Justia Criminal Law Opinion Summaries

Appellant raped and brutally murdered three women in separate incidents over a one-year span. Prior to the capital murder trial, appellant pled guilty to three counts of burglary, two counts of attempted criminal homicide, and two counts of firearms not to be carried without a license. The jury returned a guilty verdict of first-degree murder for each murder as well as guilty verdicts on all remaining charges. Appellant appealed a Court of Common Pleas order his first petition for relief. Finding that appellant did not meet his burden for relief, the Supreme Court affirmed the PCRA court. View "Pennsylvania v. Robinson" on Justia Law

Appellant Harold Murray, IV, appealed the death sentence he received for his conviction on three counts of first degree murder. Upon review of the facts of this case, the Supreme Court affirmed the convictions, but vacated the death sentence. The case was remanded for a new penalty hearing. View "Pennsylvania v. Murray IV" on Justia Law

Appellant Guillermo Ramos entered an open guilty plea to charges of Manufacturing of a Controlled Substance (Marijuana) and Possession with Intent to Deliver a Controlled Substance (Marijuana) (PWID) both of which were violations of 35 P.S. 780-113(a)(30). The Commonwealth provided written notice that it intended to proceed under the mandatory sentencing provision of 42 Pa.C.S. 9712.1 and 35 Pa.C.S. 780-113(a)(30) with regard to Ramos’s guilty plea to the PWID count. The trial court sentenced Ramos to an aggregate sentence of five months to ten years in prison. Specifically, Ramos received nine months to five years in prison on the Manufacturing of a Controlled Substance (Marijuana) conviction to run concurrently with a term of five months to ten years in prison on the PWID conviction. In an amended sentencing order after stating its belief that the sentence it had imposed on the PWID count exceeded the allowable statutory maximum, the sentencing court modified the sentence for that conviction to a flat, five year prison term which it deemed to be a mandatory sentence pursuant to 42 Pa.C.S. 9712.1. The Superior Court unanimously affirmed his judgment of sentence in an unpublished memorandum opinion. Ramos challenged on appeal to the Supreme Court the legality of imposing a mandatory minimum sentence pursuant to 42 Pa.C.S. 9712.1. After review, the Supreme Court concluded that as the most recent and the specific statute, 42 Pa.C.S. 9712.1 controlled in this case. Accordingly, under 1 Pa.C.S. 1933, the general provision of 42 Pa.C.S. 9756(b)(1) must yield to the specific sentencing provisions of Section 9712.1(a) and Section 780-113(f)(2), respectively requiring a five-year mandatory minimum sentence and a maximum sentence of no more than five years for a violation of Section 780-113(a)(30). As such, the trial court properly imposed a flat, five-year prison sentence for Ramos’s PWID conviction. View "Pennsylvania v. Ramos" on Justia Law

The issue on appeal before the Supreme Court in this matter involved questions of statutory construction pertaining to the five-year mandatory minimum sentence attaching to the offense of possession of a controlled substance with intent to deliver while in possession or control of a firearm. Specifically, the Supreme Court considered the meaning of the terms "control of a firearm" and "close proximity," as used in Section 9712.1(a), including the interrelationship between "control" and the concept of constructive possession as it appears in several Superior Court decisions. Appellant was charged with PWID, simple possession, possession of drug paraphernalia, and possession of an instrument of crime (the handgun). At a pre-trial conference, Appellant argued that the charge of possession of an instrument of crime should have been quashed, "given [the] lack of nexus between [Appellant] and that weapon and someone else's room." A common pleas judge quashed the charge, without explaining the reasoning underlying such ruling. The Supreme Court remanded the case for resentencing, with the admonition that imposition of the mandatory sentence under Section 9712.1(a) was not foreclosed. Should the lower court determine that the Commonwealth did not establish by a preponderance that Appellant was in constructive control of the firearm, the court should implement individualized sentencing, "per the usual practices." View "Pennsylvania v. Hanson" on Justia Law

Appellant Robert Diamond received two death sentences after pleading guilty to the first degree murders of Angel Guadalupe and Reginald Woodson. Appellant claimed on appeal that the trial court erred in the penalty phase, erred in finding statutory aggravating circumstances, erred in failing to find mitigating circumstances, erred in its weighing of aggravating and mitigating circumstances, and that his sentence was based on arbitrary factors. Finding no merit to appellant's challenges, the Supreme Court affirmed his conviction and judgment of sentence. View "Pennsylvania v. Diamond" on Justia Law

Appellant was convicted on two counts of first-degree murder for the shooting deaths of Mendez Thomas and Lisa Diaz. On appeal, appellant challenged the sufficiency of the evidence presented against him at trial. After review of the trial court record, the Supreme Court found the evidence sufficient to support appellant's murder convictions. View "Pennsylvania v. Sanchez" on Justia Law

Appellant Alexander Keaton appealed the denial of his petition for post-conviction relief. He claimed the PCRA court erroneously denied the underlying claim that his invoking a Fifth Amendment right to counsel during custodial interrogations on a rape charge invalidated his uncounseled, incriminating statements given weeks later in an unrelated murder and rape case. Upon review of the matter, the Supreme Court found appellant never invoked his right to counsel in the initial rape case, and as such, the PCRA court did not err in denying appellant relief. View "Pennsylvania v. Keaton" on Justia Law

The issue before the Supreme Court in this case centered on the proper scope of the “illegal sentence” doctrine. The Superior Court held that the claim at the heart of this appeal, implicated the legality of appellee’s sentence; found that the claim was meritorious; vacated appellee’s aggravated assault conviction; and then directed that the principle of double jeopardy precluded appellee from being recharged in connection with the assault. The Supreme Court addressed the question of whether the claim was subject to waiver. The Court found that appellee’s claim concerning her underlying conviction for aggravated assault did not implicate the legality of the sentence for purposes of issue preservation. Accordingly, the Court vacated the Superior Court's order and remanded the case back to to that court for consideration of appellee’s remaining appellate claims. View "Pennsylvania v. Spruill" on Justia Law

The Commonwealth appealed a court of common pleas order that declared Section 9543(a)(1)(i) of the Post-Conviction Relief Act (PCRA) was unconstitutional as applied to Petitioner Emma Turner. The PCRA court held that barring Petitioner from obtaining collateral relief on her timely claim of trial counsel ineffectiveness because she had completed serving her sentence, as Section 9543(a)(1)(i) requires, would violate Petitioner’s constitutional due process right to be heard on this issue. The PCRA court, therefore, permitted Petitioner to proceed with her PCRA petition, despite her ineligibility under Section 9543(a)(1)(i), granted an evidentiary hearing, and ultimately awarded her a new trial. Because the Supreme Court concluded that Petitioner had no due process right to be heard outside of the limits imposed by Section 9543(a)(1)(i) of the PCRA, and that she had the opportunity to attempt to vindicate her claim on direct appeal under "Commonwealth v. Bomar," (826 A.2d 831 (Pa. 2003)), or within the time frame permitted by the PCRA, the Court reversed the PCRA court's decision and held that this section was constitutional as applied to Petitioner. View "Pennsylvania v. Turner" on Justia Law

In 1994, Appellee Joseph Elliott was convicted of the first degree murder of Kimberly Griffith, and sentenced to death. Following the denial of relief on direct appeal, appellee filed a petition for collateral relief. Without holding an evidentiary hearing, the Court of Common Pleas of Philadelphia County (the PCRA court) granted appellee a new trial on the following grounds: (1) that trial counsel was ineffective for failing to prepare for trial or interview appellee in person prior to trial; and (2) that trial counsel was ineffective for failing to object to the medical examiner’s testimony regarding the estimated time of the victim’s death. The PCRA court denied appellant relief on his remaining claims. The Commonwealth appealed the PCRA court’s grant of a new trial, and appellee filed a cross-appeal from the denial of relief on his other issues. After careful consideration of the PCRA Court record, the Supreme Court found appellee did not meet his burden to prove he received ineffective assistance of counsel, and that it was an error for the lower court to grant a new trial without an evidentiary hearing. Therefore the Supreme Court reversed the grant of a new trial, and affirmed the denial of relief on appellee's remaining claims. View "Pennsylvania v. Elliott" on Justia Law