Justia Pennsylvania Supreme Court Opinion Summaries

S.W., a minor, was placed with foster parents A.E. and Ann.E. by the Allegheny County Office of Children, Youth and Families (CYF) shortly after her birth in September 2020. In August 2022, CYF filed a petition to remove S.W. from the foster parents' home. The foster parents attended the hearing but did not seek to intervene. The trial court granted CYF's petition, and S.W. was placed with another foster family. The foster parents later filed a motion to intervene, which the trial court denied, stating they did not have standing as they had not requested S.W.'s return and had not achieved the status of prospective adoptive parents.The foster parents appealed to the Superior Court, which vacated the trial court's order and remanded for further proceedings, holding that the foster parents had standing as prospective adoptive parents based on the precedent set in Mitch v. Bucks County Children and Youth Social Services Agency. However, the Superior Court panel was divided, with one judge expressing doubts about the standing of prospective adoptive parents under the current law and another judge suggesting legislative changes to grant standing to all foster parents.The Supreme Court of Pennsylvania reviewed the case and determined that the issue of standing for prospective adoptive parents was moot, as the foster parents had withdrawn their motion to intervene and for S.W.'s return. Despite this, the court addressed the substantive issue due to its public importance. The court concluded that the legislative enactment of 42 Pa.C.S. § 6336.1, which states that foster parents and preadoptive parents do not have legal standing in dependency proceedings unless they have been awarded legal custody, abrogated the judicially created standing for prospective adoptive parents established in Mitch. The court reversed the Superior Court's decision, holding that preadoptive parents without legal custody do not have standing in dependency proceedings. View "In the Interest of: S.W." on Justia Law

Gianni and Jennifer Pignetti owned two noncontiguous parcels of land in Philadelphia, used for storing vehicles and equipment for Mr. Pignetti's electrical business. The Pennsylvania Department of Transportation (PennDOT) condemned part of one parcel and all of the other for an Interstate 95 improvement project. The Pignettis sought just compensation, arguing the parcels should be valued together as one under the Eminent Domain Code, which allows for such valuation if noncontiguous tracts in substantially identical ownership are used together for a unified purpose.The Court of Common Pleas of Philadelphia County agreed with the Pignettis, finding that the parcels were used together for a unified purpose and had substantially identical ownership. PennDOT appealed, and the Commonwealth Court reversed, ruling that the Pignettis did not prove the parcels were used together for a unified purpose. The Commonwealth Court applied a stricter standard from the case Morris v. Commonwealth, requiring that the parcels be so inseparably connected that the loss of one would necessarily and permanently injure the other.The Supreme Court of Pennsylvania reviewed the case and reversed the Commonwealth Court's decision. The Supreme Court held that the plain language of Section 705 of the Eminent Domain Code does not require the stricter standard from Morris. Instead, it requires only that the parcels be used together for a unified purpose. The Court found that the Pignettis' use of the parcels for storing business equipment and vehicles met this requirement. The case was remanded for further proceedings to address whether the parcels had substantially identical ownership, an issue not resolved by the Commonwealth Court. View "Pignetti v. PennDOT" on Justia Law

Michael Huff filed nomination petitions to run as a Democratic candidate for two judicial offices in the First Judicial District of Pennsylvania. Julian Domanico objected, arguing that Huff did not meet the constitutional residency requirement because he lived with his family in Montgomery County, not in the First Judicial District. Huff claimed his residence was a property in Philadelphia, where he had moved in May 2024, while his wife and children continued to live in Montgomery County.The Commonwealth Court held an evidentiary hearing and found that Huff's family resided in Montgomery County. The court applied Section 704(d) of the Pennsylvania Election Code, which presumes a married person's residence is where their family lives unless the couple is separated. Since Huff and his wife were not separated, the court concluded that Huff's domicile was in Montgomery County and ordered his name removed from the ballot.The Supreme Court of Pennsylvania reviewed the case. The court noted that the Pennsylvania Constitution requires judges to reside in their respective districts for at least one year before election. The court emphasized that residency for constitutional eligibility is determined by domicile, which involves physical presence and intent to remain. The court found that Section 704 of the Election Code, which applies to voter registration, should not be used as a bright-line rule for determining a candidate's eligibility to run for office.The Supreme Court vacated the Commonwealth Court's decision, ruling that the lower court improperly relied solely on Section 704(d) without considering the totality of the circumstances to determine Huff's domicile. The case was remanded for reconsideration based on the traditional concept of domicile, which includes assessing physical presence and intent to remain. View "In re Nomination of Huff" on Justia Law

In March 2016, thirteen-year-old J.R. Gustafson was accidentally shot and killed by his fourteen-year-old friend at a residence in Mt. Pleasant, Pennsylvania. J.R.'s parents, Mark and Leah Gustafson, filed a lawsuit against Springfield Armory, the manufacturer of the firearm, and Saloom Department Store, the retailer that sold the firearm. They alleged defective design, negligent design and sale, and negligent warnings and marketing. The trial court dismissed the complaint with prejudice, citing the Protection of Lawful Commerce in Arms Act (PLCAA), which bars certain civil actions against firearms manufacturers and sellers.The Gustafsons appealed, and the Superior Court reversed the trial court's decision, remanding the case for further proceedings. The Superior Court's en banc panel issued a per curiam order, with no single rationale garnering majority support. Some judges found the PLCAA barred the claims but was unconstitutional, while others found the PLCAA did not bar the claims or was constitutional. The Superior Court's order was challenged, leading to the current appeal.The Supreme Court of Pennsylvania reviewed the case and determined that the PLCAA barred the Gustafsons' action. The court found that the action constituted a "qualified civil liability action" under the PLCAA, as it was a civil action against a manufacturer and seller of a qualified product for damages resulting from the criminal or unlawful misuse of a firearm. The court also concluded that the product liability exception did not apply because the discharge of the firearm was caused by a volitional act that constituted a criminal offense.The court further held that the PLCAA was a valid exercise of Congress's Commerce Clause authority and did not violate the Tenth Amendment or principles of federalism. Consequently, the Supreme Court of Pennsylvania vacated the Superior Court's order and remanded the case for reinstatement of the trial court's dismissal of the Gustafsons' complaint. View "Gustafson v. Springfield, Inc." on Justia Law

Several applicants sought licenses to operate video gaming terminals under Pennsylvania's Video Gaming Act, which requires applicants to demonstrate "good character, honesty, and integrity." The Pennsylvania Gaming Control Board denied the applications of Todd Teitelbaum, Michael Brozzetti, and Frank Brozzetti, citing their involvement in the skill games industry, which the Board viewed as unregulated and problematic. The Board's decision was based on general criticisms of the skill games industry, including the lack of regulatory safeguards and the economic impact on casinos and the lottery.The Commonwealth Court reviewed the Board's decision and reversed it, finding that the Board's rationale was insufficient. The court noted that the Board's decision relied solely on generalizations about the skill games industry and did not provide specific evidence regarding the applicants' personal character, honesty, or integrity. The court highlighted the absence of any criminal convictions, tax evasion, connections to organized crime, or other nefarious conduct by the applicants. The Commonwealth Court concluded that the Board's decision was arbitrary and an abuse of discretion.The Supreme Court of Pennsylvania reviewed the case and agreed with the Commonwealth Court that the Board's decision was arbitrary and capricious. The Supreme Court noted that the Board failed to provide specific evidence regarding the applicants' personal qualities and relied solely on general criticisms of the skill games industry. However, the Supreme Court vacated the Commonwealth Court's order to issue the licenses, remanding the case to the Board for further consideration of the applications without directing any particular outcome. The Supreme Court emphasized that the Board's discretion is not absolute and must be based on reason and specific evidence related to the applicants. View "Brozzetti v. PGCB" on Justia Law

Nicole Simone, a resident in a multi-tenant building, fell and was injured on January 16, 2018, after slipping on ice on a walkway in a common area. She filed a premises liability action against Mohammed Zakiul Alam on December 2, 2019, alleging that he owned, possessed, maintained, and controlled the premises, and was responsible for the common areas. Simone claimed that the ice accumulation was due to damaged or misrouted rain gutters and spouts, and sought damages exceeding $50,000.The Luzerne County Court of Common Pleas dismissed Simone’s complaint on October 7, 2022, for failure to join an indispensable party, specifically Alam’s brother, Mohammed Zafiul Alam, who was a co-owner of the property. The trial court held that all co-owners must be joined in a premises liability action. Simone’s motion to vacate and reconsider was denied, and she appealed to the Superior Court. The Superior Court affirmed the trial court’s decision, relying on precedent that all tenants in common must be joined in such actions.The Supreme Court of Pennsylvania reviewed the case and concluded that a tenant in common who did not exercise possession or control over the property is not an indispensable party in a premises liability action. The court found that liability in such cases is based on possession and control, not mere ownership. Since Alam alone managed and controlled the property, his brother was not an indispensable party. The court reversed the Superior Court’s order and remanded the case for further proceedings. View "Simone v. Zakiul Alam" on Justia Law

Mark R. Schmidt, a workers' compensation attorney, sustained a work-related injury while loading files into a trial bag. His treatment included pain management with medications like OxyContin and Oxycodone. To avoid increasing his medication dosage, his physician, Dr. Murphy, prescribed CBD oil. Schmidt purchased CBD oil and lotion over the counter and used them as directed. He sought reimbursement from his employer, Schmidt, Kirifides and Rassias, PC, for the CBD oil costs, which the employer refused, arguing that CBD oil is not a pharmaceutical drug.A Workers' Compensation Judge (WCJ) granted Schmidt's penalty petition, ordering the employer to reimburse him for the CBD oil costs. The Workers' Compensation Appeal Board (Board) reversed this decision, stating that Schmidt did not follow the necessary rules for reimbursement and that CBD oil is not a "supply" under the Workers' Compensation Act (WCA) due to the lack of FDA approval. The Commonwealth Court reversed the Board's decision, concluding that CBD oil is a "medicine" or "supply" under the WCA and that Schmidt, not being a provider, was not required to submit standard billing forms for reimbursement.The Supreme Court of Pennsylvania reviewed the case and held that any item prescribed by a health care provider as part of a treatment plan for a work-related injury falls within the meaning of "medicines and supplies" under Section 306(f.1)(1)(i) of the WCA. The court also held that the cost containment provisions of the WCA and related regulations do not apply to claimants who are not providers. Therefore, Schmidt was entitled to reimbursement for the CBD oil costs, and the Commonwealth Court's order was affirmed. View "Schmidt v. Schmidt, Kirifides & Rassias" on Justia Law

Chanel Glover and Nicole Junior, a same-sex married couple, decided to conceive a child using assistive reproductive technology (ART) and a sperm donor. They entered into various contracts with a fertility clinic and a sperm bank, and both signed affidavits expressing their intent for Junior to adopt the child. However, their relationship deteriorated before the child was born, and Glover filed for divorce. Junior sought a court order to establish her parentage of the child, which the family court granted.The Court of Common Pleas of Philadelphia County confirmed Junior as the legal parent of the child, ordered Glover to inform Junior when she went into labor, and required Junior's name to appear on the child's birth certificate. Glover appealed, and the Superior Court affirmed the trial court's decision, holding that Junior established parentage through contract principles, equitable estoppel, and intent-based parentage.The Supreme Court of Pennsylvania reviewed the case and held that none of the existing pathways to establish legal parentage—biology, adoption, equity, or contract—applied to the facts of this case. The court adopted the doctrine of intent-based parentage into Pennsylvania common law, recognizing that the parties' mutual intent to conceive and raise the child together, as evidenced by their actions and agreements, established Junior's parentage. The court affirmed the Superior Court's decision on the ground of intent-based parentage, emphasizing that this doctrine aligns with public policy and the evolving concept of family. View "Glover v. Junior" on Justia Law

Keith Lamar Foster was interviewed by Detective Bryan Sellers regarding a sexual assault case. Foster voluntarily went to the police station, was not restrained, and was allowed to use his cell phone. During the interview, Detective Sellers told Foster he was not a suspect, despite having obtained a search warrant for Foster’s DNA. Foster provided a DNA sample, which later matched the DNA found on the victim, leading to his arrest and charges of rape and sexual assault.The Court of Common Pleas of Allegheny County granted Foster’s motion to suppress his statements, ruling that the detective’s misrepresentation rendered Foster’s statement involuntary. The court found that the detective’s statement deprived Foster of his ability to make a free and unconstrained choice to undergo the interview.The Superior Court of Pennsylvania reversed the suppression order, concluding that under the totality of the circumstances, Foster’s statement was voluntary. The court noted that Foster was not in custody, the interview was non-coercive, and Foster voluntarily provided his DNA sample.The Supreme Court of Pennsylvania affirmed the Superior Court’s decision. The court held that a misrepresentation by police that an interviewee is not a suspect does not per se render a statement involuntary under the Fifth Amendment. The court emphasized that the totality of the circumstances test remains the proper standard for determining voluntariness. The court found that Foster’s statement was voluntary, considering the non-coercive nature of the interview, Foster’s voluntary presence, and his consent to provide a DNA sample. View "Commonwealth v. Foster" on Justia Law

Dr. Omar Almusa, a licensed medical physician and surgeon in Pennsylvania, unlawfully distributed hydrocodone between 2014 and 2018. He pleaded guilty to unlawful dispensing and distributing a controlled substance, conspiracy to distribute, and health care fraud. In 2019, he was sentenced to 24 months in prison followed by three years of supervised release. Consequently, the State Board of Medicine automatically suspended his medical license for at least ten years, effective August 15, 2019.Almusa did not appeal the suspension. In 2020, the General Assembly enacted Act 53, redefining how licensing boards consider criminal offenses, specifying that only drug trafficking offenses (involving at least 100 grams of a controlled substance) warrant automatic suspension. Almusa's offense did not meet this threshold. In 2021, Almusa petitioned for reinstatement of his license, arguing that Act 53 should apply to his case, allowing him to seek reinstatement without waiting ten years.The Board denied his petition, stating that Act 53 did not apply retroactively to suspensions imposed before its enactment. The Commonwealth Court affirmed the Board's decision, interpreting the suspension and reinstatement as a single action requiring a ten-year suspension period.The Supreme Court of Pennsylvania reversed the Commonwealth Court's decision. It held that automatic suspension and reinstatement are separate actions under the Medical Practice Act. The Court found that Act 53, effective December 28, 2020, applies to reinstatement proceedings initiated after this date. Since Almusa's offense did not qualify as drug trafficking under Act 53, the ten-year waiting period did not apply to his reinstatement petition. The Court concluded that Almusa was entitled to have his reinstatement petition considered under the new law. View "Almusa v. State Board of Medicine" on Justia Law