Commonwealth v. Blystone
119 A.3d 306
| Pa. | 2015Background
- Blystone challenged a Fayette County trial court order denying limited courtroom closure and sealing related transcripts in his capital sentencing proceeding.
- The closure sought to protect sensitive information from Appellant’s mother regarding his traumatic upbringing, provided only if assurances of non-public treatment were guaranteed.
- Appellant’s prior PCRA and federal habeas corpus proceedings had already recognized the potential for new sentencing considerations based on mitigating evidence, including mental health testimony.
- The trial court held the closure motion premature, noting it did not show risk to safety or that alternatives were unavailable, and lacked subpoena or other discovery steps.
- The appellate issue centers on whether the interlocutory order denying closure is appealable under Pa.R.A.P. 313(b) (collateral order doctrine).
- The Pennsylvania Supreme Court ultimately quashed the appeal for lack of jurisdiction, ruling the order was not appealable under the collateral order doctrine.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the appellate court has jurisdiction to review the trial court’s closure denial. | Blystone argues the order is appealable under Rule 313(b) as a collateral-order | Commonwealth contends no jurisdiction since the order fails 313(b) criteria | No jurisdiction; appeal quashed |
Key Cases Cited
- Commonwealth v. Fenstermaker, 530 A.2d 414 (Pa. 1987) (supports opening of trials; collateral considerations)
- Commonwealth v. Williams, 86 A.3d 771 (Pa. 2014) (collateral-order separability and importance standards)
- Rae v. Pa. Funeral Dirs. Ass’n, 977 A.2d 1121 (Pa. 2009) (limits on piecemeal interlocutory review)
- Ben v. Schwartz, 729 A.2d 547 (Pa. 1999) (policy on collateral-order preservation)
- Harris v. Commonwealth, 32 A.3d 243 (Pa. 2011) (privilege and disclosure implications in collateral orders)
- Pridgen v. Parker Hannifin Corp., 905 A.2d 422 (Pa. 2006) (conceptual distinctness in collateral-review analysis)
- Commonwealth v. Wright, 78 A.3d 1070 (Pa. 2013) (collateral order doctrine requirements and review limitations)