliance review by DNRC as part of the MWUA water use permitting process, given the permit at issue did not authorize degradation of affected surface waters subject to advance environmental review and regulation under more specifically-applicable state and federal regulations. Indeed, the MWUA permit at issue only gave RCR the right to appropriate and use a particular quantum of water for a proposed use and did not directly authorize the mining activity which would be the direct cause of any potential degradation, whether by contaminant discharge or groundwater depletion. If and when the proposed use— i.e. the mining—was independently authorized to proceed it would be subject to a Montana Metal Reclamation Act (MMRA) review, which would incorporate review of the use with MWQA nondegredation standards. Accordingly, the Court found that the limited scope of the MWQA review, in connection with issuance of the MWUA Permit, did not substantially interfere with objectors' right to a clean and healthful environment under the constitution.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The Montana Supreme Court upheld a Montana Department of Natural Resources and Conservation (DNRC) decision to grant RC Resources, Inc. (RCR) a water use permit under the Montana Water Use Act (MWUA), which governs who, how much, and for what purpose persons may use water in Montana. In doing so, the Supreme Court reversed the decision of the district court striking down the permit thereby rejecting the district court's conclusion that the "legal demands" language of the MWUA required the DNRC to evaluate consumer classification-based nondegredation standards under the Montana Water Quality Act (MWQA), given such were relevant to water quality rather than water availability, which was the subject of the MWUA. The Supreme Court further rejected arguments by the objectors to the permit that the MWUA violated their right to a clean and healthful environment under the state constitution, by denying them an opportunity for advance MWQA compliance review by DNRC as part of the MWUA water use permitting process, given the permit at issue did not authorize degradation of affected surface waters subject to advance environmental review and regulation under more specifically-applicable state and federal regulations. Indeed, the MWUA permit at issue only gave RCR the right to appropriate and use a particular quantum of water for a proposed use and did not directly authorize the mining activity which would be the direct cause of any potential degradation, whether by contaminant discharge or groundwater depletion. If and when the proposed use— i.e. the mining—was independently authorized to proceed it would be subject to a Montana Metal Reclamation Act (MMRA) review, which would incorporate review of the use with MWQA nondegredation standards. Accordingly, the Court found that the limited scope of the MWQA review, in connection with issuance of the MWUA Permit, did not substantially interfere with objectors' right to a clean and healthful environment under the constitution.
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Clark Cnty. v. Bean, 482 P.3d 1207 (Nev. 2020)
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Nevada | 2020 | Labor, Employment & Economic Justice |
State:
Nevada
Year:
2020
Topics:
Labor, Employment & Economic Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingA retired firefighter sought permanent partial disability benefits under a previous version of the governing Nevada statute. The retiree argued that the reasoning in DeMaranville v. Employers Insurance Co. of Nevada, 448 P.3d 526 (Nev. 2019) (DeMaranville) controlled (concluding that a retiree was entitled to death benefits based on the wages earned immediately before retirement) and that he was entitled to a benefits award, while Clark County argued that the reasoning in Howard v. City of Las Vegas, 120 P.3d 410, 412 (Nev. 2005) controlled (concluding that a workers' compensation claimant is not entitled to total temporary disability benefits for an occupational disease manifesting after retirement), negating any benefits award. The Supreme Court held that DeMaranville's analysis of compensation for death benefits (retiree died from a compensable occupational disease years after retiring) was applicable because the regulation governing the calculation of compensation for both types of benefits is the same and that compensation for the employee's permanent partial disability rating must be based on the wages he earned before retiring.
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Justice Vote Breakdown
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Summary of Case Context & Holding
A retired firefighter sought permanent partial disability benefits under a previous version of the governing Nevada statute. The retiree argued that the reasoning in DeMaranville v. Employers Insurance Co. of Nevada, 448 P.3d 526 (Nev. 2019) (DeMaranville) controlled (concluding that a retiree was entitled to death benefits based on the wages earned immediately before retirement) and that he was entitled to a benefits award, while Clark County argued that the reasoning in Howard v. City of Las Vegas, 120 P.3d 410, 412 (Nev. 2005) controlled (concluding that a workers' compensation claimant is not entitled to total temporary disability benefits for an occupational disease manifesting after retirement), negating any benefits award. The Supreme Court held that DeMaranville's analysis of compensation for death benefits (retiree died from a compensable occupational disease years after retiring) was applicable because the regulation governing the calculation of compensation for both types of benefits is the same and that compensation for the employee's permanent partial disability rating must be based on the wages he earned before retiring.
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Clark Cnty. Sch. Dist. v. Payo, 403 P.3d 1270 (Nev. 2017)
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Nevada | 2017 | Health Care, Public Health |
State:
Nevada
Year:
2017
Topics:
Health Care, Public Health
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingA middle school student injured his eye while participating in a floor hockey game during his mandatory physical education class. As a result of his injury, Payo required eye surgery and follow-up care in the following years. Eight years after the initial injury, the now-adult Payo filed a complaint against the school district alleging negligence, negligent infliction of emotional distress, negligence per se, and negligent supervision. Upon motion by the school district, the district court dismissed the claims of negligent infliction of emotional distress and negligence per se, while maintaining the claims of negligence and negligent supervision. Following trial, the jury found in favor of Payo and awarded damages. The School District appealed, arguing that the former student's claims were barred under the implied assumption of risk doctrine, that the claims should have been dismissed under the discretionary-function-immunity doctrine (where government defendants enjoy immunity from negligence claims for discretionary functions when the defendant has relied on some policy consideration in exercising their discretion), and that the evidence presented had not supported a finding of proximate causation. First, the Supreme Court held that the implied assumption of risk doctrine does not apply when individuals are required to participate in physical education activities and there is no voluntary exposure to a risk. Second, the Court further held that the discretionary-function-immunity applied to the school district's decision to add floor hockey to its curriculum and to not provide safety equipment. Nonetheless, this immunity did not excuse liability for allegedly negligent administration, instruction, and supervision of the physical education curriculum. Finally, the Court held that Payo had failed to provide sufficient evidence to support a finding of proximate causation. While Payo had presented evidence indicating that certain parts of the floor hockey game were improper and outside the scope of the district's rules (such as team size, type of ball used, supervision, etc.), Payo had not demonstrated that any of these were the cause of, or contributed to, the injuries sustained. Lacking proximate causation, the jury could not have properly reached a negligence verdict on the evidence provided.
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Justice Vote Breakdown
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Summary of Case Context & Holding
A middle school student injured his eye while participating in a floor hockey game during his mandatory physical education class. As a result of his injury, Payo required eye surgery and follow-up care in the following years. Eight years after the initial injury, the now-adult Payo filed a complaint against the school district alleging negligence, negligent infliction of emotional distress, negligence per se, and negligent supervision. Upon motion by the school district, the district court dismissed the claims of negligent infliction of emotional distress and negligence per se, while maintaining the claims of negligence and negligent supervision. Following trial, the jury found in favor of Payo and awarded damages. The School District appealed, arguing that the former student's claims were barred under the implied assumption of risk doctrine, that the claims should have been dismissed under the discretionary-function-immunity doctrine (where government defendants enjoy immunity from negligence claims for discretionary functions when the defendant has relied on some policy consideration in exercising their discretion), and that the evidence presented had not supported a finding of proximate causation. First, the Supreme Court held that the implied assumption of risk doctrine does not apply when individuals are required to participate in physical education activities and there is no voluntary exposure to a risk. Second, the Court further held that the discretionary-function-immunity applied to the school district's decision to add floor hockey to its curriculum and to not provide safety equipment. Nonetheless, this immunity did not excuse liability for allegedly negligent administration, instruction, and supervision of the physical education curriculum. Finally, the Court held that Payo had failed to provide sufficient evidence to support a finding of proximate causation. While Payo had presented evidence indicating that certain parts of the floor hockey game were improper and outside the scope of the district's rules (such as team size, type of ball used, supervision, etc.), Payo had not demonstrated that any of these were the cause of, or contributed to, the injuries sustained. Lacking proximate causation, the jury could not have properly reached a negligence verdict on the evidence provided.
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Clark Cnty. Sch. Dist. (CCSD) v. Bryan, 478 P.3d 344 (Nev. 2020)
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Nevada | 2020 | LGBTQ+ Rights, LGBTQ+ Youth, LGBTQ+ Discrimination |
State:
Nevada
Year:
2020
Topics:
LGBTQ+ Rights, LGBTQ+ Youth, LGBTQ+ Discrimination
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPlaintiffs sued a school district for student-on-student harassment after two sixth-graders targeted Plaintiffs' children with sexual slurs, other insults, and physical assaults under 20 U.S.C. § 1681 (Title IX), which prohibits discrimination on the basis of sex. Plaintiffs also claimed the school district failed to conduct an official investigation as required under Nevada law (Nev. Rev. Stat. Ann. § 388.1351) or to prevent continued harassment. The trial court found for Plaintiffs and the school district appealed. The Supreme Court held, in relevant part, that Title IX's protections against sex-based discrimination extend to prohibit discrimination against homosexual and transgender individuals and discrimination based on perceived sexual orientation, as in both situations the perpetrator's view of the victim's sexual orientation is a factor motivating the harassment. The case was reversed and remanded on other grounds.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Plaintiffs sued a school district for student-on-student harassment after two sixth-graders targeted Plaintiffs' children with sexual slurs, other insults, and physical assaults under 20 U.S.C. § 1681 (Title IX), which prohibits discrimination on the basis of sex. Plaintiffs also claimed the school district failed to conduct an official investigation as required under Nevada law (Nev. Rev. Stat. Ann. § 388.1351) or to prevent continued harassment. The trial court found for Plaintiffs and the school district appealed. The Supreme Court held, in relevant part, that Title IX's protections against sex-based discrimination extend to prohibit discrimination against homosexual and transgender individuals and discrimination based on perceived sexual orientation, as in both situations the perpetrator's view of the victim's sexual orientation is a factor motivating the harassment. The case was reversed and remanded on other grounds.
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City of Surprise v. Ariz. Corp. Comm'n, 437 P.3d 865 (Ariz. 2019)
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Arizona | 2019 | Environment, Actions against Government |
State:
Arizona
Year:
2019
Topics:
Environment, Actions against Government
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIn 2017, City of Surprise documented its intent to condemn the assets of Circle City Water Company (City Circle), a public service corporation. A residential developer contended that “Circle City [was] obliged under an existing contract to allocate its . . . water for a planned development” and asked the Arizona Corporation Commission (ACC) to step in after Surprise stated it had no obligation to provide water under the contract. ACC ordered Circle City to file an application to seek authorization from ACC to go forward with its transfer of assets to Surprise and requested a copy of the draft condemnation agreement and a writing to confirm whether Surprise would “assume Circle City’s water contract with the developer.” Surprise filed a special action, alleging that the Commission “acted without jurisdiction” in entering its order. The Arizona Supreme Court accepted original jurisdiction over this special action to determine whether a state law that restricts the sale transfer of assets of a utility allows the ACC to condemn the utility and force a transfer. A.R.S § 40-285 provides, "[a] public service corporation shall not sell, lease, assign, mortgage or otherwise dispose of . . . its . . . system . . . without first having secured from the commission an order authorizing it so to do.” The Supreme Court held that the statute does “not give the Commission power over a city’s exercise of eminent domain” and that the ACC "has no role to play in condemnations." Because the statute does not contemplate condemnation, the Supreme Court held that the interpretation of ACC's authority turns on the words "otherwise dispose of" since condemnation is neither sale not a voluntary transfer. The Supreme Court held that condemnations are not covered by the statute since “sell, lease, assign” and “mortgage” are all voluntary transactions, and a condemnation, in contrast, is an involuntary governmental taking of assets.
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Justice Vote Breakdown
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Summary of Case Context & Holding
In 2017, City of Surprise documented its intent to condemn the assets of Circle City Water Company (City Circle), a public service corporation. A residential developer contended that “Circle City [was] obliged under an existing contract to allocate its . . . water for a planned development” and asked the Arizona Corporation Commission (ACC) to step in after Surprise stated it had no obligation to provide water under the contract. ACC ordered Circle City to file an application to seek authorization from ACC to go forward with its transfer of assets to Surprise and requested a copy of the draft condemnation agreement and a writing to confirm whether Surprise would “assume Circle City’s water contract with the developer.” Surprise filed a special action, alleging that the Commission “acted without jurisdiction” in entering its order. The Arizona Supreme Court accepted original jurisdiction over this special action to determine whether a state law that restricts the sale transfer of assets of a utility allows the ACC to condemn the utility and force a transfer. A.R.S § 40-285 provides, "[a] public service corporation shall not sell, lease, assign, mortgage or otherwise dispose of . . . its . . . system . . . without first having secured from the commission an order authorizing it so to do.” The Supreme Court held that the statute does “not give the Commission power over a city’s exercise of eminent domain” and that the ACC "has no role to play in condemnations." Because the statute does not contemplate condemnation, the Supreme Court held that the interpretation of ACC's authority turns on the words "otherwise dispose of" since condemnation is neither sale not a voluntary transfer. The Supreme Court held that condemnations are not covered by the statute since “sell, lease, assign” and “mortgage” are all voluntary transactions, and a condemnation, in contrast, is an involuntary governmental taking of assets.
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City of Pittsburgh v. Fraternal Ord. of Police, Fort Pitt Lodge No. 1, 224 A.3d 702 (Pa. 2020)
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Pennsylvania | 2020 | Labor, Employment & Economic Justice, Collective Bargaining |
State:
Pennsylvania
Year:
2020
Topics:
Labor, Employment & Economic Justice, Collective Bargaining
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingA police union challenged the City of Pittsburg’s failure to pay appropriate overtime through arbitration and won. The City of Pittsburg challenged the arbitrator’s decision as legally flawed. The Supreme Court held that even if incorrect, the arbitrator’s decision was binding on the City of Pittsburg. The Policemen and Firemen Collective Bargaining Act (Act 111) has a strong presumption in favor of finality for arbitration awards, which may only be vacated in instances of overt reform of a collective bargaining agreement, not because of the arbitrator’s erroneous interpretations or applications of law
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Justice Vote Breakdown
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Summary of Case Context & Holding
A police union challenged the City of Pittsburg’s failure to pay appropriate overtime through arbitration and won. The City of Pittsburg challenged the arbitrator’s decision as legally flawed. The Supreme Court held that even if incorrect, the arbitrator’s decision was binding on the City of Pittsburg. The Policemen and Firemen Collective Bargaining Act (Act 111) has a strong presumption in favor of finality for arbitration awards, which may only be vacated in instances of overt reform of a collective bargaining agreement, not because of the arbitrator’s erroneous interpretations or applications of law
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