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Weekly Caselaw Updates

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Commonwealth v. DiStefano

The Pennsylvania Supreme Court held that the Superior Court misapplied the appellate court standard for reviewing trial court evidentiary rulings. The Commonwealth charged Appellant with homicide and aggravated assault. The MDJ concluded that the Commonwealth presented a prima facie case for both aggravated assault and homicide. The trial court ruled…

Commonwealth v. DiStefano
Pennsylvania Supreme Court

The Pennsylvania Supreme Court held that the Superior Court misapplied the appellate court standard for reviewing trial court evidentiary rulings. The Commonwealth charged Appellant with homicide and aggravated assault. The MDJ concluded that the Commonwealth presented a prima facie case for both aggravated assault and homicide. The trial court ruled that the Commonwealth failed to… Continue reading Commonwealth v. DiStefano

Maple v. Superintendant SCI Albion
3rd Circuit

The Third Circuit reversed the District Court’s grant of habeas relief. The defendant filed a habeas corpus petition and argued that the police had violated his Miranda rights by getting confessions that tainted the trial. The District Court agreed, and the Third circuit reversed, ruling that the case against the defendant “was very strong. Even… Continue reading Maple v. Superintendant SCI Albion

Anariba v. Dir. Hudson County Corr. Ctr.
3rd Circuit

The Third Circuit held that the District Court retained jurisdiction over the petitioner’s habeas corpus petition after the Court denied the petition without prejudice, and the Government whisked him away to a facility in another jurisdiction. The petitioner has been in immigration custody for nearly seven years as he laboriously challenged his removal order. In… Continue reading Anariba v. Dir. Hudson County Corr. Ctr.

Commonwealth v. Merced
Pennsylvania Superior Court

The Pennsylvania Superior Court reversed the trial court’s grant of habeas corpus relief because the lower court erroneously excluded the arresting officer’s hearsay evidence from the court’s scope of review. After being held over on charges associated with allegations of sexual abuse, the defendant filed a habeas corpus petition and argued the Commonwealth had violated… Continue reading Commonwealth v. Merced

Commonwealth v. Burke
Pennsylvania Superior Court

The proper remedy for a violation of Commonwealth v. McClelland is a discharge, not remand. The defendant, the Commonwealth, and the trial court agreed the magisterial district court and trial court violated McClelland when those courts relied exclusively on hearsay evidence at the preliminary hearing and habeas corpus hearing. In this interlocutory appeal, the Pennsylvania… Continue reading Commonwealth v. Burke

In re Rosado
3rd Circuit

AEDPA slays another habeas petition. In 1995, Rosado was almost eighteen and a half years old when he shot and killed someone. Seven months later, he pleaded guilty in Pennsylvania state court to first-degree murder and was sentenced to mandatory life without parole. After Rosado filed his first round of habeas petitions, the United States… Continue reading In re Rosado

Randolph v. Sec’y Pa. Dept. of Corr.
3rd Circuit

The week before his capital trial, Randolph hired Sam Stretton to replace his court-appointed counsel. On the Thursday before Monday’s jury selection, Stretton entered his appearance and asked the trial court if it could delay the start of the trial until the following month. Citing previous delays and the proximity to trial, the trial court… Continue reading Randolph v. Sec’y Pa. Dept. of Corr.

Wallace v. Superintendent Mahanoy SCI
3rd Circuit

The petitioner pleaded guilty but mentally ill to third-degree murder in a Pennsylvania common pleas court. After his plea and sentence, he took no action on the case for more than a decade but sought to excuse his delay when he filed a habeas corpus petition. The petitioner claimed that his mental illness prohibited him… Continue reading Wallace v. Superintendent Mahanoy SCI

Baxter v. Superintendent Coal Twp. SCI
3rd Circuit

The Third Circuit granted the appellee’s motion to publish its opinion in Baxter v. Superintendent Coal Twp. SCI. The case arose in the context of a habeas corpus petition wherein the petitioner claimed that the trial court’s reasonable doubt instruction to the jury was inaccurate and caused prejudice. The instruction provided the example that if… Continue reading Baxter v. Superintendent Coal Twp. SCI

Holland v. Warden Canaan USP
3rd Circuit

In Holland v. Warden Canaan USP, the Third Circuit heard a rare appeal from the denial of post-conviction relief based on a petition filed under 28 U.S.C. § 2241 instead of § 2255. Here, the petitioner was convicted of violating 18 U.S.C. § 924(c) when he traded drugs for a gun. After the date of the conviction,… Continue reading Holland v. Warden Canaan USP