Justia Pennsylvania Supreme Court Opinion Summaries

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

Cedric Galette initiated a negligence action against Julie McCrey and New Jersey Transit (NJ Transit) in the Court of Common Pleas of Philadelphia County. Galette alleged that he was injured when a vehicle operated by McCrey, in which he was a passenger, was struck by an NJ Transit vehicle. NJ Transit, an instrumentality of the State of New Jersey, filed a motion to dismiss the suit, invoking interstate sovereign immunity. The trial court denied the motion.NJ Transit appealed to the Superior Court, which affirmed the trial court's decision. The Superior Court held that NJ Transit is not an instrumentality or arm of the State of New Jersey and, therefore, is not entitled to sovereign immunity protections. The court applied a six-factor test from Goldman v. Southeastern Pennsylvania Transportation Authority to determine NJ Transit's status and concluded that the factors did not support NJ Transit's claim to sovereign immunity.The Supreme Court of Pennsylvania reviewed the case to determine whether the United States Supreme Court's decision in Franchise Tax Board of California v. Hyatt (Hyatt III) compels a conclusion that interstate sovereign immunity bars Galette’s suit against NJ Transit. The court held that NJ Transit is indeed an arm of the State of New Jersey, emphasizing the statutory classification of NJ Transit as an instrumentality of the state, the degree of control the state exercises over it, and its core function of providing public transportation, which is a governmental function. Consequently, the court reversed the Superior Court's judgment, resulting in the dismissal of Galette’s suit against NJ Transit. The case was remanded to the trial court for further proceedings regarding Galette’s claims against McCrey. View "Galette v. New Jersey Transit" on Justia Law

In 2007, Richard Roland Laird was sentenced to death following his retrial for first-degree murder, having originally been convicted and sentenced to death in 1988 for the same offense. Laird's most recent appeal challenges the denial of his latest Post Conviction Relief Act (PCRA) petition as untimely. He requested the Pennsylvania Supreme Court to create an equitable exception to the PCRA’s time-bar, citing the decision in Commonwealth v. Bradley, and also argued that Article 7 of the International Covenant on Civil and Political Rights (ICCPR) precluded the dismissal of his petition as untimely.The Court of Common Pleas of Bucks County denied Laird’s PCRA petition, finding it untimely and not meeting any statutory exceptions. The court also rejected Laird’s claims on the merits, including ineffective assistance of counsel (IAC) claims and an illegal sentencing claim. Laird’s appeal to the Pennsylvania Supreme Court followed.The Pennsylvania Supreme Court affirmed the lower court’s decision, holding that Bradley did not establish an equitable exception to the PCRA’s time-bar and that its rationale could not be extended to create one. The court emphasized that the PCRA’s time limitations are jurisdictional and not subject to equitable principles. Additionally, the court held that the ICCPR could not be invoked to circumvent the PCRA’s timeliness requirements, reaffirming that exceptions to the PCRA’s time-bar are strictly limited to those set forth in the statute.Thus, the Pennsylvania Supreme Court affirmed the order denying Laird’s PCRA petition as untimely, concluding that neither Bradley nor the ICCPR provided a basis to bypass the PCRA’s jurisdictional time-bar. View "Commonwealth v. Laird" on Justia Law

A police detective was charged with multiple criminal offenses, including unsworn falsification to authorities, tampering with or fabricating physical evidence, tampering with public records or information, and obstructing administration of law or other governmental function. The charges stemmed from allegations that the detective assisted his cousin in stalking a woman and attempted to cover up his misconduct by using police databases to obtain her information and then lying about it during an internal affairs investigation.The Municipal Court of Philadelphia dismissed the charges against the detective for lack of evidence. The Commonwealth refiled the charges, but the Court of Common Pleas of Philadelphia County also dismissed them, concluding that the Commonwealth failed to establish a prima facie case. The Superior Court of Pennsylvania affirmed the dismissal, agreeing that the evidence was insufficient to support the charges.The Supreme Court of Pennsylvania reviewed the case and reversed the Superior Court's decision. The Court held that the Commonwealth had presented sufficient evidence to establish a prima facie case for each of the charges. The Court found that the detective's actions, including his false statements during the internal affairs investigation and the suspicious addition of a second folder to the homicide file, supported the charges. The Court emphasized that at the preliminary hearing stage, the evidence must be viewed in the light most favorable to the Commonwealth, and all reasonable inferences must be drawn in its favor. The case was remanded for further proceedings. View "Commonwealth v. Williams" on Justia Law