Justia Civil Rights Opinion Summaries

The case involves a petition challenging the public release of a grand jury report by the 30th County Investigating Grand Jury. The petitioner argued that the report did not meet the statutory definition of an "investigatory grand jury report" under the Investigatory Grand Jury Act (IGJA) and that the supervising judge erred in ordering its release. The petitioner also contended that the report's criticism of named, unindicted individuals violated their due process rights and the fundamental right to reputation under the Pennsylvania Constitution.The Philadelphia County Court of Common Pleas initially accepted the report and ordered its public release. The supervising judge provided notice and an opportunity to respond to some, but not all, named, unindicted individuals criticized in the report. The petitioner, along with others, sought to have the report permanently sealed or redacted. The supervising judge made some redactions but ultimately ordered the report to be unsealed.The Supreme Court of Pennsylvania reviewed the case and concluded that the report did not satisfy the IGJA's definition of an "investigatory grand jury report" because it neither related to organized crime or public corruption nor proposed recommendations for legislative, executive, or administrative action in the public interest. The court found that the report focused on punishing specific individuals and providing answers to the deceased-accused's family, rather than addressing broader public concerns.The court also determined that due process requires notice and an opportunity to respond for all named, unindicted individuals criticized in a grand jury report. The supervising judge's failure to provide such notice to all criticized individuals was deemed an error. Consequently, the Supreme Court vacated the supervising judge's order and remanded the case with instructions to permanently seal the report. View "In Re: The Thirtieth County Investigating Grand Jury" on Justia Law

Lisa Smith, the appellant, lived with her boyfriend, Keiff King, and her four-year-old son, Tahjir, in a home in Abington Township, Pennsylvania. On January 22, 2018, after Tahjir spilled cereal, he was subjected to severe punishment by Smith and King, including being forced to hold difficult positions and being beaten. Tahjir was also placed in a hot shower, resulting in severe burns. Later, when Tahjir showed signs of severe distress, Smith and King delayed seeking medical help. Eventually, Smith called 911, but Tahjir was pronounced dead at the hospital. An autopsy revealed that Tahjir died from "crush syndrome" due to severe beatings and burns.Smith and King were charged with first-degree murder, endangering the welfare of a child, and criminal conspiracy. Smith's motion to suppress her statements to the police was partially granted, excluding statements made before receiving Miranda warnings. At trial, King's redacted statement, which replaced Smith's name with feminine pronouns, was admitted. The trial court instructed the jury to consider King's statement only against him. Both Smith and King were convicted, and Smith was sentenced to life in prison without parole, plus additional years.The Supreme Court of Pennsylvania reviewed whether Smith's Sixth Amendment right to confrontation was violated by admitting King's redacted statement. The court held that there was no violation, as the redacted statement did not directly or powerfully implicate Smith in the crime. The court emphasized that the statement did not identify Smith as a participant in the abuse and that the jury was properly instructed to consider the statement only against King. Consequently, the court affirmed the Superior Court's decision, upholding Smith's conviction and sentence. View "Commonwealth v. Smith" on Justia Law

The Supreme Court of Pennsylvania held that the Pennsylvania Department of Corrections (DOC) had violated the procedural due process rights of an inmate, Thomas Washington. The DOC had increased the rate at which it garnished Washington’s prison account to pay for his court-ordered financial obligations, without giving him prior notice or an opportunity to challenge this increase. The court rejected the DOC's argument that the increase was mandated by a legislative amendment and that no discretion was available for the DOC to alter the rate. The court held that the amendment to the law did not remove the obligation for the DOC to follow due process requirements before increasing the rate of deductions from inmates' accounts. The court reversed the lower court's decision, which had dismissed Washington's complaint, and remanded the case for further proceedings. The court noted that even if Washington was not ultimately entitled to a return of the additional funds, he had a right to make his case before the increased deductions occurred. View "Washington v. PA Dept. of Corrections" on Justia Law

The Pennsylvania Supreme Court granted discretionary review to consider whether the Commonwealth Court erred when it applied the plurality’s analysis in Easton Area School District v. Miller, 232 A.3d 716 (Pa. 2020) (Easton Area II) and ordered redaction and disclosure of the school bus surveillance video it determined to be an education record subject to the Family Educational Rights and Privacy Act (FERPA). In 2016, Valerie Hawkins, on behalf of Fox 43 News (collectively, Requester), submitted a Right-to-Know Law (RTKL) request to Central Dauphin School District (the District), seeking a copy of school bus surveillance video which captured an incident between a 17-year-old member of a District high school basketball team (the student), and a parent of another player (the adult), who allegedly grabbed the student’s wrist during their interaction. The incident occurred in a parking lot outside the high school’s gymnasium, while the players and school staff were boarding the school bus following a basketball game. The adult involved received a summary citation for harassment related to the incident. Requester attached a copy of the citation notice from the magisterial district court record to the record request; the notice identified the adult and student by name as the defendant and victim, respectively. Karen McConnell, the District’s open records officer, denied the request for access to the video, explaining it was an education record containing “personally identifiable information directly related to a student or students,” which, according to the District, protected the video from release under FERPA, and consequently precluded its disclosure under the RTKL as well. The Supreme Court concluded the Commonwealth Court did not err when it applied the analysis articulated in Easton Area II and ordered the mandatory redaction and disclosure of a school bus surveillance video it determined to be an education record subject to FERPA. Accordingly, the Supreme Court affirmed the Commonwealth Court's order with instructions to the District to reasonably redact the students’ personally identifiable information prior to disclosure. View "Central Dauphin Sch. Dist. v. Hawkins, et al." on Justia Law

In late 2012, 16-year-old Shane McGuire and a group of his friends smashed pumpkins and stacked bricks on the doorstep of a home in McGuire’s neighborhood. The teens were still on the property when the homeowner, City of Pittsburgh Police Officer Colby Neidig, arrived home with his wife and children. McGuire watched the family’s reaction to the vandalism and then banged on the front door and ran away, accidentally tripping over his own brick boobytrap in the process. Neidig saw McGuire running, and gave chase, catching McGuire, knocking him to the ground and punching McGuire in the face. Neidig was not wearing his police uniform at the time, nor did he identify himself as a police officer. Neidig called 911 and restrained McGuire until Officer David Blatt, an on-duty City of Pittsburgh police officer, arrived. Two years later, McGuire filed a federal lawsuit against Neidig, Blatt, and the City of Pittsburgh, asserting excessive use of force in violation of 42 U.S.C. § 19833 and state law assault and battery claims. Ultimately, the jury returned a verdict in McGuire’s favor, finding that Neidig used unreasonable force against McGuire while acting under color of state law under Section 1983, and that Neidig was liable for McGuire’s assault and battery claims as well. The issue this case presented for the Pennsylvania Supreme Court's review involved whether the City of Pittsburgh had a statutory duty to indemnify one of its police officers for the judgment entered against him in a federal civil rights lawsuit. The Supreme Court rejected the argument that a federal jury’s finding that a police officer acted “under color of state law” for purposes of Section 19831 necessarily constituted a “judicial determination” that he also acted within the “scope of his office or duties” for purposes of the Political Subdivision Tort Claims Act. Thus, the judgment was affirmed. View "McGuire v. City of Pittsburgh" on Justia Law

On October 25, 2011, Appellant Nicole B.’s then-eight-year-old son N.B. was sexually assaulted by three of his male fourth-grade classmates in a bathroom at his public elementary school in the City of Philadelphia. According to Appellant, N.B. had endured two months of pervasive physical and verbal harassment at school leading up to the sexual assault. During that time, both Appellant and N.B. reported the harassment to his teacher and to school administrators, to no avail. In November 2011, Appellant withdrew N.B. from the elementary school after learning of the attack. Over two years later, in 2014, Appellant filed an administrative complaint with the Human Relations Commission against the Philadelphia School District (“District”) in her individual capacity and on N.B.’s behalf, asserting claims of discrimination on the basis of gender and race under the Pennsylvania Human Relations Act (“PHRA”). The Human Relations Commission rejected Appellant’s complaint as untimely, because it was filed beyond the 180-day time limit. In this appeal by allowance, the Pennsylvania Supreme Court considered whether principles of equitable tolling found in PHRA, or Pennsylvania’s Minority Tolling Statute (“Minority Tolling Statute”), applied to an otherwise untimely complaint. After review, the Supreme Court found the PHRA’s equitable tolling provision applied to a minor whose parent failed to satisfy the applicable statute of limitations for filing an administrative complaint prior to the minor reaching the age of majority. By this finding, the Court reversed the order of the Commonwealth Court. View "Nicole B. v. Philadelphia Sch. Dist., et al." on Justia Law

In this appeal by allowance, the issue presented for the Pennsylvania Supreme Court was whether application of the Pennsylvania Human Relations Act (“PHRA”) to the judicial branch of our tripartite form of government violated separation of powers principles. On April 3, 1989, the Lehigh County Court of Common Pleas (“CCP”) Office of Adult Probation hired Appellant Michael Renner as a Parole Officer. In July 2011, Appellant informed Lehigh County Chief Probation Officer John Sikora that he had been diagnosed with a serious mental health condition and was hospitalized; he was subsequently absent from work for 4 to 6 weeks. During Appellant’s absence, Sikora telephoned him numerous times to confirm the legitimacy of Appellant’s condition. Upon his return to work, Appellant alleged Sikora and Lehigh County Benefits Manager Mark Surovy, both of whom supervised Appellant, pressured Appellant to resign or take a leave of absence. Appellant confronted Sikora about his hostilities towards him, but Sikora refused to discuss the matter. Subsequently, in March 2014, Sikora terminated Appellant for failing to administer a urine test to an offender under his supervision. Appellant claimed the test was not required and that the reason for his termination was pretextual. Appellant protested his termination to then-President Judge of the CCP Carol McGinley, but Judge McGinley refused to take any action. As a result, Appellant claimed he could not obtain other employment in any other court system, and, in 2014, he filed a charge of unlawful discrimination with the Equal Employment Opportunity Commission, which was dual-filed with the Pennsylvania Human Relations Commission (“PHRC”), against Lehigh County Adult Probation, Sikora, and Surovy. Thereafter, Appellant completed training as a municipal officer, and, subsequently, was offered a police officer position by Northampton and Fountain Hill Boroughs. Appellant alleged that the CCP and Lehigh County learned that Appellant was offered employment as a police officer, and caused an order to be issued banning Appellant from possessing a firearm or taser in the Lehigh County Courthouse, Old Courthouse, and Government Center. As a result, Northampton and Fountain Hill Boroughs rescinded their employment offers. Appellant eventually got his gun possession ban lifted, but as a condition, the CCP and Lehigh County required him to undergo a medical exam, which Appellant contended was a violation of the PHRA. The Pennsylvania Supreme Court concluded that application of the PHRA to the judiciary would violate separation of powers principles, and thus, affirmed the order of the Commonwealth Court. View "Renner v. CCP of Lehigh Co., et al" on Justia Law

Appellant William Rohland was an inmate confined at SCI-Huntingdon. In 2005, he was charged in Lackawanna County, Pennsylvania, with various offenses. He was ultimately sentenced on those charges in November 2006 to one-to-five years’ imprisonment, and was required as part of his sentence to pay restitution, fines, and costs. Thereafter, in 2007, Appellant was convicted in Luzerne County on two counts of first-degree murder and sentenced to two consecutive terms of life imprisonment. As of December 2016, the Department of Corrections' records reflected Appellant still owed approximately $2,300 in connection with his Lackawanna County sentence, although the incarceration aspect of that sentenced had expired. Thus, the prison’s business office sent Appellant a memorandum notifying him of the amount owed and indicating that the prison would begin making periodic Act 84 deductions from his inmate account to satisfy that obligation. The memo also gave instructions on how Appellant could challenge the deductions. The issue this case presented for the Pennsylvania Supreme Court's review was whether the deductions from an inmate account could continue after Appellant finished serving the prison-term portion of the sentence while still incarcerated on a separate sentence. The Supreme Court determined the Department had clear legal authorization under Act 84 to effectuate such deductions. That being the case, the Supreme Court determined the Commonwealth Court acted properly in granting the Department's motion for summary judgment. View "Rohland v Business Office, Dept. of Corrections" on Justia Law

The United States Court of Appeals for the Third Circuit certified a question of law to the Pennsylvania Supreme Court. Plaintiffs William DeForte and Evan Townsend were employed as police officers with the Borough of Worthington (the “Borough”). Neither officer was salaried or received benefits. Instead, they were paid hourly wages and, moreover, were simultaneously employed by other police forces. The Borough’s police force consisted of four part-time officers, including Plaintiffs. On November 5, 2012, the Borough terminated Plaintiffs’ employment without affording any process. Plaintiffs brought separate actions (which were consolidated) against the Borough at the federal district court. Plaintiffs asserted, inter alia, that the Borough Code or the Tenure Act conferred a constitutionally-protected property interest in their continued employment, and the lack of any process associated with their dismissal violated their federal due process rights. They requested relief under Section 1983 of the Civil Rights Act of 1871. The Borough moved for summary judgment. In ruling on the motion, the district court considered whether Plaintiffs were entitled to civil-service protections in connection with their dismissal under either the Police Tenure Act, or the Borough Code, The Supreme Court, answering the two-part question forwarded by the Third Circuit: (1) the civil service protections embodied in the Borough Code and the Tenure Act were broadly in pari materia insofar as they were intended to govern all borough police forces; and (2) when calculating the size of a borough police force in any given case, the same test should be used. More particularly, the “normal working hours” criterion contained in the Borough Code should be employed to determine how many members a borough police force has for purposes of deciding whether the Tenure Act’s two-officer maximum or the Borough Code’s three-officer minimum was implicated. View "Deforte v. Boro of Worthington" on Justia Law

A jury found that Pennsylvania State Police (“PSP”) Trooper Joseph Lombardo was acting outside the scope of his employment based on his use of force in an incident following a routine traffic stop. Accordingly, Trooper Lombardo was unable to benefit from the protections of sovereign immunity and judgment was entered against him and in favor of Shiretta Justice. The trial court affirmed, denying Trooper Lombardo’s post-trial motion for judgment notwithstanding the verdict (“JNOV”) and a new trial. On appeal, the Commonwealth Court reversed, concluding that Trooper Lombardo’s conduct fell within the scope of his employment and remanded for the entry of JNOV in favor of Trooper Lombardo. The Pennsylvania Supreme Court reversed and remanded, finding that because the jury’s determination was reasonably inferable from the facts, the Commonwealth Court erred in disturbing the verdict. The matter was remanded back to the Commonwealth Court to consider the trial court’s denial of Trooper Lombardo’s motion for a new trial. View "Justice v. Lombardo" on Justia Law