Justia Criminal Law Opinion Summaries

The issue on appeal before the Supreme Court was whether it was possible, as a matter of law, to be convicted as an accomplice to third-degree murder. The Commonwealth presented evidence that the victim was lured to an apartment complex, where he was ambushed, shot, and mortally wounded. Appellant Stanley Roebuck participated with others in orchestrating the events, but he did not shoot the victim. For his role, Appellant was charged with, among other offenses, third degree murder. On appeal, Appellant argued that there is no rational legal theory to support accomplice liability for third-degree murder. The Superior Court affirmed Appellant's sentence. The Supreme Court granted discretionary review, and concluded that a conviction for murder of the third degree is supportable under complicity theory where the Commonwealth proves the accomplice acted with the culpable mental state required of a principal actor, namely, malice. In other words, the Pennsylvania Crimes Code legally, logically, and rationally imposes accomplice liability for depraved heart murder. The Court affirmed the superior court's decision.

Appellants Dawn Pyeritz sued the Commonwealth, the Pennsylvania State police and several of its police officers for the destruction of her personal property, speficially "a black nylon tree stand safety harness, or belt, that allegedly was crucial evidence in a separate civil action." The police seized this item during a criminal investigation of a suspicious death. A trooper agreed to retain the belt in the custody of the police, apparently for a longer time than permitted by internal police regulations. The belt was destroyed before Appellants' counsel asked for its return. The trial court granted summary judgment to the Appellees, which the Commonwealth Court affirmed. The Commonwealth Court held that no cause of action exists against a third party – someone other than the original alleged tortfeasor – for negligent spoliation of evidence. The Supreme Court granted review, and now holds that Pennsylvania law does not recognize a cause of action for negligent spoliation of evidence.

The issue before the Supreme Court was whether acceptance into an Accelerated Rehabilitative Disposition (ARD) program following a second charge of driving under the influence of alcohol (DUI) constituted a DUI violation and thus triggers the requirement for installation of an ignition interlock system as a condition of restoring a revoked driver's license. In 1998, Appellee John Whalen was convicted of DUI in Florida. Nine years later, Appellee was again arrested for DUI, this time in Pennsylvania. The trial court admitted Appellee into an ARD program after expressly making a determination that Appellee’s 1998 Florida DUI conviction did not present a bar to his entry into this program. Appellee successfully completed his ARD program. Pursuant to one provision of the ARD program, Appellee’s driver’s license was suspended for a period of sixty days, with the added condition that the ignition interlock be installed on his vehicle. Appellee appealed the ignition interlock requirement to the court of common pleas, arguing that the Department had no authority to impose this requirement in his case because ARD was not an adjudication of guilt. The Commonweath Court affirmed the DOT's decision. Upon reivew, the Supreme Court determined that the Commonwealth Court erred in its interpretation of the relevant statutory provisions when it concluded that acceptance into ARD did not establish a DUI violation. Accordingly, the Supreme Court reversed and remanded the case for further proceedings.

Appellant Terry Chamberlain appealed the death sentence imposed on him after a jury convicted him of two counts of first-degree murder, burglary and possessing "an instrument of crime" in 1994. On direct appeal, the Supreme Court held that the trial court abused its discretion in denying a pretrial motion for a continuance to allow Appellant to obtain DNA testing of certain blood evidence. The case was remanded for the trial court to allow Appellant to do the testing. The trial court completed proceedings on remand, and the case went back to the Supreme Court for its consideration on the remaining claims in Appellant's appeal. Upon review of those claims, the Court affirmed Appellant's death sentence.

The Supreme Court considered the effect of a pro se notice of appeal which was forwarded to the superior court by a counseled criminal defendant, where counsel, who was not made aware of the pro se notice, subsequently filed a timely post-sentence motion which was denied by the trial court, and then a second timely notice of appeal. In this case, the superior court administratively quashed the counseled-appeal as duplicative, then quashed Appellee Michael Cooper's pro se appeal as premature and void. Yet the court also remanded the case to the trial court for additional review of the counseled post-sentence motion. Upon review, the Supreme Court held that the superior court erred in quashing the appeal and remanding the counseled post-sentencing motion. Therefore, the Court vacated the order and remanded the case back to the superior court for consideration of the merits of Appellee's direct appeal.

n this appeal, the issue before the Supreme Court was whether the mere offer of an automobile ride to a child constituted an attempt to âlureâ the child under Section 2910 of Pennsylvaniaâs Criminal Code, entitled âLuring a child into a motor vehicle or structure.â Appellant was charged with four counts of harassment, stalking, and attempted luring of a child into a motor vehicle for offering two neighborhood boys a ride to school in Appellant's own neighborhood. He had seen the children in the neighborhood, and offered them short rides to school or to the store. The children declined, and Appellant made no further attempt to "help." Appellant was acquitted of the charged at a bench trial because the judge "expressly stated she found no evidence that Appellant had any intent to harm the children, and that she believed 'the circumstances show no reason to believe that this defendant had any evil or improper intent in doing what he did.'â However, on the sole basis of Appellantâs offer of the rides, she convicted him on all four counts of attempted luring. The trial court found that â[Appellantâs] offer of a ride to the victims is sufficient to constitute an attempt to âlure.ââ The trial court subsequently sentenced Appellant to 18 monthsâ probation. As an automatic result of his convictions, Appellant was statutorily mandated to register for ten years as a sex offender under Meganâs Law. Appellant filed an appeal to the Superior Court, arguing that the evidence was insufficient as a matter of law to sustain his conviction, because his offer of a ride to the children, by itself, did not constitute a âlureâ or an attempt to âlure,â given that he did not offer the children any enticement to get into his car, nor did he command or otherwise threaten them. Appellant also argued that he had no ill intent in offering the children a ride, but, rather, was merely acting as a âdisabled Good Samaritan.â After careful review, the Supreme Court concluded that an attempt to âlureâ does not include the action of simply extending an offer of an automobile ride to a child, when it is unaccompanied by any other enticement or inducement for the child to enter the motor vehicle. Consequently, the Court reversed Appellant's conviction for attempted luring.

Appellant Michael Travaglia appealed his death sentence imposed by the Westmoreland County Court of Common Pleas following a penalty hearing held pursuant to a grant of federal habeas corpus relief. Appellant was convicted in the shooting death of an Apollo police officer in 1980. Prior to the officer's homicide, state police received information indicating that Appellant was involved in a number of armed robberies and killings in Pittsburgh and surrounding counties. Appellant would later give a statement to police implicating himself in the killing of the officer and several others. Following the denial of his post-sentence motions Appellant appealed to the Supreme Court where he raised eighteen alleged errors in his penalty hearing. The Supreme Court took each issue in turn and ultimately affirmed Appellant's death sentence.

Sean Pearce was bicycling along a road when he collided with a construction barrel and fell into the road. At least two vehicles, one driven by Appellee Gregory Wisneski, subsequently fatally struck Pearce. Appellee later admitted driving along the road when, initially thinking he hit a speed bump, he looked in his mirror and saw a body in the road. Appellee did not stop at the scene. The Commonwealth charged Appellee with failing to stop at an accident, failing to comply with a duty to give information and render aid, and failing to immediately notify the police. Appellee filed a habeas petition seeking dismissal of the charges, arguing the Commonwealth could not prove Pearce was alive when Appellee struck him. The trial court concluded that the statutes required the victim to be alive at the time of the accident, reasoning that "once a victim of an accident is dead, the accident concludes that the statutes cannot apply to vehicles that later come upon the scene." A divided Superior Court affirmed the trial court's dismissal of the information against Appellee. Upon review, the Supreme Court found that "a person does not turn into mere property upon their death, certainly not for purposes of a driver's obligations under the Vehicle Code. We find, therefore, the term 'resulting in injury' must include causing harm or damage to the body of a human, whether deceased or not. To find otherwise would defeat the legislative scheme, and would be offensive to our notions of the value of the person." The Court reversed the Superior Court and remanded the case for further proceedings.

The issue central to this case was whether Appellee George Banks was competent to be executed. Appellee used a semi-automatic rifle to murder thirteen people and seriously wounded a fourteenth in an early morning shooting spree in 1982. Five of the victims were Appellee's children, and four were Appellee's former or then-current girlfriends. In 2004, the Supreme Court ordered the trial court to determine whether Appellee had the capacity to initiate clemency proceedings or to designate someone to initiate them on his behalf. "To say that [the Court's] direction for expedition went unheeded by [the trial court judge] would be an understatement." Clemency proceedings were delayed by federal counsel seeking to burden the Commonwealth's ability to have its mental health experts examine Appellee in order to prepare a case in rebuttal against counsel's claim that Appellee had become insane. The Court concluded that "the competency question [was] important, but narrow, and it should have been resolved sooner." Following the Court's review of the competency determination rendered by the trial court, the Court concluded that Appellee was incompetent to be executed under the standards set forth in Pennsylvania case law. "It appear[ed] that [Appellee was] in a different place mentally than he was nearly thirty years ago when he committed his crimes and when he was tried."

In 1999, a jury convicted Appellant Steven Hutchinson of first-degree murder and other crimes for the shooting death of one of his girlfriends. Appellant unsuccessfully filed a petition for post-conviction relief raising numerous guilt and penalty phase claims. On appeal to the Supreme Court, Appellant appealed the denial of his guilt phase claims, raising ten issues for the Courtâs review. Taking each in turn, the Supreme Court found sufficient evidence in the trial court and PCRA court records to support his conviction. Accordingly, the Court affirmed his conviction.