Justia Pennsylvania Supreme Court Opinion Summaries

The Housing Authority of the City of Pittsburgh leased a unit in the Northview Heights Complex to Darlene Nash. On January 9, 2021, Nash hosted a birthday party at her unit, which was attended by numerous people, including a juvenile known as “Shooter.” During the party, after Nash asked another guest, Blake Green, to leave, Green was shot and killed inside Nash’s unit. Shooter was identified as the main suspect, though no charges or arrests were made. The Housing Authority served Nash with a notice to terminate her lease, citing the shooting as a violation of lease provisions prohibiting criminal activity and the discharge of deadly weapons by any “Covered Person,” which includes guests and other persons under the tenant’s control.The Magisterial District Court granted the Housing Authority possession of the unit, permitting eviction. Nash appealed to the Allegheny County Court of Common Pleas, where a non-jury trial was held. The trial court found that Shooter was not an unauthorized occupant or a guest, but was an “Other Person Under the Tenant’s Control” (OPTC) due to Nash’s “open house” invitation. The court concluded Nash violated the lease and awarded possession to the Housing Authority. Nash’s post-trial motion was denied, and she appealed to the Commonwealth Court.The Commonwealth Court reversed, reasoning that an invitation to the unit was not the same as an invitation to the premises, and the Housing Authority had not established that Shooter was on the premises due to Nash’s invitation. On appeal, the Supreme Court of Pennsylvania reviewed the lease and relevant law de novo, holding that an invitation to a unit is an invitation to the premises, and Shooter was an OPTC at the time of the shooting. The Supreme Court reversed the Commonwealth Court’s decision, holding that the Housing Authority may evict Nash for the criminal act committed by Shooter in her unit. View "Housing Authority v. Nash" on Justia Law

In this discretionary appeal, the Pennsylvania Supreme Court addressed whether a magisterial district court had jurisdiction over a case proceeding under the Landlord and Tenant Act, where the plaintiff was the purchaser of a property at a sheriff’s sale, and the defendants were the property’s former owners who refused to leave, but where the parties did not have a landlord-tenant relationship. The Supreme Court determined the magistrate court did not have jurisdiction, and so reversed and remanded for dismissal. View "Assouline v. Reynolds" on Justia Law

In 2008, Appellants, Gamesa Energy USA, LLC and Gamesa Technology Corporation, Inc. (Gamesa), entered into a commercial lease agreement (the Lease) to rent 35,000 square feet of office space in Philadelphia (the Premises) from Appellees, Ten Penn Center Associates, L.P. and SAP V Ten Penn Center NF G.P. L.L.C. (collectively Ten Penn Center). In May 2011, following Gamesa’s submission of the information required under Article 20.2 of the Lease, Ten Penn Center approved a request to sublease approximately 15,000 square feet, or forty percent of the Premises, to Viridity Energy, Inc. (Viridity) through August of 2018. In April 2012, Gamesa informed Ten Penn Center it would be moving out of the Premises as part of a corporate consolidation, and would continue to pay its monthly rent and attempt to find a sub-lessee for the open space. Viridity remained in the Premises under the terms of its sublease with Gamesa. Gamesa was twice late with the rent after it moved out, but still paid amounts due. In 2012, Gamesa submitted a request to Ten Penn Center for consent to sublease 5,200 square feet of the Premises to Business Services International, LLC (BSI), a business entity comprised of two foreign corporations formed for the particular purpose of subleasing office space through Gamesa. Ten Penn Center responded on June 26th, informing Gamesa it was in default of the Lease for vacating the Premises and, as a result, Ten Penn Center had no obligation to entertain the request to sublease. Ten Penn Center proposed it would grant consent to the BSI sublease if Gamesa forfeited its remaining tenant improvement allowance. Thereafter, negotiations between the parties stalled, and the proposed sublease with BSI never materialized. In 2013, Gamesa filed a complaint against Ten Penn Center, asserting claims of breach of contract, tortious interference in business relationships, and unjust enrichment. The Pennsylvania Supreme Court granted discretionary review of this commercial landlord and tenant dispute to determine whether the Superior Court erred in holding the tenant was limited to damages for breach of contract and could not also recover the rent it paid following the landlord’s breach, despite prevailing on its claims for both remedies at trial. After careful review, the Supreme Court found no reversible error and affirmed the Superior Court. View "Gamesa Energy USA v. Ten Penn Center, et al" on Justia Law