April 26, 2010
Judging by the comments on our Facebook fan page, many of you were intrigued by Friday’s Headnote of the Day – and curious as to why a lower court would ever presume to “dismiss a Supreme Court decision” in the first place.
Understanding this headnote requires some knowledge of the case in point. In 1976, Robert Rambo (yes, that’s his real name) was arrested after customs officials tipped off local police regarding 10 pounds of hashish making its way through the mail toward Rambo’s suburban apartment.
The hashish was tucked inside some pottery that had been sent from his brother in Morocco. After accepting the packages, Rambo set them down, unopened, and went out. While he was gone, the police entered his apartment and seized the packages. Later that day, when he contacted police as instructed in a note they had left behind, he was arrested and charged with possession and intent to distribute.
At his trial, Rambo testified that he had agreed to take delivery of pottery and antiques from his brother, but that he had no idea the packages would contain hashish or that his brother was involved with drugs. The jury didn’t buy it, and Rambo was sentenced to three years.
The Pennsylvania Supreme Court overturned Rambo’s conviction, citing insufficient evidence that he really knew what was in the packages, despite the jury’s verdict. However, when Rambo later petitioned to have his arrest record expunged, the lower court denied his request.
“Such a miracle result for the defendant is not a compelling reason to expunge the record and encourage the sale of drugs without safeguarding the public from a repeat of defendant’s drug pushing activities,” the lower court asserted.
The Supreme Court was not amused. “The lower court’s reasoning fails to comprehend, or ignores, the significance of the Supreme Court’s decision,” the high court wrote in its reversal. “Neither this court nor any lower court may dismiss a Supreme Court decision as a ‘miracle result.’
“…The Commonwealth argues that it has an interest ‘in discouraging the sale of drugs in order to protect the public,’” the high court continued. “This argument, like the lower court’s opinion, begs the question. It assumes that appellant was engaged in the sale of drugs, and ignores the fact that appellant has been vindicated. Punishment of the innocent is the clearest denial of life, liberty and property without due process of law.”
We hope this sheds a bit more light on this intriguing headnote. Thanks for all the comments – and keep ‘em coming!