The Pennsylvania Supreme Court has denied a petition filed by Lancaster County District Attorney Craig Stedman that would have ordered a local district judge to replace a verdict from a 2015 traffic citation case.
The ruling effectively ends the ongoing legal dispute over whether Elizabethtown District Judge Jayne Duncan erred in replacing another judge's verdict.
However, the state Supreme Court did not issue an opinion in its decision Friday, simply denying it with a 16-word order.
Stedman viewed that as a “favorable” outcome, while Duncan's attorney Heidi Eakin referred to it as a “clear” repudiation.
“It was a 7-0 opinion. It doesn't get more clear than that,” she said Monday.
“(Stedman) has vilified Jayne Duncan in the press, keeping this going at taxpayers expense,” she said. “Now you see what the end result is.”
Eakin declined to say if there would be further legal action taken by Duncan.
The petition, a writ of mandamus, is an order from a court to an inferior government official ordering them to properly fulfill official duties or correct an abuse of discretion. Stedman filed the petition in June of 2015.
On Monday, Stedman said the Commonwealth’s focus was on opposing Duncan's claim that a magisterial district judge should be allowed to to change a verdict up to 30 days afterward.
“The Commonwealth’s primary concern was not this one particular traffic matter, but was always of the potential statewide ramifications should Magisterial District Justice Duncan’s claim have been granted,” Stedman said in a statement. “Because the court did not make that substantive finding, or any substantive finding, the law remains unchanged and we thus consider this ruling to be very favorable in the grand scheme of things.”
Duncan, who the Court of Common Pleas removed from handling all criminal and traffic cases during an ongoing criminal investigation into the matter, has yet to be reinstated in that capacity, court officials said Monday.
The caseload reassignment, which had been diverted to other jurisdictions in July 2015, remains “in effect until further notice” and is “currently under review” following the high court decision, deputy court administrator Russell Glass said in an email.
Duncan has continued to handle civil, landlord and truancy matters throughout the ordeal.
“There has been no announcement from the district attorney's office on whether they plan on continuing the criminal investigation,” Eakin said. “It's back in the DA's hands now.”
However, Stedman said the decision to lift the order belongs to President Judge Dennis Reinaker, who signed the order barring Duncan from hearing criminal and traffic cases.
Reinaker was unavailable for comment Monday.
Looking to “ensure the accuracy of criminal records,” Stedman filed the petition on behalf of the Commonwealth after Shawn Kerr was given two hearings on the same three traffic citations.
Kerr initially was found guilty in absentia of all three violations by District Judge Daniel Garrett on May 15, 2015. Garrett substituted for Duncan that day because she was at a funeral.
The verdicts were never entered or recorded in the dockets; instead the case was marked as continued.
One month later, Duncan held another hearing where Kerr appeared and pleaded guilty to two traffic violations. The third was withdrawn by Northwest Regional police Officer Joshua Reager, who issued three tickets to Kerr on April 12, 2015.
Reager had previously testified that after he learned Duncan was giving Kerr a second hearing, he contacted the district attorney's office out of concern for trying Kerr twice for the same offense.
However, Eakin has said the verdict would not be changed while the matter was under appeal.
Court records Monday morning showed Duncan's verdicts are on record.
Kerr appealed Duncan's ruling.
'Very unusual' situation
Bruce Ledewitz, a law professor at Duquesne University School of Law, referred to the situation as “very unusual” and a “precise circumstance that is not likely to be repeated.”
The mandamus filing is not unusual, he said. Because Duncan's ruling was a “partial acquittal,” prosecutors have little ability to appeal due to double jeopardy laws, he said.
The mandamus filing was a potential way to look for a remedy.
While Stedman may have been looking for a correction of the verdict, he may have also been attempting to ensure something like this could not happen in the future, Ledewitz said.
“This is kind of a complex legal context,” Ledewitz said. “What type of precedent does this set for the future, if any?”
The court could be saying this is the kind of error that just cannot be corrected or they may have meant there is no error at all, he said. Or maybe it was an error, but it doesn't rise to the level of mandamus, he said.
“Our focus throughout this process was to prevent a change in established law which would allow for verdicts to be changed within 30 days, as presented by Magisterial District Justice Duncan’s defense. We are relieved that was not the outcome,” Stedman said.