In Re: Sealed Arrest Warrants Appeal of:The Herald

2024 Pa. Super. 39, 313 A.3d 214
CourtSuperior Court of Pennsylvania
DecidedMarch 6, 2024
Docket21 WDA 2023
StatusPublished
Cited by1 cases

This text of 2024 Pa. Super. 39 (In Re: Sealed Arrest Warrants Appeal of:The Herald) 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.

Bluebook
In Re: Sealed Arrest Warrants Appeal of:The Herald, 2024 Pa. Super. 39, 313 A.3d 214 (Pa. Ct. App. 2024).

Opinion

J-S99001-23

2024 PA Super 39

IN RE: SEALED ARREST WARRANTS : IN THE SUPERIOR COURT OF PURSUANT TO PA. R.CRIM.513.1 : PENNSYLVANIA : : APPEAL OF: THE HERALD : STANDARD-UNIONTOWN : NEWSPAPERS, INC, MON VALLEY : INDEPENDENT, AND OBSERVER : REPORTER : No. 21 WDA 2023

Appeal from the Order Entered December 14, 2022 In the Court of Common Pleas of Westmoreland County Criminal Division at No: 801 MD 2022

BEFORE: STABILE, J., DUBOW, J., and KING, J.

OPINION BY STABILE, J.: FILED: MARCH 6, 2024

Presently before us is the appeal of Appellants, The Herald Standard-

Uniontown Newspapers, Inc., Mon Valley Independent, and Observer Reporter

from the trial court’s order of December 14, 2022, denying their petition to

intervene and unseal arrest warrant information that had been sealed

pursuant to Pa.R.Crim.P. 513.1.1 As explained in more detail below, we issued

an order on February 8, 2022, affirming in part and reversing in part the trial

court’s sealing order. Specifically, we reversed the order insofar as it denied

Appellants’ petition to intervene and insofar as it sealed the public dockets.

We affirmed the trial court’s order insofar as it sealed other arrest warrant

information. Given the sensitivity of the Commonwealth’s ongoing

____________________________________________

1 Rule 513.1 is titled “Sealing of Arrest Warrant.” We will address the pertinent subsections throughout this opinion. J-S99001-23

investigation, we awaited the expiration of the sealing order prior to issuing

this opinion in support of the order.

This matter arises from the criminal prosecution of Keven Van Lam,

currently pending in Westmoreland County.2 On November 6, 2022, in

response to a petition from the Westmoreland County District Attorney, the

trial court issued an order pursuant to Rule 513.1 sealing the arrest warrant

information for 60 days. Pursuant to that order, local media outlets were

denied access to any information pertaining to the Van Lam case, including

the public dockets.

On November 22, 2022, Appellants filed an emergency petition to

intervene and unseal the criminal record, arguing that the prosecution,

involving a fatal shooting in Rostraver Township, was of public interest and

that the media could not monitor and report on the case with the entire record

sealed. The trial court conducted a hearing on Appellants’ petition on

December 14, 2022. At the hearing, Appellants asked, at a minimum, that a

public docket be made available. N.T. Hearing, 12/14/22, at 5, 13-15. For

its part, the Commonwealth indicated that it would not object to the release

2 This sealed arrest warrant proceeding is docketed at Westmoreland County Court of Common Pleas number CP-65-MD-0000801-2022. The criminal proceeding against the defendant was docketed at Magisterial District Court docket number MJ-10103-CR-0000479-2022. Now that the preliminary hearing has been held and the charges bound over for court, the Magisterial District Court docket is closed and the criminal prosecution is pending at Westmoreland County Court of Common Pleas docket number CP-65-CR- 0003527-2023.

-2- J-S99001-23

of a public docket so long as the docket did not include arrest warrant

information as defined under Rule 513.1. Id. at 18-19. The trial court denied

all requested relief at the conclusion of the hearing:

I am going to state on the record that, as the presiding judge over this matter and the one who signed the order to seal the record to maintain the integrity of the Commonwealth’s investigation, I find that it is absolutely imperative that the arrest record warrant, the information contained in my order of November 6th and 7th, that that information continue to remain sealed by virtue of the arguments made at the hearing today.

Id. at 22. The trial court advised Appellants of the date and time of the

preliminary hearing and directed the prosecutor to advise Appellants’ counsel

of any continuance(s). Id. at 23.

Appellants timely appealed3 to this Court on December 28, 2022. They

filed a motion to expedite the appeal on January 5, 2023. This Court granted

the motion on January 13, 2023. On February 8, 2023, after an in camera

review of the sealed information, this Court issued an order affirming in part

and reversing in part as set forth above. Order, 2/8/23. Meanwhile, the

preliminary hearing in the Van Lam matter was continued seven times, with

the consent of the defendant, until it finally occurred on October 18, 2023. At

the conclusion of the preliminary hearing, the charges against Van Lam of

first-degree murder, criminal homicide, and evidence tampering were held for

3 The trial court’s order in this matter is immediately appealable. Commonwealth v. Fenstermaker, 530 A.2d 414, 421 (Pa. 1987).

-3- J-S99001-23

court, and the sealing order expired. We now issue the following opinion in

support of our order of February 8, 2023.

“As a preliminary matter, we note that the determination of whether an

item will be considered a public judicial record or document subject to the

common law right of access is a question of law, for which the scope of review

is plenary.” Commonwealth v. Upshur, 924 A.2d 642, 647 (Pa. 2007)

(plurality). “However, the trial court’s decision regarding access to a particular

item will be reviewed for abuse of discretion.” Id. “Regarding the

constitutional right of access, at least, the court should issue individualized,

specific, particularized findings on the record that closure is essential to

preserve higher values and is narrowly tailored to that interest.”

Commonwealth v. Curley, 189 A.3d 467, 473 (Pa. Super. 2018).

Rule 513.1 permits the sealing of “arrest warrant information” for “good

cause shown.” Pa.R.Crim.P. 513.1(A), (B). Arrest warrant information is “the

criminal complaint in cases which an arrest warrant is issued, the arrest

warrant, any affidavit(s) of probable cause, and documents or information

related to the case.” Pa.R.Crim.P. 513.1(A). The judge and clerk of courts

may not make arrest warrant information available for public inspection until

the sealing order expires. Pa.R.Crim.P. 513.1(G). Per its official comment,

Rule 513.1 was adopted to codify the Pennsylvania Supreme Court’s opinion

in Commonwealth v. Fenstermaker, 530 A.2d 414, 420 (Pa. 1987). There,

our Supreme Court set forth some principles guiding our analysis of the issue

-4- J-S99001-23

before us. Most significantly, our criminal courts operate under a presumption

of openness. Id. at 417, 420.

The importance of the public having an opportunity to observe the functioning of the criminal justice system has long been recognized in our courts. Criminal trials in the United States have, by historical tradition, and under the First Amendment, been deemed presumptively open to public scrutiny and this “... presumption of openness inheres in the very nature of the criminal trial under our system of justice.” Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 573 (1980).

Id. at 417.

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In Re: Sealed Arrest Warrants Appeal of:The Herald
2024 Pa. Super. 39 (Superior Court of Pennsylvania, 2024)

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2024 Pa. Super. 39, 313 A.3d 214, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-sealed-arrest-warrants-appeal-ofthe-herald-pasuperct-2024.