Justia Pennsylvania Supreme Court Opinion Summaries

In 1908, the Bradford County Commissioners sold an unseated tract of land, known as the Haines Warrant, to Calvin H. McCauley, Jr. at a tax sale. Over a century later, the Pennsylvania Game Commission, a successor in interest to McCauley, initiated litigation to determine ownership of various tracts of land in central Pennsylvania. The Third Circuit Court of Appeals asked the Pennsylvania Supreme Court whether the 1908 tax sale constituted a title wash, thereby divesting the owners of the Haines Warrant’s subsurface estate of their interest.The United States District Court for the Middle District of Pennsylvania found that McCauley was acting as an agent for Central Pennsylvania Lumber Company (CPLC) when he purchased the Haines Warrant at the tax sale. The District Court determined that CPLC had a duty to pay the delinquent 1907 taxes, which led to the 1908 tax sale, and thus was barred under the Powell Rule from purchasing more than its prior interest in the Haines Warrant’s surface estate. The court concluded that McCauley’s purchase acted only as a redemption of CPLC’s prior surface interest, leaving the Proctor heirs’ interest in the subsurface estate intact.The Pennsylvania Supreme Court reviewed the case and held that the 1908 tax sale did not constitute a title wash. The Court determined that owners of unseated land had a duty to pay taxes levied on their property, and McCauley’s purchase, as an agent of CPLC, operated merely as a payment of the taxes owed, not as a title wash. Therefore, the purchase did not divest the Proctor heirs of their interest in the Haines Warrant’s subsurface estate. The Court answered the certified question in the negative, affirming that the Proctor heirs retained their subsurface rights. View "Commonwealth v. Proctor" on Justia Law

In 2017, Tower Health, a non-profit corporation, acquired Pottstown Hospital, an acute care facility in Montgomery County, Pennsylvania. Tower Health created a non-profit LLC, Pottstown Hospital, LLC, to manage the hospital. The hospital provides various health services, including emergency care, inpatient and outpatient services, and community outreach. The hospital applied for a charitable real estate tax exemption for three properties, which was initially granted by the Montgomery County Board of Assessment Appeals.The Pottstown School District appealed the exemption to the Montgomery County Court of Common Pleas, arguing that the hospital did not operate entirely free from a profit motive due to high executive compensation and the relationship with Tower Health. The trial court found that the hospital met the criteria for a purely public charity under the HUP test, including operating free from a private profit motive, and upheld the tax exemption. The court noted that the hospital provided substantial uncompensated care and that executive compensation was reasonable and within market value.The Commonwealth Court reversed the trial court's decision, focusing on the compensation of Tower Health's executives and the management fees charged to the hospital. The court concluded that the hospital did not operate free from a private profit motive, as a substantial portion of executive compensation was tied to financial performance.The Supreme Court of Pennsylvania reviewed the case and held that the compensation of Tower Health's executives and the management fees were not relevant to the hospital's tax exemption status. The court emphasized that only the hospital's operations and executive compensation should be considered. The court found that the hospital's executive compensation was reasonable and within market value, thus meeting the HUP test. The Supreme Court reversed the Commonwealth Court's decision and reinstated the trial court's order granting the tax exemption. View "Pottstown SD v. Mont Co Bd" on Justia Law

In 2012, George Thomas Shifflett was charged with driving under the influence (DUI) and accepted into an Accelerated Rehabilitative Disposition (ARD) program. In 2022, Shifflett was involved in another DUI incident and was charged as a second-time offender based on his previous ARD acceptance. Shifflett pled guilty to the 2022 DUI but contested the use of his 2012 ARD as a prior offense for sentencing purposes, arguing it was unconstitutional under Alleyne v. United States.The Adams County Court of Common Pleas granted Shifflett's motion to exclude evidence of his 2012 ARD and sentenced him as a first-time offender. The Commonwealth appealed, and the Superior Court vacated the sentence, remanding for resentencing as a second-time offender, citing recent Superior Court decisions that overruled Commonwealth v. Chichkin, which had held that using ARD as a prior offense for sentencing was unconstitutional.The Supreme Court of Pennsylvania reviewed the case to determine if considering Shifflett's ARD as a prior offense for sentencing violated Alleyne. The Court held that ARD does not equate to a conviction because it lacks the procedural safeguards of a criminal trial, such as the right to a jury trial and the requirement of proof beyond a reasonable doubt. Therefore, using ARD as a prior offense for sentencing enhancement is unconstitutional under Alleyne.The Court concluded that Section 3806 of the Motor Vehicle Code, which includes ARD in the definition of a prior offense, is facially unconstitutional to the extent it allows ARD to be used for sentencing enhancement. The Court reversed the Superior Court's order and remanded the case for reinstatement of Shifflett's original sentence as a first-time offender. View "Commonwealth v. Shifflett" on Justia Law

Kristina Steets was severely injured in 2017 while working for Celebration Fireworks, Inc. The employer accepted liability for her total disability under the Workers' Compensation Act (WCA) in 2018. In 2019, Steets filed petitions to amend the description of her injuries and sought specific loss benefits. The Workers' Compensation Judge (WCJ) granted her petitions, and the Workers' Compensation Appeal Board (WCAB) and the Commonwealth Court affirmed. However, Steets died from her injuries while the Commonwealth Court's decision was pending.Steets' estate filed petitions seeking payment of the specific loss benefits awarded to her, which were still under appellate review at the time of her death. The WCJ denied the Estate's claims beyond funeral expenses, and the WCAB affirmed. The Commonwealth Court, in a split decision, also affirmed, ruling that specific loss benefits did not survive Steets' work-related death based on the precedent set by Estate of Harris v. WCAB (Sunoco, Inc.).The Supreme Court of Pennsylvania reviewed the case and overruled Estate of Harris and Burns International Security Services, Inc. v. WCAB (Crist), which had held that Section 306(g) of the WCA was the exclusive means by which specific loss benefits survive the death of a worker. The Court held that Section 410 of the WCA applies, which states that if a claimant dies before the final adjudication of their claim, the compensation due to the claimant up to the date of death shall be paid to the dependents or, if there are no dependents, to the estate. Since Steets died before the final adjudication of her specific loss benefits claim, the employer was required to pay those benefits to her estate. The case was remanded to the WCJ to determine the amount of specific loss benefits due to the Estate. View "Steets v. Celebration Fireworks" on Justia Law

A group of appellants, including Firearms Owners Against Crime and two firearms dealers, filed a case against the Pennsylvania State Police (PSP) Commissioner, alleging that PSP was not complying with the Pennsylvania Uniform Firearms Act. The appellants claimed that PSP was intentionally understaffing its Pennsylvania Instant Check System (PICS) Operations Section, leading to significant delays in background checks for firearm purchases, sometimes exceeding seven hours. They argued that these delays violated the statutory requirement for "instantaneous" or "immediate" background checks and caused financial harm to firearms dealers due to canceled transactions.The Commonwealth Court initially issued a preliminary injunction, finding that PSP had a statutory duty to employ sufficient personnel to ensure compliance with the Act and that the delays were causing financial harm to the dealers. However, the court later sustained PSP's preliminary objections, ruling that the statute did not specify a mandatory timeframe for background checks and that the operational decisions regarding staffing were discretionary. The court also dismissed the appellants' request for a refund of the $2.00 background check fee, as the statute did not provide for such refunds.The Supreme Court of Pennsylvania reviewed the case and held that while the statute did not require "instantaneous" responses, it did mandate that PSP provide results as quickly as possible with available resources. The court affirmed the Commonwealth Court's denial of injunctive and mandamus relief, as these would compel affirmative action barred by sovereign immunity. However, the court reversed the denial of declaratory relief, allowing the appellants to seek a judicial declaration of PSP's duties under the Act. The court also vacated the order denying leave to amend the petition, allowing the appellants to include new allegations regarding PSP's response to the preliminary injunction. The case was remanded for further proceedings consistent with these findings. View "Firearms Owners v. Comm'r of PSP" on Justia Law

On December 18, 2018, police responded to a report of check fraud at a bank involving two suspects. One suspect exited the bank and approached a Kia Soul before returning inside. Police located the vehicle with Rasheed Muhammad in the driver’s seat. Upon approaching, the officer detected marijuana and observed Muhammad searching the car’s center console and other areas. Muhammad provided a rental agreement for the car, which was in his name. After backup arrived, Muhammad was asked to exit the vehicle, and a search revealed a loaded firearm in the center console. Muhammad did not have a license to carry a firearm and was arrested after attempting to flee.The Delaware County Court of Common Pleas convicted Muhammad of carrying a firearm without a license and resisting arrest. Muhammad’s motion for acquittal was denied, and he was sentenced to 3 ½ to 7 years in prison for the firearm charge, followed by 2 years of probation for resisting arrest. The Superior Court affirmed the judgment, finding sufficient evidence to support the conviction based on the circumstances, including Muhammad’s proximity to the firearm and his behavior indicating knowledge and intent to conceal it.The Supreme Court of Pennsylvania reviewed whether the jury’s negative answer to a special interrogatory about Muhammad’s possession and control of the firearm rendered the evidence insufficient for his conviction. The court found no conflict between the jury’s answer and the conviction, noting that the interrogatory’s conjunctive phrasing did not negate the elements required for carrying a firearm without a license. The court affirmed the Superior Court’s order, upholding Muhammad’s judgment of sentence. View "Commonwealth v. Muhammad" on Justia Law

In this case, the appellant, Christopher Lynn Johnson, was convicted of first-degree murder and related offenses for the shooting death of Officer David Grove, a Deputy Wildlife Conservation Officer. On the night of November 11, 2010, Officer Grove encountered Johnson and his friend Ryan Laumann spotlighting deer near Gettysburg National Military Park. After stopping Johnson's vehicle, a confrontation ensued, during which Johnson shot Officer Grove multiple times, resulting in his death. Johnson fled the scene but was apprehended the following morning.The Court of Common Pleas of Adams County denied Johnson's petition for relief from his death sentence under the Post Conviction Relief Act (PCRA). Johnson raised multiple claims, including ineffective assistance of counsel, Brady violations, and improper victim impact evidence. The PCRA court held a five-day evidentiary hearing and ultimately found no merit in Johnson's claims. The court determined that Johnson failed to demonstrate prejudice from his counsel's actions and that there was no evidence of an agreement between the Commonwealth and Laumann regarding his testimony.The Supreme Court of Pennsylvania reviewed the case and affirmed the PCRA court's decision. The court found that Johnson's claims of ineffective assistance of counsel lacked merit, as his counsel conducted a thorough investigation and presented a robust mitigation defense during the penalty phase. The court also concluded that Johnson failed to prove any Brady or Napue violations, as there was no agreement between the Commonwealth and Laumann. Additionally, the court held that the victim impact evidence presented was permissible and did not violate Johnson's constitutional rights. Finally, the court determined that the cumulative effect of the alleged errors did not warrant relief. View "Commonwealth v. Johnson" on Justia Law

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