Justia Pennsylvania Supreme Court Opinion Summaries

At issue in this appeal was whether an order determining that grandparents had standing under Section 5325(3) of the Domestic Relations Code, 23 Pa. C.S. § 5325(3), to file and pursue an action for partial physical custody of their grandchildren was a collateral order appealable as of right under Pennsylvania Rule of Appellate Procedure 313, Pa.R.A.P. 313 (Rule 313). In August 2017, A.L.R. (Father) and T.A.D-R. (Mother) (collectively, Parents) began residing with J.C.D., III, and A.M.D. (collectively, Grandparents), Mother’s parents, at their home in York County, Pennsylvania. While Parents resided at Grandparents’ home, the Children were born to Parents: E.J.R. and A.L.R. Parents and the Children resided with Grandparents until May 2022, when, following a disagreement, Parents moved out of Grandparents’ home with the Children. Thereafter, Grandparents filed a complaint seeking shared legal and partial physical custody of the Children. Parents filed preliminary objections, alleging, inter alia, that Grandparents lacked standing to pursue an action for custody of the Children. The trial court found: (1) Parents and Children lived in the same home as Grandparents for approximately five years; (2) during that time, Grandparents were not raising the Children and did not stand in loco parentis to the Children and helped Parents with the Children as grandparents and as people sharing living quarters typically do; and (3) Grandparents filed their custody complaint within six months of when Parents removed the Children from Grandparents’ home. Based on these findings, the trial court entered an order concluding that Grandparents did not have standing to file and pursue an action for shared legal and partial physical custody of the Children. After reconsideration, the trial court entered a second order determining the Grandparents did have standing to file and pursue their action for partial custody of the Children. The Pennsylvania Supreme Court held that such an order was not a collateral order, and, therefore, it affirmed the Superior Court’s order quashing this appeal. View "A.M.D., et al. v. A.L.R, et al." on Justia Law

The Pennsylvania Supreme Court granted appeal in this matter to consider whether the Superior Court erred in holding that a trial court lacked jurisdiction to correct a patent and obvious error in a sentencing order when the defendant’s request for correction was filed outside the time limitations of the Post Conviction Relief Act (“PCRA”). In November 1994, Appellant Rodney McGee fatally assaulted Barry Williams. In 1996, Appellant entered into a negotiated guilty plea multiple accounts for acts against multiple people; court stated that Appellant’s aggregate sentence for all of the offenses was 32 1⁄2 to 65 years. On the same day that Appellant entered his plea and the trial court orally imposed the above sentence, the trial court issued a three-page typed document titled “Order” (“typed sentencing order”) that was inconsistent with what the court orally imposed on the record. Decades later, on June 3, 2020, Appellant filed a pro se PCRA petition, and counsel was appointed. On August 5, 2020, Appellant filed a “Motion to Correct Illegal Sentence” arguing that there was an obvious incompatibility between the two orders. Finding that the orders in question were “patently erroneous” and “contrary to common sense,” the trial court concluded that amendment of the orders was proper, as the time limits of the PCRA did not apply. The Commonwealth appealed the trial court’s decision to the Superior Court, asserting that the trial court did not have jurisdiction to entertain Appellant’s Motion because the underlying claim was cognizable under the PCRA, and had been filed outside the PCRA’s jurisdictional time constraints. In a unanimous memorandum opinion, the Superior Court reversed. The Pennsylvania Supreme Court affirmed, finding no "patent and obvious error" in the trial court's sentencing orders. The Court did not reach the question of whether a trial court’s inherent authority to correct patent and obvious errors in the record is subject to the time limitations of the PCRA. View "Pennsylvania v. McGee" on Justia Law

Appellant Kevin Jackson appealed a superior court judgment which vacated a pretrial order of the Court of Common Pleas of Philadelphia County (suppression court) and remanded the matter for further proceedings. The suppression court granted Jackson’s motion to suppress evidence recovered after a police officer detained Jackson via what was known as a Terry stop. While the suppression court concluded that the officer lacked the requisite reasonable suspicion to detain Jackson, the superior court reached the opposite conclusion. The superior court's judgment was affirmed by operation of law because the Pennsylvania Supreme Court was evenly divided. The opinion in support of affirmance agreed with the superior court's conclusion that the police officer had reasonable suspicion to detain Jackson under the particular facts of this case. The opinion in support of reversal noted that it was "critical that courts and practitioners in this area of the law be cognizant of the burden that rests with the Commonwealth to justify a warrantless search or seizure when it seeks to do so based upon a 'high-crime area;' ... If we assume for the purpose of analysis that the Commonwealth established with empirical evidence that the area where Jackson was stopped constituted an area known for disproportionately regular gun violence, that evidence would not be relevant because it does not tend to make it more probable that Jackson was engaged in gun violence. Contrary to the Commonwealth’s argument, the Fourth Amendment requires the government to explain how reasonable suspicion relates to the individual’s conduct taking place in the location or area, for instance, by showing that his conduct was unique and, therefore, suspicious." View "Commonwealth v. Jackson, K., Aplt." 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

Appellant Joseph Koepfinger (“Father”) was a nonagenarian and father of several adult children, including Appellee Margaret Koepfinger (“Daughter”). In September 2016, shortly after the death of Father’s wife/Daughter’s mother, Father executed a power of attorney (“POA”), naming Daughter as his agent. The POA gave Daughter the authority to, among other things, create an irrevocable trust for Father; it further provided that Father could revoke the POA but only in writing. Soon after the execution of the POA, tensions began to build between Father and Daughter due to Father’s developing relationship with Madeline Masucci (“Masucci”). In 2017, Father allegedly orally informed Daughter that he revoked the POA and that he executed a new power of attorney, naming his son/Daughter’s brother as his agent. Daughter, however, claimed she was not informed of these events until May of 2018. In the meantime, in April 2018, acting as Father’s agent under the POA, Daughter created an irrevocable trust for Father, placing a substantial amount of his assets into that trust. Daughter named herself as trustee. After Daughter allegedly was informed that Father revoked the POA, she filed a Petition for Declaratory Judgment requesting, in relevant part, judicial declarations that: (1) the 2016 POA was not revoked at the time that she created the trust; (2) the creation and funding of the trust was within her scope of authority under the POA; and (3) the trust is valid. The issue this case presented for the Pennsylvania Supreme Court's review centered on whether a judicial determination that a power of attorney was void ab initio invalidated an irrevocable trust created by the purported agent under the void power of attorney. The orphans’ court answered this question in the affirmative, but the Superior Court reversed. The Supreme Court held that, when a court concludes that a power of attorney is a nullity, any action taken under the auspices of the power of attorney is likewise a nullity. Consequently, the Court vacated the Superior Court’s judgment and reinstated the orphans’ court’s order. View "In Re: Koepfinger" 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

In August 2014, Dairy Farmers of America, Inc. (“DFA”) sponsored a golf outing for its employees at Tanglewood Golf Course in Mercer County, Pennsylvania. As a condition of attendance, DFA required employees to provide a “monetary contribution to offset costs and expenses” associated with the event, which it used to pay for items such as “greens fees, food and alcohol.” One of DFA’s employees, Roger Williams, made the contribution and attended the golf outing. According to Appellant David Klar, DFA had reason to know that Williams was an alcoholic and that he previously had been arrested for driving under the influence of alcohol. At the event, Williams’ alcohol consumption was unsupervised, and he drank beyond the point of visible intoxication. Williams departed the golf outing in his car. While driving, Williams encountered Klar, who was operating a motorcycle in the southbound lane. Williams swerved across the center line into Klar’s path. The resulting collision caused Klar to suffer numerous and grievous injuries. Klar sued both Williams and DFA, contending that they were jointly and severally liable for his injuries. This case calls upon the Pennsylvania Supreme Court to revisit precedents that have prevailed for half a century and that imposed liability upon persons and entities licensed to engage in the commercial sale of alcohol while limiting the liability of non-licensees and “social hosts.” The lower courts applied these precedents to conclude that an organization which hosted an event at which alcohol was provided, but was not a liquor licensee, could not be held liable for injuries caused by a guest who became intoxicated at the event. Finding no basis to disturb the long-settled law of Pennsylvania, the Supreme Court affirmed. View "Klar v. Dairy Farmers of America" 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

Appellant Jakeem Towles appealed the dismissal of his second petition for post conviction relief (PCRA). Towles was convicted for the 2010 homicide of Cornell Stewart, Jr. and the attempted homicide of John Wright following an altercation at a rap performance in Columbia, Pennsylvania. The Court of Common Pleas of Lancaster County (PCRA court) concluded that Towles’ petition was untimely filed and, alternatively, without merit. Towles claimed that the Commonwealth had made threats and promises to a witness to induce him to testify against Towles at trial. In apparent recognition of the facial untimeliness of his second PCRA petition, Towles asserted that his petition met the so-called “governmental interference” and “newly discovered facts” timeliness exceptions in the Post Conviction Relief Act. Towles further claimed that he acted with due diligence in asserting his claim within the one-year time limit. The Pennsylvania Supreme Court concurred with the PCRA court's finding that Towles' petition was untimely, and affirmed dismissal. View "Pennsylvania v. Towles" on Justia Law

During their employment with Dialysis Clinic, Inc. (DCI), the Doctors maintained staff privileges and worked at Washington Hospital. In 2013, Alyssa McLaughlin was admitted to the Hospital and received treatment from, among other medical staff, the Doctors, Kathryn Simons, M.D., Anne F. Josiah, M.D., Thomas Pirosko, D.O., and Ashely Berkley, D.O. At some point during or after that treatment, McLaughlin sustained severe and permanent neurological injuries. Attributing those injuries to negligence in her treatment, McLaughlin and her husband, William McLaughlin (collectively, the McLaughlins), initiated an action against the Doctors, the Hospital, and the other physicians noted above who were responsible for her care. The issue this case presented for the Pennsylvania Supreme Court's review centered on whether, as a matter of law, the Hospital could seek contribution and/or indemnity from DCI for negligence committed by DCI’s employees (the Doctors). The trial and superior courts both concluded that, although traditional principles of contribution and indemnity did not apply cleanly these particular circumstances, equitable principles of law permitted the Hospital to seek both contribution and indemnity from DCI. As a result, the trial court denied DCI’s motion for summary relief, and the superior court affirmed. The Supreme Court was unanimous in finding that, if the Hospital and DCI were determined to be vicariously liable for the negligence of the Doctors, the law permitted the Hospital to seek contribution from DCI. The Court was evenly divided on the question of whether the Hospital could also seek indemnification from DCI. Given the decision on contribution and inability to reach a decision on indemnity, the superior court was affirmed on those questions. View "McLaughlin v. Nahata, et al." on Justia Law