Justia Pennsylvania Supreme Court Opinion Summaries

Cromwell Township appealed a Commonwealth Court's order that sentenced its supervisors to three to six months' imprisonment for contempt. The Department of Environmental Protection (DEP) had approved the Township's comprehensive plan for sewage services, but the Township decided the Plan was too expensive to implement. Despite requesting several extensions of time, the Township failed to implement its plan. At the time, the Orbisonia Rockhill Joint Municipal Authority (ORJMA) which operated public sewage systems including those within the Township, was experiencing an overload in its wastewater treatment plant. The Township Board of Supervisors approached ORJMA and proposed a joint venture that would increase the capacity of ORJMA's plant and simultaneously decrease the anticipated cost to the Township for sewage treatment. The Township submitted an amended Plan which was accepted by the DEP. But prior to implementing the Plan, the Township Board elected new members. New members who openly opposed the Plan repealed the ordinances required under the amended Plan. The Township then stopped cooperating. The DEP filed suit to enforce the Plan asking that fines be levied against Board members and to set a timeline to purge the contempt. The court, unsatisfied with the Township's efforts to purge the contempt sentenced its members to jail time. Upon review, the Supreme Court found that the Township's failing to timely appeal the Plan and its amendment when new supervisors took office meant that the DEP's act was final, and the Township was foreclosed from challenging the Plan. However, the Court found that the Commonwealth Court's failing to use less restrictive means prior to imposing prison sentences on Board members compelled reversal: "the Commonwealth Court had lesser alternatives available to it in its attempt to compel Township's compliance with the court's prior order… but the Commonwealth Court inexplicably refused." The Court reversed the Commonwealth Court's order sentencing Township Board members to imprisonment, and remanded the case for further proceedings. View "Pa. Dept. of Environ. Prot. v. Cromwell Twp." on Justia Law

Appellants Dawn Pyeritz sued the Commonwealth, the Pennsylvania State police and several of its police officers for the destruction of her personal property, speficially "a black nylon tree stand safety harness, or belt, that allegedly was crucial evidence in a separate civil action." The police seized this item during a criminal investigation of a suspicious death. A trooper agreed to retain the belt in the custody of the police, apparently for a longer time than permitted by internal police regulations. The belt was destroyed before Appellants' counsel asked for its return. The trial court granted summary judgment to the Appellees, which the Commonwealth Court affirmed. The Commonwealth Court held that no cause of action exists against a third party – someone other than the original alleged tortfeasor – for negligent spoliation of evidence. The Supreme Court granted review, and now holds that Pennsylvania law does not recognize a cause of action for negligent spoliation of evidence. View "Pyeritz v. Pennsylvania" on Justia Law

The Supreme Court granted review to determine whether a public school district was obligated to fund a kindergarten program offered by a cyber charter school for a four-year-old student when the district exercised its discretion not to offer such a program in its public schools. In 2006, the Secretary of Education notified Appellant Slippery Rock Area School District that funds had been deducted from the district's state subsidy and made payable to Appellee Pennsylvania Cyber Charter School. The Secretary deducted funds because Slippery Rock failed to pay Cyber School for numerous students residing in the district who were attending Cyber School. Slippery Rock objected to the withholding of $1,716.63 for a four-year-old female student enrolled in Cyber School’s kindergarten program. Slippery Rock averred that while it operates a discretionary kindergarten program for five-year-old children, the student at issue did not meet the age requirements for admission into the district’s kindergarten program, Slippery Rock argued that it was not obligated to "assume the costs or obligation of this individual’s enrollment into [Cyber School]." The Secretary concluded that Slippery Rock could not deny payment to Cyber School simply because Slippery Rock did not have a four-year-old kindergarten program. Subsequently the Secretary granted Cyber School's motion to dismiss Slippery Rock's objection. The Commonwealth Court affirmed the Secretary, but the Supreme Court reversed the Commonwealth Court and the Secretary: "[t]o hold that Slippery Rock is obligated to fund educational opportunities for students not yet eligible to attend the district’s public schools would allow those students who enroll in Cyber School to receive greater benefits than a similarly-situated student who chooses to attend the public school." View "Slippery Rock Area Sch. Dist. v. Pa. Cyber Charter Sch." on Justia Law

The issue before the Supreme Court was whether acceptance into an Accelerated Rehabilitative Disposition (ARD) program following a second charge of driving under the influence of alcohol (DUI) constituted a DUI violation and thus triggers the requirement for installation of an ignition interlock system as a condition of restoring a revoked driver's license. In 1998, Appellee John Whalen was convicted of DUI in Florida. Nine years later, Appellee was again arrested for DUI, this time in Pennsylvania. The trial court admitted Appellee into an ARD program after expressly making a determination that Appellee’s 1998 Florida DUI conviction did not present a bar to his entry into this program. Appellee successfully completed his ARD program. Pursuant to one provision of the ARD program, Appellee’s driver’s license was suspended for a period of sixty days, with the added condition that the ignition interlock be installed on his vehicle. Appellee appealed the ignition interlock requirement to the court of common pleas, arguing that the Department had no authority to impose this requirement in his case because ARD was not an adjudication of guilt. The Commonweath Court affirmed the DOT's decision. Upon reivew, the Supreme Court determined that the Commonwealth Court erred in its interpretation of the relevant statutory provisions when it concluded that acceptance into ARD did not establish a DUI violation. Accordingly, the Supreme Court reversed and remanded the case for further proceedings. View "Whalen v. Penna. Dept. of Trans." on Justia Law

In this discretionary appeal, the Supreme Court was asked to address whether the "regular use" exclusion in a personal automobile insurance police was valid to preclude payment of underinsured motorist benefits (UIM) to a police officer injured in the course of employment while operating his police vehicle for which the officer did not have an ability to obtain UIM coverage. Appellant Robert Williams was a Pennsylvania State Trooper seriously injured in an accident involving his police vehicle. At the time of the accident, Appellant maintained a personal automobile insurance policy with Government Employees Insurance Company (GEICO). He sought to recover UIM benefits from GEICO from the accident, but GEICO denied coverage citing the "regular use" exclusion contained in the policy. The trial court granted GEICO's motion to dismiss, and the Superior Court affirmed in an unpublished memorandum. Appellant argued on appeal that because of the special factual circumstances and challenges he faces as a state trooper, his insurer should have provided him with UIM coverage "despite the unambiguous policy exclusion because Pennsylvania has a strong public policy of protecting police officers and other first responders such that they are entitled to special treatment." Upon review, the Supreme Court concluded "Appellant's argument simply fails." The Court held that the trial and superior courts were correct in denying Appellant coverage under his UIM policy, and affirmed their decisions. View "Williams v. Government Employees Ins. Co." on Justia Law

Consolidating several appeals, the Supreme Court addressed the effect of a municipality's financial distress and recovery planning on an arbitration award agreed to pursuant to the Policemen and Firemen Collective Bargaining Act (Act). For approximately twenty years, the City of Scranton has been designated a distressed municipality under the Municipalities Financial Recovery Act. Pursuant to the Recovery Act, the City has its Commonwealth-mandated financial advisors who assist in creating a financial recovery plan (essentially a budget). In the most recent collective bargaining agreements between the City of Scranton and its Police and Firefighter Unions expired at the close of 2002. Negotiations as to future terms and work conditions for union members resulted in impasses. Accordingly, pursuant to the Act, arbitrators were selected to establish appropriate terms and conditions. Throughout the arbitrations, the City maintained that the arbitrators lacked legal authority to award relief impinging on the City's financial recovery plan. The City attempted to resist paying the ensuing award that resulted from the arbitration. The Commonwealth Court found that it was required to vacate the awards, holding that they did not conform to the City's Recovery Plan and would result in increased financial and operational burdens on an already distressed municipality. The Unions appealed to the Supreme Court. The Court focused on the distinction between the terms "arbitration award" and "arbitration settlement": the City argued that it was not mandated to pay "awards" but "settlements." The Supreme Court found the term "settlement" ambiguous, and the plain meaning could include the "award" given by the arbitrators in this case. Accordingly, the Court reversed the Commonwealth Court's order that the award negatively impacted the City's Recovery Plan. View "City of Scranton v. Firefighters Local Union" on Justia Law

At issue before the Supreme Court was whether an opinion rendered by a medical expert was sufficient to rebut the presumption of disease causation under the Pennsylvania Workers' Compensation Act. Joseph Kriebel worked for the City of Philadelphia as a firefighter from 1974 to 2003. He died in 2004 from liver disease caused by hepatitis C. His widow Appellant Patricia Kriebel, filed a claim petition under the Act in 2005, alleging that her husband contracted hepatitis C in the course of his employment. Appellant sought to raise the presumption of occupational exposure. In support of her claim, Appellant presented the testimony of her husband's treating physician. The City rebutted the presumption of disease causation with testimony of its own medical expert. Upon review, the Supreme Court held that an expert's opinion does not constitute substantial competent evidence where it is based on a series of assumptions that lack the necessary factual predicate. Since the medical opinions in this case were based on unfounded suppositions, they were legally insufficient to overcome the presumption of disease causation. The Supreme Court reversed the Commonwealth Court that held that the City overcame the presumption with its' medical expert's testimony, and reinstated the order of the superior court which held in favor of Appellant. View "City of Philadelphia v. Workers' Comp. Appeal Bd." on Justia Law

At issue before the Supreme Court was whether it was a violation of public policy to exclude from underinsured motorist coverage (UIM) a claim by an individual eligible for workers' compensation benefits. Appellant Frank Heller was severely injured from an automobile accident that happened during the course of his employment as a police officer for Sugarcreek Borough. Workers' Compensation covered his medical expenses and two-thirds of his salary. The Borough paid the remainder of Appellant's salary. Appellant's losses and damages far exceeded the policy limit from the tortfeasor's insurance carrier. Accordingly, Appellant notified his insurer of a potential UIM claim and sought UIM benefits from the Borough pursuant to a policy issued by the Pennsylvania League of Cities and Municipalities. Ultimately, Appellant's claim was denied. Upon review, the Supreme Court concluded that an exclusion in Appellant's workers' compensation policy violated public policy and was therefore unenforceable. The Court reversed the Commonwealth Court which held that the policy considerations favored the insurer: "Invalidating the workers' compensation exclusion would not force [the UIM insurer] to underwrite an unknown risk for which it did not receive compensation. The Borough voluntarily elected to purchase optional UIM coverage. .. [W]e find [Appellant's] assertion that the Borough purchased illusory coverage persuasive… the vast majority of all UIM claims likely will be made by Borough employees who are eligible for workers' compensation. The subject exclusion operates to deny UIM benefits to anyone who is eligible for workers' compensation." View "Heller v. Pa. League of Cities and Municipalities" on Justia Law

Appellants the Piper Group filed a constitutional challenge to a 1996 zoning ordinance enacted by Bedminster Township. In support of this challenge, Piper relied on an opinion from the Supreme Court that had been announced six days earlier pertaining to the same ordinance, "C&M Developers, Inc. v. Bedminster Twp. Hearing Bd." In "C&M," the Court invalidated the Township’s ordinance because it contained certain requirements that unconstitutionally restricted a landowner’s development rights. Relying heavily on C&M, Piper identified those same constitutional defects and sought permission to develop its land at a significantly higher density than would have been permissible under the invalidated ordinance. The Board of Supervisors, the trial court, and the Commonwealth Court all rejected Piper’s proposed cure to the unconstitutionality and held that Piper could develop its land in accordance with the Township’s alternative amended ordinance which cured the constitutional defects in the 1996 ordinance as identified in C&M and allowed increased development, but not to the extent requested by Piper. On appeal to the Supreme Court, Piper argued that the lower courts improperly denied Piper the full relief it requested. Specifically, Piper argued that the decisions violated the Municipalities Planning Code (“MPC”) and the “pending ordinance doctrine” as set forth in "Casey v. Zoning Hearing Bd. of Warwick Twp.," (328 A.2d 464 (Pa. 1974)) and its progeny. The Court disagreed and therefore affirmed the lower courts' decisions. View "Piper Group, Inc. v. Bedminster Twp." on Justia Law

Indian Rocks Property Owners Association, Inc. developed rules and regulations that were recorded as protective covenants running with the land in a development in Salem Township, Wayne County. Appellees John and Regina Glatfelter purchased a lot within the Indian Rocks community. John died in 1990 leaving Regina as the sole owner of the lot. The lot sat vacant until 2003 when the Glatfelters' son David began constructing a foundation. The Association initially inspected and approved the excavation, but late that year informed the Glatfelters that the work was substandard and inadequate pursuant to the covenants. The Glatfelters were ordered to cease construction until a new plan was approved. The Glatfelters agreed to stop work until they submitted a new application for construction in conformance with the covenants, but they failed to comply with the agreement. The Association brought suit to enforce the covenants, which the trial court approved and entered into its order. Since that suit, the Commonwealth amended the Construction Code to exempt "recreational cabins" from its requirements. Adopting the Construction Code, the Association passed a resolution refusing to recognize the recreational cabin exemption. When the Glatfelters sought to use the changed Construction Code to their advantage, the Association argued that its refusal to recognize the Code's changed cabin exemption did not apply to the Glatfelters' construction project. The trial court granted the Association's contempt petition against the Glatfelters. Upon review, the Supreme Court held that the Glatfelters stipulated that they would comply with the Association's rules prior to the change in the Code. As such, they were bound to the terms of the stipulation when completing their construction project: "the Glatfelters cannot use the recreational cabin exemption as a trump card to bypass the rules and regulations to which they agreed. … Our holding is premised entirely on the Glatfelters' failure to obtain the Association's approval regarding the intended structure." The Court did not address the validity of the Association's resolution refusing the adopt the recreational cabin exemption. View "Indian Rocks Property Owners Assoc. v. Glatfelter" on Justia Law