Justia Pennsylvania Supreme Court Opinion Summaries

The Supreme Court of Pennsylvania held that the Pennsylvania Interscholastic Athletic Association (PIAA) is subject to the Right to Know Law’s record-disclosure mandates. The PIAA is a non-profit corporation and voluntary-member organization which organizes interscholastic athletics and promotes uniform standards in interscholastic sports. In 2020, Simon Campbell, a private citizen, filed a records request under the Right to Know Law seeking eight categories of records from the PIAA. The PIAA objected, asserting it is not a Commonwealth authority or entity subject to the Right to Know Law, and noted its intent to litigate the issue. The court found that the inclusion of PIAA in the definition of a state-affiliated entity, a subset of the definition of a Commonwealth agency, indicates that the General Assembly intended to subject PIAA to the Right to Know Law's record-disclosure scheme. Furthermore, the court found that the General Assembly did not mean the phrase "Commonwealth entity" to be strictly limited to official government agencies. Instead, the Assembly intended the phrase to include organizations that perform some role associated with statewide governance. View "Pennsylvania Interscholastic Athletic Association, Inc. v. Campbell" on Justia Law

The Supreme Court of Pennsylvania ruled in favor of the Ivy Hill Congregation of Jehovah’s Witnesses, finding that the Commonwealth Court violated the coordinate jurisdiction rule by dismissing the Congregation's petition against the Department of Human Services. According to the faith's tenets, congregation elders are obligated to maintain the confidentiality of confessions, which might include confessions of child abuse. The Pennsylvania Child Protective Services Law (“CPSL”) identifies certain individuals, including clergymen, as mandated reporters of child abuse. The Congregation filed a petition for review, asking for a declaration on whether their elders are entitled to the clergyman privilege, which would protect them from the mandatory reporting requirements of the CPSL. The Commonwealth Court dismissed the petition, reasoning that the Department of Human Services was not a proper defendant and that declaratory relief would not terminate the controversy. However, the Supreme Court of Pennsylvania held that this dismissal violated the coordinate jurisdiction rule as it directly contradicted the Commonwealth Court's prior determination on the same issues. The case was remanded for further proceedings. View "Ivy Hill Cong. of Jehovah Witnesses v. DHS" on Justia Law

The Supreme Court of Pennsylvania affirmed the decision of the Commonwealth Court confirming certain modifications to a recovery plan for the City of Chester under the Municipalities Financial Recovery Act, commonly known as Act 47. The case arose from the City of Chester's financial distress, which led to the appointment of a receiver. The receiver sought to modify the existing recovery plan due to the City’s challenges and the failure of local officials to cooperate with his efforts. The City objected to several initiatives in the modified plan, arguing they unlawfully deprived its elected officials of their authority to govern on behalf of the residents. The Supreme Court held that the modifications were necessary to achieve financial stability in the City and were not arbitrary, capricious, or wholly inadequate to alleviate the City's fiscal emergency. The court emphasized that the financial health of the municipality was paramount and that local officials must accept the measures necessary for recovery, whether they like it or not. View "Dept of Comm and Econ Dev v. City of Chester" on Justia Law

In Pennsylvania, a group of casinos, including Greenwood Gaming and Entertainment, Inc., Mountainview Thoroughbred Racing Association, LLC, and Chester Downs and Marina, LLC, sued the Pennsylvania Department of Revenue. The casinos claimed that online games offered by the state lottery simulated slot machines, violating restrictions imposed by the state legislature and infringing on the casinos' share of the online market. The Commonwealth Court disagreed and dismissed their complaint.Upon appeal, the Supreme Court of Pennsylvania found that the Commonwealth Court erred in its interpretation of the law by focusing on individual components of an online lottery game. The Supreme Court held that determining whether an online lottery game violates the prohibition against simulating a slot machine requires a subjective assessment of the game's overall appearance and effect when in play.The Supreme Court vacated the order of the Commonwealth Court and remanded the case for further proceedings, instructing the lower court to focus on the overall presentation and effect of the challenged game, not on individual features. View "Greenwood Gaming v. Dept. of Rev." on Justia Law

In this case, the Supreme Court of Pennsylvania was called upon to determine whether the ascension of an unclassified service employee to a classified service position with higher pay with the same public employer is a promotion under the Civil Service Reform Act (CSRA) and the Veterans’ Preference Act (VPA). The case arose when Ralph E. Lynn, a classified service employee, and Aaron Novotnak, an unclassified service employee, both veterans, applied for a classified service position with the Department of Corrections (DOC). The Office of Administration (OA) deemed the position a promotion for Lynn and did not apply veterans’ preference, while it deemed the position an appointment for Novotnak and applied veterans’ preference. The DOC selected Novotnak for the position, and Lynn appealed to the State Civil Service Commission.The Supreme Court of Pennsylvania held that the ascension of an unclassified service employee to a classified service position with higher pay with the same public employer is not a promotion under the CSRA and the VPA, but rather an appointment. Therefore, it is not discriminatory under section 2704 of the CSRA to award a veterans’ preference to an unclassified service employee seeking an appointment but not to a classified service employee seeking a promotion. The court affirmed the order of the Commonwealth Court in part and reversed in part. The court ruled that Lynn was not entitled to veterans’ preference as he was seeking a promotion, not an appointment. However, Lynn will remain in his position due to a separate issue of technical discrimination that was not reviewed by the court. View "Department of Corrections v. Lynn" on Justia Law

In April 2017 and June 2017, Appellant Diane Zilka filed petitions with the Philadelphia Department of Revenue (the “Department”), seeking refunds for the Philadelphia Tax she paid from 2013 to 2015, and in 2016, respectively. During the relevant tax years, Appellant resided in the City, but worked exclusively in Wilmington, Delaware. Thus, she was subject to four income taxes (and tax rates) during that time: the Philadelphia Tax; the Pennsylvania Income Tax (“PIT”); the Wilmington Earned Income Tax (“Wilmington Tax”); and the Delaware Income Tax (“DIT”). The Commonwealth granted Appellant credit for her DIT liability to completely offset the PIT she paid for the tax years 2013 through 2016; because of the respective tax rates in Pennsylvania versus Delaware, after this offsetting, Appellant paid the remaining 1.93% in DIT. Although the City similarly credited against Appellant’s Philadelphia Tax liability the amount she paid in the Wilmington Tax — specifically, the City credited Appellant 1.25% against her Philadelphia Tax liability of 3.922%, leaving her with a remainder of 2.672% owed to the City — Appellant claimed that the City was required to afford her an additional credit of 1.93% against the Philadelphia Tax, representing the remainder of the DIT she owed after the Commonwealth credited Appellant for her PIT. After the City refused to permit her this credit against her Philadelphia Tax liability, Appellant appealed to the City’s Tax Review Board (the “Board”). The issue this case presented for the Pennsylvania Supreme Court's review as whether, for purposes of the dormant Commerce Clause analysis implicated here, state and local taxes had to be considered in the aggregate. The Court concluded state and local taxes did not need be aggregated in conducting a dormant Commerce Clause analysis, and that, ultimately, the City’s tax scheme did not discriminate against interstate commerce. Accordingly, the Court affirmed the Commonwealth Court order. View "Zilka v. Tax Review Bd. City of Phila." on Justia Law

The Commonwealth of Pennsylvania, Department of Transportation; Yassmin Gramian, individually; Michael Carroll, in his capacity as Acting Secretary of the Department of Transportation; and Melissa Batula, P.E., individually and in her capacity as Acting Executive Deputy Secretary for the Department of Transportation (collectively, PennDOT) appealed a Commonwealth Court order that denied, in part, and granted, in part, a “Motion for Adjudication of Civil Contempt or in the Alternative . . . Motion for a Preliminary Injunction” (PI Motion) filed by Glenn O. Hawbaker, Inc. (Hawbaker). Pertinent here, the Commonwealth Court’s order preliminarily enjoined PennDOT from proceeding with any action for the debarment of Hawbaker as a prequalified bidder on PennDOT construction contracts based upon criminal charges filed against Hawbaker or Hawbaker’s subsequent entry of a corporate nolo contendere plea to those criminal charges. After review, the Supreme Court agreed with PennDOT that the Commonwealth Court erred in exercising equitable jurisdiction to award Hawbaker preliminary injunctive relief in this matter. Accordingly, the Court reversed the Commonwealth Court order, and remand the matter for further proceedings. View "Glenn Hawbaker, Inc. v. PennDOT" on Justia Law

The Pennsylvania Supreme Court considered a class action challenge to the constitutionality of Act 12 of 2019 (“Act 12”),3 which, inter alia, enacted changes to the Pennsylvania Human Services Code. In particular, the Court had to determine whether the lawmaking which culminated in the passing of Act 12 satisfied the state Constitution's Article III requirements. The Court held that the process by which the General Assembly passed Act 12 satisfied both the “original purpose” and “single subject” mandates found in Article III of the Pennsylvania Constitution. Thus, the Court affirmed the order of the Commonwealth Court and found the statutory enactment to be constitutional. View "Weeks, et al. v. Dept. Health Serv." on Justia Law

In 2015, the Department of Transportation (“PennDOT”) began constructing a diamond interchange and installing a drainage system on property abutting Interstate 70 (“I-70”) in Washington County, Pennsylvania. The property’s owner, Appellant Donald Bindas, petitioned for the appointment of a board of viewers, seeking compensation for this encumbrance upon his land. PennDOT asserted that its predecessor, the Department of Highways (“DOH”), had secured a highway easement for the land in question in 1958. Both the trial court and the Commonwealth Court agreed, dismissing Bindas’ suit. Upon its review of the statutory authority that PennDOT invoked, as well as the record, the Pennsylvania Supreme Court found that DOH’s failure to comply with the requirements of 36 P.S. § 670-210 rendered that easement invalid. Accordingly, the Court vacated the Commonwealth Court’s order, and remanded with the instruction that PennDOT’s preliminary objections be overruled. View "Bindas. v. PennDOT" on Justia Law

The issue this case presented for the Pennsylvania Supreme Court's consideration was whether the Commonwealth Court abused its discretion when, sua sponte, it issued a remand to the Office of Open Records (“OOR”) for additional fact-finding after that court already had determined that the agency subject to the record request failed to meet its burden of proving that an exception to disclosure requirements applied. To this the Court concluded that such an abuse of discretion occurred, and accordingly judgment was reversed. The Court remanded this matter to the Commonwealth Court for further proceedings. View "PA State Police v. ACLU of PA" on Justia Law