Justia Pennsylvania Supreme Court Opinion Summaries

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

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

A catastrophic multi-vehicle collision occurred in Westmoreland County, Pennsylvania, involving a motorcoach bus, FedEx and UPS tractor-trailers, and other vehicles. The crash resulted in five deaths and numerous injuries, requiring a large emergency response and extensive investigation. Plaintiffs, who resided in various locations across the country and abroad, filed civil lawsuits in the Philadelphia County Court of Common Pleas against several corporate defendants, all of which conduct business nationwide. The defendants sought to transfer the cases to Westmoreland County, arguing that the majority of witnesses, including first responders and investigators, were located there and would face significant hardship if required to travel over 200 miles to Philadelphia for trial.The Philadelphia County Court of Common Pleas granted the defendants’ petitions to transfer venue, finding that the burden on witnesses was substantial and that the doctrine of forum non conveniens warranted transfer. The court noted that the defendants had identified numerous witnesses whose testimony would be material and who would be significantly inconvenienced by the distance. The plaintiffs appealed, and the Superior Court of Pennsylvania reversed, holding that the defendants failed to show that the identified witnesses were “key witnesses” whose testimony was “critical” to the defense, and that the affidavits did not sufficiently detail the necessity of their testimony.The Supreme Court of Pennsylvania reviewed the case and reversed the Superior Court’s order. The Court held that the Superior Court’s imposition of a “key witness” requirement was inconsistent with Pennsylvania precedent. The Supreme Court clarified that a petitioner seeking transfer for forum non conveniens must identify the burdened witnesses and provide a general statement of their expected testimony, but need not show that their testimony is “critical” or “necessary” to the defense. The trial court’s decision to transfer the cases to Westmoreland County was found to be a proper exercise of discretion. View "Tranter v. Z&D Tour, Inc." on Justia Law

In this case, the appellant, Brendan Linton, was riding his bicycle on a heavily trafficked state highway in Butler Township, Pennsylvania. The highway had one lane of travel in each direction, with a speed limit varying from 45 to 55 mph. Pennsylvania State Trooper Joshua Osche observed Linton riding his bicycle at speeds significantly lower than the posted speed limits, causing a buildup of traffic behind him. Despite multiple vehicles successfully passing Linton, Trooper Osche eventually initiated a traffic stop, citing Linton for impeding the normal and reasonable movement of traffic under Section 3364(b)(2) of the Vehicle Code.The Court of Common Pleas of Butler County found Linton guilty of violating Section 3364(b)(2), concluding that he should have moved to the berm area to allow faster-moving traffic to pass. The court imposed a $25 fine. The Superior Court of Pennsylvania affirmed the judgment, agreeing that Linton's failure to use the berm constituted a violation of the statute.The Supreme Court of Pennsylvania reviewed the case to determine whether Section 3364(b)(2) requires pedalcyclists to leave the roadway whenever faster-moving traffic approaches. The Court concluded that the statute calls for a fact-bound assessment of reasonableness, taking all relevant considerations into account. The Court held that there may be circumstances under which a factfinder could determine that the "reasonable efforts" a pedalcycle operator must exert include temporarily leaving the roadway. However, the Court rejected the rigid interpretations of both the appellant and the lower courts, emphasizing that the statute does not mandate pedalcyclists to always vacate the roadway for faster-moving traffic.The Supreme Court reversed the Superior Court's order and remanded the case for further proceedings consistent with its opinion, instructing the lower court to reconsider the sufficiency of the evidence using the proper legal standard. View "Commonwealth v. Linton" 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

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

Appellants CKHS, Inc. and The Foundation for Delaware County sought a preliminary injunction to prevent Appellees Prospect Medical Holdings, Inc. and Prospect Crozer, LLC from converting Delaware County Memorial Hospital from an emergency and acute care facility to a behavioral health hospital. The asset purchase agreement (APA) between the parties included clauses requiring Prospect to maintain key service lines, including emergency medicine, for five years and to consult with a local advisory board before making significant changes after that period. Additionally, the APA stipulated that any breach would cause irreparable damage.The Delaware County Court of Common Pleas granted the preliminary injunction, finding that Appellants demonstrated the necessary prerequisites, including irreparable harm. The court relied on the APA's irreparable harm clause and expert testimony from Melissa Lyon, who testified that removing healthcare access points from a community almost always negatively impacts health outcomes, particularly for socioeconomically disadvantaged and elderly populations.The Commonwealth Court reversed the trial court's order, concluding that the trial court abused its discretion by finding irreparable harm based on speculative and hypothetical evidence. The Commonwealth Court held that the APA's irreparable harm clause alone was insufficient and required concrete evidence of harm, which it found lacking in Lyon's testimony.The Supreme Court of Pennsylvania reviewed the case and determined that the Commonwealth Court misapplied the appellate standard of review, which requires a highly deferential approach to the trial court's decision. The Supreme Court found that the trial court had apparently reasonable grounds to issue the preliminary injunction based on Lyon's testimony and the APA's irreparable harm clause. Consequently, the Supreme Court reversed the Commonwealth Court's order and remanded the case for further proceedings to address the remaining factors for preliminary injunctive relief. View "CKHS, Inc. v. Prospect Med Hldgs, Inc." on Justia Law

Alcatel-Lucent USA Inc. (Alcatel) challenged the constitutionality of Pennsylvania's 2014 cap on net-loss carryover (NLC) deductions for corporate net income (CNI) tax. The cap allowed corporations to carry forward net operating losses up to the greater of $4 million or 25% of the company's 2014 net income. Alcatel, with a net income of $27,332,333 and accumulated losses exceeding that amount, could only carry over $6,833,083 due to the cap, resulting in a taxable income of around $20 million and a tax liability of approximately $2 million. Alcatel paid the tax and sought a refund, arguing the cap violated the Uniformity Clause of the Pennsylvania Constitution.The Department of Revenue's Board of Appeals and the Board of Finance and Revenue denied Alcatel's refund request, citing lack of authority to decide constitutional issues. Alcatel then appealed to the Commonwealth Court, which initially affirmed the Board's decision, applying the Chevron test and concluding that the Nextel decision should not apply retroactively. However, after the Pennsylvania Supreme Court's decision in General Motors Corp. v. Commonwealth, which held that Nextel applies retroactively, an en banc panel of the Commonwealth Court reversed the earlier decision, sustaining Alcatel's exceptions and ordering a refund.The Supreme Court of Pennsylvania reviewed the case and concluded that the General Motors decision was erroneous. The Court held that Nextel should apply only prospectively, not retroactively, as it established a new principle of law. The Court applied the Chevron test, determining that retroactive application would not further the operation of the rule and would cause significant financial harm to the Commonwealth. Consequently, the Court reversed the Commonwealth Court's decision, ruling that due process does not require the Commonwealth to refund the taxes paid by Alcatel in 2014. View "Alcatel-Lucent USA Inc. v. Commonwealth" on Justia Law