Justia Pennsylvania Supreme Court Opinion Summaries

In 2016, voters in Donegal Township, Washington County, Pennsylvania, decided to increase the number of members on the township’s board of supervisors from three to five. Subsequently, in 2020, the voters opted to reduce the number back to three. This led to a legal dispute involving Richard Martin, Jr., Richard Fidler, and Tammy Iams, who were elected to the five-member board but faced shortened terms due to the reduction.The Court of Common Pleas of Washington County initially dismissed the action brought by Martin, Fidler, and Iams, who challenged the constitutionality of Section 402(e) of the Second Class Township Code. The Commonwealth Court partially reversed this decision, ruling that Section 402(e) was unconstitutional as applied to Martin and Fidler, as it effectively removed them from office before their terms expired, contrary to Article VI, Section 7 of the Pennsylvania Constitution.The Supreme Court of Pennsylvania reviewed the case and focused on whether Section 402(e) was unconstitutionally applied. The Court held that Section 402(e) did not result in the removal of Martin and Fidler from office but rather modified their terms due to the reduction in the number of supervisors. The Court emphasized that Article VI, Section 7 of the Pennsylvania Constitution, which provides the exclusive method for removing elected officials, was not applicable because the statute did not involve removal but rather a lawful modification of legislative office terms.The Supreme Court of Pennsylvania reversed the Commonwealth Court's decision, upholding the application of Section 402(e) and concluding that it did not violate the Pennsylvania Constitution. The Court found that the reduction in the number of supervisors and the subsequent election for the new three-member board were constitutionally permissible actions by the legislature. View "Martin v. Donegal Township" on Justia Law

Circle of Seasons Charter School (Charter School) purchased two properties from The Pennsylvania State University (PSU) in May 2017. These properties were previously tax-exempt as part of PSU's Lehigh Valley Campus. Following the sale, Lehigh County issued assessment notices changing the properties' status from non-taxable to taxable, effective January 1, 2018. The notices did not include the required mailing date. Charter School claimed it did not receive these notices and subsequently did not pay the 2017 and 2018 tax bills until refinancing the properties in June 2018.The Lehigh County Court of Common Pleas sustained the preliminary objections of Northwestern Lehigh School District (School District) and dismissed Charter School's complaint with prejudice. The trial court found that Charter School had actual notice of the tax assessments by November 2017 and could have addressed the taxes in its 2018 annual appeal to the Lehigh County Board of Assessment Appeals (the Board). The Board granted tax-exempt status effective January 1, 2019, but Charter School did not seek retroactive relief or a refund for the taxes paid for 2017 and 2018.The Commonwealth Court reversed the trial court's decision, ruling that the defective notices entitled Charter School to a nunc pro tunc hearing before the Board to determine the validity of the assessment changes and potential refunds. The court emphasized that the omission of the mailing date on the notices was a significant defect, warranting a new hearing.The Supreme Court of Pennsylvania reversed the Commonwealth Court's decision, reinstating the trial court's order. The Supreme Court held that Charter School had the burden to establish the properties' tax-exempt status and failed to do so in a timely manner. The court concluded that Charter School waived its claims by not seeking retroactive relief or a refund during the 2018 appeal and that nunc pro tunc relief was not warranted. View "Circle of Seasons Chart School v. Northwestern Lehigh School District" on Justia Law

The case involves the District Attorney (DA) of Philadelphia, who challenged articles of impeachment passed by the Pennsylvania House of Representatives. The articles were transmitted to the Senate on the last day of the 206th General Assembly session. The DA argued that the articles became null and void upon the session's expiration, and the new Senate could not conduct a trial based on them.The Commonwealth Court initially denied the DA's request for summary relief, ruling that the impeachment articles did not expire with the session's end. The court also found that the DA, as a local official, could be impeached under the Pennsylvania Constitution. However, the court agreed with the DA that some articles of impeachment did not allege conduct amounting to "misbehavior in office" and that certain articles intruded on the judiciary's exclusive authority to govern attorney conduct.The Supreme Court of Pennsylvania reviewed the case. The court first addressed the justiciability of the issue, concluding that it had the authority to determine whether the impeachment articles expired with the session's end. The court emphasized that the Constitution must be read as an integrated whole, and the General Assembly's powers, including impeachment, are limited to the duration of its session.The court held that the articles of impeachment became null and void upon the expiration of the 206th General Assembly session. Consequently, the Senate of the 207th General Assembly could not conduct a trial based on those articles. The court reversed the Commonwealth Court's order denying the DA's request for summary relief on this issue. View "Krasner v. Ward" on Justia Law

The case involves the Pennsylvania Department of Environmental Protection (DEP) developing a rulemaking package to join the Regional Greenhouse Gas Initiative (RGGI), aimed at reducing CO2 emissions from power plants. The RGGI Regulation faced opposition from the Pennsylvania Legislative Reference Bureau (LRB) and other state officials, leading to litigation. Three nonprofit environmental organizations (Nonprofits) sought to intervene in the litigation to defend the RGGI Regulation, citing environmental and health concerns.The Commonwealth Court initially denied the Nonprofits' application to intervene, ruling that their interests were adequately represented by DEP. The court also granted a preliminary injunction against the RGGI Regulation. Nonprofits appealed both the denial of intervention and the preliminary injunction.The Supreme Court of Pennsylvania reviewed the case. It found that the Nonprofits had established a substantial, direct, and immediate interest in the outcome of the litigation, based on the testimony of their members regarding the adverse health and environmental impacts of CO2 emissions. The court determined that DEP did not adequately represent the Nonprofits' interests, particularly because DEP had not invoked the Environmental Rights Amendment (ERA) in its defense of the RGGI Regulation.The Supreme Court of Pennsylvania reversed the Commonwealth Court's decision denying the Nonprofits' application to intervene, allowing them to participate as parties in the ongoing litigation. However, the appeal from the preliminary injunction was dismissed as moot because the Commonwealth Court had already issued a permanent injunction against the RGGI Regulation, superseding the preliminary injunction. View "Shirley v. PA Legislative Reference Bureau" on Justia Law

Stadium Casino RE, LLC ("Stadium") contested the Pennsylvania Gaming Control Board's ("Board") decision to award a Category 4 slot machine license to SC Gaming OpCo, LLC and Ira Lubert (collectively "SC Gaming"). Stadium argued that Lubert's bid was invalid because it was funded by individuals not authorized to participate in the auction, and that the Board should have awarded the right to apply for the license to Stadium as the second-highest bidder or conducted another auction.The Commonwealth Court initially reviewed the case, where Stadium sought declarations that Lubert's bid was invalid and that the Board lacked authority to consider SC Gaming's application. Stadium also sought an injunction to stop the Board from considering SC Gaming's application and requested a mandamus order to allow Stadium to apply for the license or to conduct another auction. The Board and SC Gaming filed preliminary objections, which the Commonwealth Court overruled, ordering them to file answers. Meanwhile, the Board proceeded with SC Gaming's licensing application, allowing Stadium to intervene but denying its discovery requests. The Board ultimately granted SC Gaming's application and issued an adjudication supporting its decision.The Supreme Court of Pennsylvania reviewed the case, focusing on whether the Board exceeded its statutory authority and failed to comply with mandatory directives in the Gaming Act. The Court found that the Board had the authority to conduct the auction and licensing proceedings and that Section 1305.2(c) of the Gaming Act did not impose jurisdictional limitations on the Board's ability to act. The Court held that the Board's procedures and findings, including the determination that SC Gaming was wholly owned by Lubert, were within its discretion and supported by the evidence. Consequently, the Court affirmed the Board's decision to award the license to SC Gaming and dismissed the action pending in the Commonwealth Court as moot. View "Stadium Casino RE, LLC v. Pennsylvania Gaming Control Board" on Justia Law

AUUE, Inc. applied for a zoning permit to develop a medical center, including a hospital, medical clinic, and professional offices, on five parcels of land in Jefferson Hills Borough. The Borough's Zoning Officer issued a use permit, recognizing that the proposed use was allowed by right in the Office Park District (O-P District), but conditioned the permit on AUUE obtaining further approvals before any development could commence. Residents of Jefferson Hills appealed, arguing that the application violated several provisions of the Borough’s Zoning Ordinance.The Zoning Hearing Board (ZHB) overturned the Zoning Officer’s decision, concluding that the proposed medical center was not permitted by right in the O-P District and that the Zoning Officer exceeded his authority by issuing a permit without ensuring full compliance with the Ordinance. The ZHB identified several violations in the application, including improper use of accessory parking lots and lack of direct access to a collector or arterial road.The Commonwealth Court reversed the ZHB’s decision, holding that the Zoning Officer had the authority to issue a use permit recognizing the proposed use as allowed by right in the O-P District. The court found that the ZHB should have limited its review to whether the proposed use was permitted by right, rather than considering overall compliance with the Ordinance.The Supreme Court of Pennsylvania affirmed the Commonwealth Court’s decision. It held that the Zoning Officer had the authority to issue a use permit for the limited purpose of recognizing that the proposed use was allowed by right in the O-P District. The ZHB was required to limit its review to this issue and was not permitted to overturn the Zoning Officer’s decision based on other potential violations of the Ordinance. View "AUUE, Inc. v. Borough of Jefferson Hills" on Justia Law

In a case involving the Pennsylvania Liquor Control Board (PLCB), the Supreme Court of Pennsylvania was asked to determine whether the PLCB is a "person" under Section 8303 of the Judicial Code and, if so, whether sovereign immunity bars mandamus damages sought under that provision. The case arose from the PLCB's failure to implement procedures to facilitate the direct shipment of special orders to customers, as required by law. The Commonwealth Court had issued a declaratory judgment to that effect and a writ of mandamus compelling the PLCB to comply. The Wine Vendors and Log Cabin subsequently applied for mandamus damages under Section 8303, which the PLCB contested, arguing that it was not a "person" under the statute and that sovereign immunity barred such damages.The Supreme Court of Pennsylvania held that the PLCB is a "person" within the meaning of Section 8303 and that sovereign immunity does not bar mandamus damages available under that provision. The court also held that attorneys’ fees awarded in relation to Section 8303 are not barred by sovereign immunity. The court affirmed the holdings of the Commonwealth Court and remanded for further proceedings. View "MFW WINE CO., LLC v. PENNSYLVANIA LIQUOR CONTROL BOARD" on Justia Law

The case involves Marcus Womack, who was arrested in 2017 following a search warrant executed at a residence in Huntingdon County, Pennsylvania. The search revealed that Womack had been selling drugs from the location, and he was found in possession of a large sum of money, drugs, and a stolen firearm. On the same day, a criminal complaint was filed against Womack, charging him with nine offenses. Unable to post bail, Womack remained in custody. Subsequent investigations revealed that Womack's drug enterprise extended beyond Huntingdon County, leading to the involvement of the Office of the Attorney General (OAG) and a statewide investigating grand jury. In 2018, a second criminal complaint was filed against Womack, charging him with twenty-eight offenses based on evidence gathered during the grand jury investigation.The trial court denied Womack's motion to dismiss the second complaint under Pa.R.Crim.P. 600(D)(1), which requires a trial to commence within 365 days from the date the complaint is filed. Womack's motion to dismiss the first complaint on the same grounds was granted. Womack was found guilty of several offenses in a bench trial on the second complaint and was sentenced to an aggregate term of 39 to 90 years’ imprisonment. He appealed to the Superior Court, arguing that the computation of time for Rule 600 purposes should have been based on the filing date of the first complaint. The Superior Court affirmed the trial court's decision.The Supreme Court of Pennsylvania affirmed the Superior Court’s order denying relief. The court applied the test from Commonwealth v. Meadius, which requires the Commonwealth to demonstrate due diligence between the period in which the complaints were filed, establish that the filing of the second complaint was necessitated by factors beyond its control, and show that its actions were not an attempt to circumvent or manipulate the speedy trial requirements. The court found that the Commonwealth met these requirements, and therefore, the Rule 600 clock began when the second complaint was filed. View "Commonwealth v. Womack" on Justia Law

The case involves the Pennsylvania Public Utility Commission (PUC) and the City of Lancaster, Borough of Carlisle, and Borough of Columbia (collectively referred to as the Municipalities). The dispute centers around Section 59.18 of the PUC’s regulations, which gives natural gas distribution companies (NGDCs) the authority to determine the location of gas meters in historic districts. The Municipalities argued that this regulation violates Article II, Section 1 of the Pennsylvania Constitution, which vests legislative power in the General Assembly, not in private entities like NGDCs.The Commonwealth Court agreed with the Municipalities, concluding that Section 59.18 unlawfully delegates legislative authority to NGDCs without providing adequate standards to guide their decisions. The court therefore declared Section 59.18 unenforceable.The PUC appealed this decision to the Supreme Court of Pennsylvania. The PUC argued that Section 59.18 does not delegate legislative power to NGDCs, but rather is a regulatory act under the PUC’s administrative authority. The PUC also contended that the Commonwealth Court failed to consider the safety issues related to meter placement, which is the primary concern of the regulation.The Supreme Court of Pennsylvania reversed the decision of the Commonwealth Court. The court found that the General Assembly never enacted a statute giving the PUC legislative authority to determine the location of gas meters in historic districts. Therefore, the PUC could not have unlawfully delegated this authority to NGDCs. The court concluded that the Municipalities' disagreement with the PUC's regulation does not amount to a constitutional violation. The case was remanded to the Commonwealth Court for further proceedings. View "City of Lancaster v. PUC" on Justia Law

The primary issue in this complex case concerned a man, Ronnie Lehman, who was residing at a residential program called the Renewal Center as a condition of his parole. While there, he was discovered unresponsive due to a drug overdose, and a search revealed possession of illegal drugs. He was charged under Section 5123(a.2) of the Crimes Code, which prohibits a prisoner or inmate from unlawfully possessing a controlled substance. Lehman's legal team argued that he didn't qualify as an "inmate" under this law because he was on parole and voluntarily living at the Renewal Center.The Supreme Court of Pennsylvania disagreed, concluding that Lehman did qualify as an "inmate" under Section 5123(a.2), (e) of the Crimes Code at the time he unlawfully possessed a controlled substance. The court reasoned that the term "committed to" in the statute didn't necessarily imply forceful or involuntary commitment, and could encompass Lehman's situation where he agreed to reside at the Renewal Center as a part of his parole conditions. Therefore, the court held that the evidence was sufficient to sustain Lehman's conviction under Section 5123(a.2), and reversed the judgment of the Superior Court which had granted Lehman post-conviction relief. View "Commonwealth v. Lehman" on Justia Law