Justia Pennsylvania Supreme Court Opinion Summaries

A school board in Pennsylvania approved a collective bargaining agreement (CBA) with a teachers’ association during a meeting, even though this agreement was not included on the agenda published at least 24 hours before the meeting, as required by the state’s Sunshine Act. The board justified the late addition by explaining that the teachers’ association had only approved the CBA earlier that same day. The board amended the agenda during the meeting by majority vote to include the CBA, then voted to approve it. A local resident challenged this action, arguing that it violated the Sunshine Act’s notice requirements.The Lehigh County Court of Common Pleas consolidated the actions and granted summary judgment in favor of the school district, finding that the board’s majority vote to amend the agenda during the meeting satisfied the statutory exception permitting such changes. On appeal, the Commonwealth Court reversed in part, interpreting Section 712.1 of the Sunshine Act to provide only three substantive exceptions to the 24-hour notice rule and treating the “majority vote” provision as a mere procedural mechanism, not a standalone exception. The Commonwealth Court concluded that the board’s action violated the Act.The Supreme Court of Pennsylvania reviewed whether Section 712.1 provides four independent exceptions to the notice requirement, or only three. The court held that the statute’s plain language creates four separate exceptions, including the majority vote provision, which allows an agency to add items to the agenda during a meeting by majority vote and subsequently take official action. Accordingly, the Supreme Court of Pennsylvania reversed the Commonwealth Court’s decision and reinstated the trial court’s order granting summary judgment to the school district, holding that the board’s actions complied with the Sunshine Act. View "Coleman v. Parkland School District" on Justia Law

A man brought a civil lawsuit against the Philadelphia District Attorney and several assistant district attorneys, alleging they violated Pennsylvania’s Wiretap Act by using and disclosing surreptitiously recorded conversations between him and his ex-wife during a criminal prosecution. The recordings, made by his ex-wife without his knowledge during their marriage, were provided to the police and used by prosecutors in their attempt to bring criminal charges against him. The criminal court ultimately found the recordings were obtained in violation of the Wiretap Act and barred their use as evidence, leading to the dismissal or withdrawal of all charges.In the Court of Common Pleas of Philadelphia County, the prosecutors raised the defense of high public official immunity in response to the civil suit for damages under the Wiretap Act. The trial court agreed, holding that the General Assembly had only waived sovereign immunity in the Wiretap Act, not high public official immunity, and dismissed the claims with prejudice. On appeal, the Commonwealth Court affirmed, reasoning that high public official immunity is a broad, absolute bar to civil suits for damages arising from actions taken within the scope of official duties, and that the Wiretap Act did not expressly waive this immunity for district attorneys or their assistants.The Supreme Court of Pennsylvania reviewed whether law enforcement officers, specifically district attorneys and assistant district attorneys, are immune from civil suits for damages under Section 5725 of the Wiretap Act. The court held that, while the Act expressly waives sovereign immunity, it does not specifically and explicitly waive high public official immunity. Therefore, district attorneys and assistant district attorneys retain high public official immunity from civil suits for damages under the Wiretap Act when acting within the scope of their official duties. The Supreme Court of Pennsylvania affirmed the order of the Commonwealth Court. View "Winig v. Office of DA of Philadelphia" on Justia Law

Four police officers entered a Pittsburgh rowhouse searching for a missing person. Inside, Vincent Smith, the appellant, started a fire that endangered the officers, who escaped unharmed. Smith was rescued and treated for smoke inhalation. The bodies of two men, previously killed by Smith, were found in the residence. Smith admitted to the killings and to starting the fire in a suicide attempt. He was charged with two counts of voluntary manslaughter and four counts of arson endangering persons (AEP), one for each officer present.Smith pled guilty to all charges in the Allegheny County Court of Common Pleas. The trial court sentenced him to consecutive terms for each manslaughter and each AEP count, totaling 26 to 52 years. Smith challenged the legality of receiving multiple sentences for AEP based on a single act of arson that endangered multiple people. The trial court, relying on Commonwealth v. Frisbie, held that each endangered person constituted a separate unit of prosecution under the AEP statute.Smith appealed to the Superior Court of Pennsylvania, arguing that only one sentence for AEP should be imposed per arson, regardless of the number of people endangered. Initially, a panel vacated three AEP sentences, but after reargument, the en banc Superior Court affirmed the trial court, holding that the unit of prosecution was each endangered person.The Supreme Court of Pennsylvania reviewed the case to determine the correct unit of prosecution for AEP under 18 Pa.C.S. § 3301(a)(1)(i). The Court held that the unit of prosecution is each act of arson, not each person endangered. It found the statute ambiguous and applied the rule of lenity, strictly construing it in favor of the defendant. The Supreme Court reversed the Superior Court’s decision, vacated Smith’s sentence, and remanded for resentencing consistent with its holding. View "Commonwealth v. Smith" on Justia Law

The appellant was convicted of first-degree murder for killing his estranged wife’s 14-month-old son, as well as attempted murder and aggravated assault of his estranged wife’s roommate. The prosecution’s case relied heavily on the testimony of a police officer who witnessed the events. At trial, the appellant represented himself and claimed innocence, alleging a police cover-up. During jury selection, one juror initially indicated on a questionnaire that a family member had been charged with a crime, but then changed the answer to “no.” Decades later, the appellant’s counsel discovered that this juror’s nephew had, in fact, been charged with attempted murder of an infant before the trial, a fact not disclosed during voir dire.The Court of Common Pleas of Dauphin County dismissed the appellant’s third Post Conviction Relief Act (PCRA) petition as untimely, reasoning that the information about the juror’s nephew was available in a 2002 news article and thus not a “new fact.” The court concluded that the appellant failed to show why he could not have discovered this information earlier, and therefore did not meet the requirements for the previously unknown fact exception to the PCRA’s time bar.The Supreme Court of Pennsylvania reviewed the dismissal de novo. It held that the lower court erred by applying a presumption that the appellant knew of the juror’s family connection simply because the information was publicly available. The Supreme Court clarified that the relevant inquiry is whether the appellant actually knew or could have discovered the fact through reasonable diligence, not whether the information was in the public record. The Court vacated the order dismissing the petition and remanded for further proceedings, holding that the appellant was entitled to a hearing to establish whether he met the requirements for the newly discovered fact exception. View "Commonwealth v. Blakeney" on Justia Law

An employee of a roofing subcontractor was severely injured after falling through an uncovered hole while working on a library roof replacement project. The general contractor had contracted with the property owner to perform the roof work and then subcontracted the roofing portion to the injured worker’s employer. The injured worker received workers’ compensation benefits from his direct employer and subsequently filed a negligence lawsuit against the general contractor, seeking damages for his injuries.In the Philadelphia County Court of Common Pleas, the general contractor asserted statutory employer immunity under Pennsylvania’s Workers’ Compensation Act, arguing it was immune from tort liability as a statutory employer. The trial court struck the general contractor’s answer and new matter as untimely and granted the injured worker’s motion to preclude the statutory employer defense at trial. The case proceeded to a jury, which found the general contractor negligent and awarded $5 million to the plaintiff. The trial court denied the general contractor’s post-trial motion for judgment notwithstanding the verdict.On appeal, the Pennsylvania Superior Court vacated the trial court’s judgment and remanded for entry of judgment in favor of the general contractor. The Superior Court held that the general contractor was the injured worker’s statutory employer and thus immune from tort liability, finding all elements of the statutory employer test satisfied and that the defense was not waivable.The Supreme Court of Pennsylvania reviewed whether to overrule prior precedent (Fonner and LeFlar) regarding statutory employer immunity and waiver, and whether the Superior Court properly applied the statutory employer test. The Supreme Court reaffirmed its prior holdings that a general contractor’s statutory employer immunity does not depend on actual payment of workers’ compensation benefits and that the defense is jurisdictional and not waivable. However, it found the Superior Court erred by exceeding its scope of review and remanded the case to the trial court to determine, after appropriate proceedings, whether the general contractor satisfied the disputed elements of the statutory employer test. View "Yoder v. McCarthy Const." on Justia Law

The case concerns an individual who was arrested twice for suspicion of driving under the influence (DUI) in Pennsylvania. The first arrest led to charges, while the second arrest did not result in charges until several months later. In the interim, the individual applied for admission to the county’s Accelerated Rehabilitative Disposition (ARD) program for the first DUI. The ARD application required disclosure of prior convictions, prior ARD participation, and any pending criminal charges, but did not ask about uncharged arrests. The applicant truthfully stated he had no pending charges at the time of the application.After the applicant was admitted to the ARD program, the Commonwealth learned of the second DUI charge and moved to revoke his ARD participation, arguing he violated program conditions by not disclosing the prior arrest. The Adams County Court of Common Pleas revoked his ARD participation, initially citing the new charges and later referencing “deception by omission.” The applicant was subsequently convicted and sentenced for the first DUI. The Pennsylvania Superior Court affirmed, reasoning that failing to disclose the second arrest, even if uncharged, undermined the spirit and intent of the ARD program, and relied on prior cases where omissions or misrepresentations justified ARD revocation.The Supreme Court of Pennsylvania reviewed the case and held that revocation of ARD participation must be based on violation of a specified condition of the program, not on implied conditions or the general “spirit” of the program. The Court found that the applicant answered all questions on the ARD application truthfully, as there were no pending charges at the time, and the application did not require disclosure of uncharged arrests. Therefore, the trial court erred in revoking ARD participation, and the Supreme Court reversed the Superior Court’s decision. View "Commonwealth v. Jenkins" on Justia Law

A patient was involuntarily admitted to a hospital for mental health treatment due to dementia-related aggression. During his stay, he developed and experienced worsening pressure ulcers. After being transferred to another facility, he died ten days later. The estate of the patient filed a wrongful death and survival action against the hospital, alleging negligence and corporate negligence in the care and treatment of the patient’s pressure ulcers, claiming these injuries contributed to his decline and death.The Lehigh County Court of Common Pleas granted the hospital’s motion for judgment on the pleadings, finding that the hospital’s care for the pressure ulcers was incidental to the patient’s mental health treatment. The court concluded that, under Section 114 of the Pennsylvania Mental Health Procedures Act (MHPA), the hospital was immune from liability for ordinary negligence because the care provided was coincident to mental health treatment, and the complaint did not allege willful misconduct or gross negligence. The Superior Court of Pennsylvania affirmed this decision, holding that the immunity provision of the MHPA applied to the hospital’s conduct.The Supreme Court of Pennsylvania reviewed whether the MHPA’s immunity provision applied to the hospital’s treatment of the patient’s physical ailments during his mental health admission. The Court held that the MHPA’s immunity provision covers not only treatment directly related to mental illness but also medical care coincident to mental health treatment, including foreseeable physical complications like pressure ulcers. Because the estate’s complaint alleged only ordinary negligence and not gross negligence or willful misconduct, the Court affirmed the Superior Court’s order granting judgment on the pleadings in favor of the hospital. View "Wunderly v. Saint Luke's Hosp." on Justia Law

A homebuyer entered into an agreement to purchase a property in Titusville, Pennsylvania, and, before completing the purchase, orally contracted with a home inspector to perform an inspection. The inspector delivered a report that did not disclose any structural or foundational issues. Relying on this report, the buyer purchased the property. The following winter, a burst pipe led to the discovery of significant defects, including the absence of a proper foundation and improper ductwork, which had not been disclosed in the inspection report. The buyer filed suit against the inspector more than two years after the report was delivered, alleging violations of the Pennsylvania Home Inspection Law, breach of contract, and violations of the Unfair Trade Practices and Consumer Protection Law.The Court of Common Pleas of Crawford County overruled most of the inspector’s preliminary objections and denied a motion for judgment on the pleadings, finding ambiguity in the statute governing the time to bring actions arising from home inspection reports. The trial court reasoned that the statute could be interpreted as either a statute of limitations or a statute of repose and declined to grant judgment for the inspector. On appeal, the Superior Court reversed, holding that the statute in question was a statute of repose, not a statute of limitations, and that all of the buyer’s claims were time-barred because they were filed more than one year after the inspection report was delivered.The Supreme Court of Pennsylvania reviewed whether the relevant statutory provision, 68 Pa.C.S. § 7512, is a statute of repose or a statute of limitations. The Court held that the statute is a statute of repose, barring any action to recover damages arising from a home inspection report if not commenced within one year of the report’s delivery, regardless of when the claim accrues. The Court affirmed the Superior Court’s judgment. View "Gidor v. Mangus" on Justia Law

Christopher Toland was sentenced in 1993 to a lengthy prison term for rape, kidnapping, and related offenses, making him eligible for parole in 2004. Between 2004 and 2020, the Pennsylvania Parole Board denied him parole fourteen times, often contrary to recommendations from the Department of Corrections. Toland filed a petition for review in the Commonwealth Court of Pennsylvania, seeking mandamus relief and alleging constitutional violations in the Board’s parole denials from 2017, 2018, and 2019. He claimed the Board relied on false information, acted arbitrarily, and applied parole standards retroactively in violation of ex post facto prohibitions.The Commonwealth Court overruled the Parole Board’s preliminary objections to Toland’s claims, allowing discovery to proceed. When Toland requested documents related to his parole eligibility, the Parole Board objected, citing its own regulation (37 Pa. Code § 61.2) that designates its records as “private, confidential and privileged.” The Commonwealth Court rejected the Board’s objections, finding that Toland, as the beneficiary of the privilege, could waive it. The Board then filed an interlocutory appeal.The Supreme Court of Pennsylvania reviewed the case and affirmed the Commonwealth Court’s order, but on a different basis. The Supreme Court held that the Parole Board does not have the authority to create an evidentiary privilege through its own regulation. Therefore, Section 61.2 does not establish a privilege that can be invoked to prevent disclosure of documents in discovery. The Court clarified that only privileges created by the legislature, the constitution, or the common law are recognized in Pennsylvania courts, and no such privilege exists under Section 61.2. The Supreme Court’s disposition was to affirm the lower court’s order. View "Toland v. PBPP" on Justia Law

The appellant pleaded guilty in 2015 to driving under the influence and resisting arrest, receiving a sentence of incarceration followed by probation. While serving probation for this 2015 case, he was arrested in 2018 for aggravated assault. After his mother posted bail on the new charges, a probation detainer from the 2015 case kept him in custody. He later pleaded guilty to aggravated assault in the 2018 case and was sentenced to a term of imprisonment. The trial court did not credit him for all the time he spent in custody before sentencing, specifically the period he was held solely on the probation detainer after bail was posted in the 2018 case.The Lackawanna County Court of Common Pleas, acting as the PCRA court, granted partial relief by awarding credit only for the period after the detainer was lifted, reasoning that the earlier period of confinement was solely due to the probation detainer in the 2015 case, for which only a probationary sentence was ultimately imposed. The Pennsylvania Superior Court affirmed, holding that the appellant was not entitled to credit for time spent in custody on the probation detainer because no prison sentence was imposed in the 2015 case, and the time was not attributable to the new charges after bail was posted.The Supreme Court of Pennsylvania reviewed the statutory language of 42 Pa.C.S. § 9760(1) and held that a defendant is entitled to credit against a new prison sentence for all time spent in custody as a result of the conduct underlying the new charge, even if the confinement was due to a probation detainer from an earlier case, so long as the conduct leading to the detainer is the same as that underlying the new charge. The Court reversed the Superior Court’s order and remanded for further proceedings to determine if relief could still be awarded. View "Commonwealth v. Phillips" on Justia Law