Com. v. Held, J., Appeal of: TribTotal Media

2020 Pa. Super. 161, 235 A.3d 339
CourtSuperior Court of Pennsylvania
DecidedJuly 8, 2020
Docket81 WDA 2019
StatusPublished
Cited by1 cases

This text of 2020 Pa. Super. 161 (Com. v. Held, J., Appeal of: TribTotal Media) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Com. v. Held, J., Appeal of: TribTotal Media, 2020 Pa. Super. 161, 235 A.3d 339 (Pa. Ct. App. 2020).

Opinion

J-A05003-20

2020 PA Super 161

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : JONATHAN C. HELD : : : No. 81 WDA 2019 APPEAL OF: TRIB TOTAL MEDIA, LLC : AND RICH CHOLODOFSKY :

Appeal from the Order Entered December 28, 2018 In the Court of Common Pleas of Westmoreland County Criminal Division at No(s): CP-65-CR-0001218-2018

BEFORE: BENDER, P.J.E., BOWES, J., and PELLEGRINI, J.*

OPINION BY BENDER, P.J.E.: FILED JULY 08, 2020

After the public corruption trial of former Westmoreland County Sheriff

Jonathan C. Held (“Held”) ended in a mistrial due to a hung jury, Trib Total

Media, LLC and Rich Cholodofsky1 (“TTM” or “Appellants”), intervened, seeking

public disclosure of the jurors’ names. The trial court entered an order

granting the release of the names, but only after Held’s still-pending criminal

charges were resolved. Appellants filed this interlocutory appeal challenging

the court’s decision to delay the disclosure of the jurors’ names as a violation

of the First Amendment. After careful review, we affirm.

____________________________________________

* Retired Senior Judge assigned to the Superior Court.

1 Mr. Cholodofsky is a reporter employed by Trib Total Media, LLC. J-A05003-20

At CP-65-CR-0001218-2018, the Office of the Attorney General (“OAG”)

charged Held with conflict of interest, 65 P.S. §1103; theft, 18 P.S. § 3921(a);

and diversion of services, 18 P.S. § 3926(b); based on accusations that Held

used public employees and resources of the Westmoreland County Sherriff’s

Office to aid in his re-election campaign. Naturally, the case attracted

significant attention from the media in Westmoreland County, including TTM.

On December 5, 2018, TTM filed a motion to intervene in Held’s ongoing trial

“for the limited purpose of filing a motion for public access to trial evidence….”

See TTM’s Motion to Intervene, 12/5/18, at 2 ¶ 4. Two day later, the trial

court declared a mistrial “following a poll of the jury and the refusal of one

juror to affirm a guilty verdict.” Trial Court Opinion (“TCO”), 3/27/19, at 2.

On December 13, 2018, the trial court issued an order 1) scheduling a status

conference for December 28, 2018, and 2) directing the Clerk of Courts to

“not release the names of the jurors … absent further [o]rder” from the court.

Order, 12/13/18, at 1 (single page).

TTM then filed a motion specifically seeking the release of the jurors’

names, arguing, inter alia, that the First Amendment compelled the court to

release them pursuant to our Supreme Court’s decision in Commonwealth

v. Long, 922 A.2d 892 (Pa. 2007). Motion for Access to Juror Names,

12/17/18, at 3-4 ¶¶ 12-14. The trial court held a hearing on that motion and

other matters on December 28, 2018. After hearing argument, the court

entered the at-issue order, granting, inter alia, the motion to disclose the

jurors’ names with the caveat that “the names may not be revealed until the

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charges against [Held] have been finally resolved.” Order, 12/28/2018, at 1

¶ 5 (hereinafter “temporary closure order”).

TTM filed a timely notice of appeal from that order, and also filed a

timely, court-ordered Pa.R.A.P. 1925(b) statement. The trial court issued its

Rule 1925(a) opinion on March 27, 2019. Appellants now present the

following questions for our review:

1 Did the trial court violate the First Amendment rights of [TTM] by refusing to release the names of the jurors after they were discharged?

2. In light of the holding in … Long, … did the trial court err in withholding [the] jurors’ names for the duration of the prosecution of [Held] without issuing contemporaneous, appropriate findings that closure is essential to preserve higher values and is narrowly tailored to serve that interest?

3. Did the trial court err in concluding that releasing the names of discharged jurors while charges remained pending against [Held] would violate the [Held]’s right to a fair retrial?

4. Did the trial court err in refusing to release the names of discharged jurors where the prosecution and [Held] did not object to their release?

TTM’s Brief at 4. Appellants’ claims are interrelated and, thus, we address

them together.

We begin by noting that the jurisdiction of this Court is not in question,

as it “is well settled that an order that denies a request for public access to a

criminal proceeding or judicial documents constitutes a collateral order from

which an immediate appeal may be taken.” Commonwealth v. Selenski,

996 A.2d 494, 495 n.2 (Pa. Super. 2010). Moreover, a claim that concerns

the “constitutional right of public access to a judicial proceeding raises a pure

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question of law. Our standard of review, therefore, is de novo, and our scope

of review is plenary.” Id. at 496.

The Supreme Court of the United States has “firmly established … that

the press and general public have a constitutional right of access to criminal

trials” pursuant to the First Amendment. Globe Newsp. Co. v. Super. Ct.

for Norfolk County, 457 U.S. 596, 603 (1982). In Globe, the Supreme

Court considered a challenge to a state statute that required judges

overseeing criminal “trials for specified sexual offenses involving a victim

under the age of 18, to exclude the press and general public from the

courtroom during the testimony of that victim.” Id. at 598. The Globe Court

determined that the First Amendment’s right of public/media access to

criminal trials was implicated by the statute, and applied the following

framework for analyzing its constitutionality:

Although the right of access to criminal trials is of constitutional stature, it is not absolute. But the circumstances under which the press and public can be barred from a criminal trial are limited; the State’s justification in denying access must be a weighty one. Where, as in the present case, the State attempts to deny the right of access in order to inhibit the disclosure of sensitive information, it must be shown that the denial is necessitated by a compelling governmental interest, and is narrowly tailored to serve that interest.

Id. at 606–07 (citations omitted).

The Globe Court recognized that “safeguarding the physical and

psychological well-being of a minor” was a compelling government interest.

Id. at 607. However, the Court determined that the remedy, “a mandatory

closure rule,” was not narrowly tailored to that interest, because “the

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circumstances of the particular case may affect the significance of the interest.

A trial court can determine on a case-by-case basis whether closure is

necessary to protect the welfare of a minor victim.” Id. at 607–08.

In Long, the Supreme Court of Pennsylvania considered the First

Amendment’s public-access-to-criminal-trials doctrine, as articulated in

Globe, in the narrower context of media access to the identities of jurors from

a criminal trial. During the jury’s deliberations in Long, a television station

intervened, seeking access to the jurors’ names and addresses. The trial court

denied their request, prompting the station to appeal (an identical procedural

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Com. v. Held, J., Appeal of: TribTotal Media
2020 Pa. Super. 161 (Superior Court of Pennsylvania, 2020)

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2020 Pa. Super. 161, 235 A.3d 339, Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-held-j-appeal-of-tribtotal-media-pasuperct-2020.