Justia Pennsylvania Supreme Court Opinion Summaries

Ronald Bole appealed a superior court's order that affirmed an arbitration award that denied him recovery of underinsured motorist benefits. The Supreme Court allowed the appeal to determine whether the rescue doctrine allowed a volunteer firefighter responding to a crash to recover despite finding his injuries were the result of a superseding cause. Upon review, the Supreme Court concluded that Bole could not, and did not disturb the arbitrator's determination. View "Bole v. Erie Insurance Exchange" on Justia Law

Alleging that Appellant Conestoga Title Insurance Company charged more for title insurance than its filed rates permitted, Appellee Nancy A. White asserted three claims against Conestoga in a class action complaint. The Supreme Court granted review to consider whether White was precluded from pursuing all of her claims because Article VII of the Insurance Department Act of 1921 provided her with an exclusive administrative remedy under Section 1504 of the Statutory Construction Act of 1972. Upon review, the Supreme Court reversed in part and affirm in part. Specifically, the Court reversed the Superior Court's order reversing the trial court's dismissal of White's common law claims for money had and received and for unjust enrichment, and the Court affirmed (albeit on different grounds) the Superior Court's order reversing the trial court's dismissal of White's statutory claim brought under Pennsylvania's Unfair Trade Practices and Consumer Protection Law. View "White v. Conestoga Title Insurance Co." on Justia Law

The issue before the Supreme Court in this case concerned the propriety of resolutions adopted by two school boards that reduce the compensation rates for elected tax collectors in an effort to adopt alternative collection methods. "[The Supreme Court] recognize[d] the difficulties faced by the School Boards in periods of financial uncertainty, but it is beyond the boards' power to transform the local tax collection system by reducing compensation levels to such a degree that the elected Tax Collectors are unable to fulfill their responsibilities; such systematic change must come from the Legislature." The Court reversed the ruling of the Commonwealth Court and remanded the case for further proceedings. View "Telly v. Pennridge School Dist." on Justia Law

Mason-Dixon Resorts, L.P. made a direct appeal to the Supreme Court to challenge a Pennsylvania Gaming Control Board decision that awarded a Category Slot Machine 3 slot machine license to intervenor Woodlands Fayette, L.L.C. Upon review, the Supreme Court affirmed: "[w]e have no doubt that there may have been other applicants for this remaining Category 3 license, including appellant, whose facilities may not have been appropriate for the award of a license. Our task, however, is not to determine for ourselves which of the facilities was the best one, but instead to pass upon the specific claims raised, under the standard review established by the Act. . . . finding no error warranting relief, we affirm the Board's Order." View "Mason-Dixon Resorts v. PA Gaming Control Board" on Justia Law

The Pennsylvania Supreme Court accepted certification from the United States Court of Appeals for the Third Circuit to address the exclusiveness of a statutory appraisal remedy provided to minority shareholders in certain merger scenarios under Pennsylvania corporate law. Where there is a fair value dispute, the BCL provides for post-merger judicial valuation or appraisal of the shares. Mitchell Partners, L.P., was a minority shareholder of Irex Corporation. In 2006, Irex participated in a merger structured so that some minority shareholders would be "cashed out" and would not receive an equity interest in the surviving corporation, a wholly owned subsidiary of North Lime Holdings Corporation. Mitchell objected to the acquisition. The merger proceeded nonetheless, and Irex commenced valuation proceedings in state court to address the dispute with Mitchell. Meanwhile, Mitchell pursued common law remedies in a diversity action in federal court, naming as defendants Irex, its directors, most of its officers, and North Lime. The defendants sought dismissal on the ground that, under Section 1105 of the BCL, judicial valuation was the sole remedy available to dissenting shareholders in the post-merger timeframe. A divided three-judge panel of the Third Circuit reversed the superior court in favor of Mitchell. Defendants sought rehearing, and the Governor of Pennsylvania and several business groups moved for leave to file supportive amicus briefs. The Governor expressed particular concern that the Third Circuit had interpreted the BCL's provisions relating to dissenting shareholders' rights in a manner inconsistent with Commonwealth case law. Accordingly, he urged the Third Circuit to grant rehearing and certify a question of law to the Supreme Court. Upon review, the Supreme Court, in response to the certified question, Section 1105 (of the BCL) "precludes postmerger remedies other than appraisal only in the absence of fraud or fundamental unfairness." View "Mitchell Partners, L.P., Aplt v. IREX Corporation" on Justia Law

Appellant Bortela Philistin appealed an order that denied him relief from his criminal convictions and death sentence pursuant to the Post Conviction Relief Act. A jury convicted Appellant of first degree murder and related offenses. In the penalty phase, the jury found the existence of two aggravating circumstances: the victim was a police officer killed in the performance of his duties, and the Appellant knowingly created a grave risk of death to another. The jury found no mitigating circumstances; thus, it returned a death sentence. Appellant raised thirteen claims on appeal pertaining to errors at trial, the sufficiency of the evidence presented against him, and ineffective assistance of trial counsel. The Supreme Court found no merit to Appellant's claims, and affirmed his conviction and death sentence. View "Pennsylvania v. Philistin" on Justia Law

The issue before the Supreme Court in this case was whether it is against public policy to release reckless behavior in a pre-injury exculpatory clause. Appellant Camelback Ski Corporation, Inc. (“Camelback”) operates a ski resort in Tannersville, Pennsylvania that offers various winter activities, including skiing and snow tubing. Before permitting its patrons to enjoy snow tubing, Camelback requires each customer to sign a pre-printed release form. In 2003, Appellee Barbara Lichtman Tayar and her family visited Camelback’s facility in the early afternoon. Appellee and her family decided to join in, and, pursuant to Camelback’s requirement, Appellee signed the Release. Appellee and her family elected to use the family tubing slopes, and completed four successful runs down the mountain, with Appellant Brian Monaghan, a Camelback employee, releasing them from the summit safely each time. On the fifth time down the mountain, Appellee exited her snow tube and was immediately struck by another snow tuber coming down the slope. Employees rushed to assist Appellee out of the receiving area. As a result of the collision, Appellee suffered multiple comminuted factures of her right leg, for which she underwent surgery and required two metal plates and 14 screws to stabilize her ankle. A majority of the appellate court determined that the release at issue was valid only with respect to Camelback (and not Monaghan), and relieved Camelback from liability for only negligent conduct. Upon review, the Supreme Court reversed the Superior Court’s order in part, affirmed in part, and remanded the case. The Court reversed the order of the Superior Court to the degree it concluded that Monaghan was not covered by the Release. The Court affirmed the order to the degree it reversed the grant of summary judgment on the basis that the Release did not bar claims based on reckless conduct, and remanded for further proceedings; on the latter point, the Court affirmed on the alternative basis that, to the degree it released reckless conduct, the Release was against public policy. View "Tayar v. Camelback Ski Corp., Inc." on Justia Law

This case was a direct appeal from a Commonwealth Court order which set aside the nomination petition of Andrew Gales as a Democratic Candidate for Pennsylvania State Representative in the 57th Legislative District. On April 4, 2012, the Supreme Court reversed the order of the Commonwealth Court, directed that the candidate’s name be printed on the April 24, 2012 primary election ballot, and indicated that an opinion would follow. The Court released its rationale for that order, and held that the Election Code does not prohibit an elector from signing a nomination petition using an obvious diminutive form of his or her first name, rather than the formal first name that appears on the elector’s voter registration card. View "In re Nomination Petition of Andrew Gales" on Justia Law

The issue before the Supreme Court was whether the Recidivism Risk Reduction Incentive Act (61 Pa. C.C. 4501-4512 (RRRI Act)) applied to defendants sentenced to mandatory terms required by two drug trafficking sentencing provisions. The superior court concluded that the RRRI Act was applicable, and affirmed Appellee Frederick Hansley's sentence. The Commonwealth challenged the trial court's application of the mandatory penalties of the trafficking sentencing provisions, contending: (1) that the trial court lacked the authority to impose lesser minimum penalties than those prescribed by those statutes; and (2) the drug trafficking sentencing statutes conflict with the RRRI Act, and that the plain language of the former provisions established that the General Assembly intended the mandatory penalties to "override" any other conflicting statutes, then-existing or later-adopted. The Supreme Court affirmed, recognizing "that the effect of the RRRI Act may be to reduce the total time in prison that an offender subject to a mandatory minimum sentence must serve. But, it is eminently clear from the plain language of the legislation that the General Assembly intended that result - for a limited class of statutorily defined defendants, upon the completion of several conditions, and subject to the controlling discretion of the Parole Board. [The Court's] plain language interpretation accords with the legislative intent as [it understood] it, and gives effect to all provisions of the relevant sentencing statutes. Accordingly, the decision below is affirmed." View "Pennsylvania v. Hansley" on Justia Law

Appellant Mark Spotz appealed the denial of his petition for collateral relief filed pursuant to the Post Conviction Relief Act (PCRA). Appellant was convicted of first-degree murder for the 1995 shooting death of Penny Gunnet for which he was sentenced to death. Appellant raised numerous issues on appeal; the Supreme Court concluded that there was "no merit" to any of the issues he raised and affirmed the decision of the PCRA court. View "Pennsylvania v. Spotz" on Justia Law