Justia Pennsylvania Supreme Court Opinion Summaries

The issue before the Supreme Court in this matter arose from direct appeal of an order that denied injunctive and declaratory relief by an en banc panel of the Commonwealth Court regarding various constitutional challenges to a law enacted by the General Assembly known as "Act 108 of 2011." Specifically, it was alleged that Act 108 was violative of: (1) the "single subject rule" of Article III, Section 3 of the Pennsylvania Constitution; (2) the separation of powers doctrine of Article V, Sections 1 and 10 of the Pennsylvania Constitution establishing a unified judicial system supervised by the Supreme Court; and (3) the due process clause of the Fourteenth Amendment to the United States Constitution under the void for vagueness doctrine. The Commonwealth Court, in a 4-3 decision, rejected the constitutional challenges and dismissed the action. After oral argument and consideration of the Commonwealth Court record, the Supreme Court concluded that with regard to the Article III, Section 3 single subject challenge, Act 108 was unconstitutional. Given this disposition, the Court did not consider the remaining arguments. View "PA State Ass'n of Jury Commissioners v. Pennsylvania" on Justia Law

The issue before the Supreme Court centered on the award of attorney's fees against an insurance company under the peer-review provisions of the Motor Vehicle Financial Responsibility Law (MVFRL). The MVFRL limits the amount providers may charge for treatment, products or services rendered to patients injured in automobile accidents where the injury is covered by an insurance policy. An individual obtained treatment from Appellee Herd Chiropractic Clinic for injuries sustained in a motor vehicle accident. The insurance company submitted the clinic's invoices to a Peer Review Organization (PRO) pursuant to the MVFRL. The PRO determined that certain treatments were not necessary or reasonable, and the insurance company subsequently refused to pay for such treatment The Clinic then sued for unpaid bills, plus treble damages and attorney's fees under the theory that the MVFRL authorized payment. The Common Pleas court found an award of fees proper and mandatory under the MVFRL. The Superior Court affirmed. The Supreme Court, however, reversed, finding that the MVFRL did not allow for what amounted to "fee shifting" by the lower courts' outcome: "We acknowledge [the Clinic's] concerns with the financial incentives in the peer-review industry and with the fact that litigation costs incurred by providers may discourage legitimate challenges. The fee accruals here – in the amount of $27,000 to vindicate a $1380 claim - present a stark example of the difficulty. . . . Nevertheless, fee shifting raises a host of mixed policy considerations in and of itself, which this Court has found are best left to the General Assembly, in the absence of contractual allocation or some other recognized exception to the general, American rule." View "Herd Chiropractic Clinic v. State Farm Mutual Automobile Ins. Co." on Justia Law

The issue before the Supreme Court in this matter concerned the standard of review with respect to a claim that the verdict was against the weight of the evidence. Appellees Jamel Clay, James Claybrook and Rashid Lewis visited "R.B." at her dormitory room in West Chester to socialize. Eventually Appellees, R.B. and her friend H.S. discussed how Appellees would stay the night. H.S. testified that Appellees "ended up" in her room, and did not dispute that she allowed them to stay. Over the course of the stay, the three Appellees engaged in sex with H.S. H.S. contacted her Resident Assistant and claimed that Appellees had raped her. Ultimately Appellees were charged and convicted with the sexual assault of H.S. Each was sentenced to two to four years' incarceration and two years' consecutive probation. Appellees filed a joint motion for post-sentence relief, arguing that the evidence was insufficient to sustain their convictions, and that the jury's verdicts were against the weight of the evidence. Upon review, the Supreme Court concluded that the superior court used the incorrect standard of review and erroneously substituted its own conclusions for those of the jury and the trial court. Accordingly, the Court reversed and remanded the case to the superior court for reconsideration. View "Pennsylvania v. Clay" on Justia Law

The issue before the Supreme Court in this case was whether Appellee John Brock waived his speedy trial claim by either failing to file a written motion to dismiss, or by failing to appear for a trial listing. Upon review, the Supreme Court concluded that under Pa.R.Crim.P. 600, a defendant must file a written motion to dismiss, and that by failing to appear in court on the day his or her case is listed for trial, a defendant waived his Rule 600 claim. Accordingly, the Court reversed. View "Pennsylvania v. Brock" on Justia Law

The issue on appeal before the Supreme Court in this case was whether sheriffs and their deputies have the independent authority to establish and conduct suspicionless roadside sobriety checkpoints. In 2007, sheriffs and deputies of the Forest and Wayne County Sheriffs' Departments established temporary checkpoints in Forest County. Appellee drove a vehicle into the checkpoint, was stopped, was found to have used alcohol, and underwent a field sobriety and chemical test. Based on the results, he was arrested and charged with DUI and other offenses. "The members of [the Supreme Court] maintain great respect and express gratitude for sheriffs and their deputies in the performance of indispensable public services within their realm. We reiterate, however, that they are not police officers - nor are they invested with general police powers beyond the authority to arrest for in-presence breaches of the peace and felonies - in the absence of express legislative designation." The Court held that the sheriffs did not have the authority to independently establish and conduct the suspicionless sobriety checkpoint at which Appellee was arrested. View "Pennsylvania v. Marconi" on Justia Law

The Commonwealth appealed an order of the Court of Common Pleas of Allegheny County which granted Appellee Connie Williams' Post-Conviction Relief Act (PCRA) petition and vacated his sentence of death on the basis that appellee demonstrated, by a preponderance of the evidence, that he was mentally retarded. A jury convicted appellee of first degree murder and abuse of a corpse for stabbing his wife, Frances Williams, to death. The Supreme Court found that the PCRA court's factual findings were supported by substantial evidence, and its legal conclusions drawn therefrom were free from error. Accordingly, the Supreme Court affirmed. View "Pennsylvania v. Williams" on Justia Law

Appellant Glatfelter Pulpwood Company challenged the Commonwealth Court's affirmance of the Board of Finance and Revenue's determination that Appellant's gains from the sale of a tract of Delaware timberland be characterized as "business income," subject to taxation in Pennsylvania. Concluding that none of Appellant's issues raised on appeal entitled it to any relief, the Supreme Court affirmed the Commonwealth Court. View "Glatfelter Pulpwood Co. v. Pennsylvania" on Justia Law

The issue before the Supreme Court in this case was whether a doctor who treats prison inmates has a common law duty to warn corrections officers that a particular inmate has a communicable disease. Appellee Michelle Seebold filed suit against Appellant Prison Health Services, Inc. ("PHS"), alleging a single cause of action expressly grounded in negligence. Appellee worked as a corrections officer at the prison and was assigned to strip search its female inmates before and after they received visitors. The complaint asserted that approximately twelve inmates were infected with methicillin-resistant staphylococcus aureus (MRSA). As a result of Appellee's contact with the inmates, she averred, she became infected. Appellee contended that PHS's staff knew or should have known of the infections and owed a duty of reasonable care to "the staff and inmates at SCI Muncy to warn them of and protect them from acquiring an MRSA infection from those inmates known to be carrying the bacteria in a communicable state." Upon review, the Supreme Court concluded that Appellee had not asserted a cause of action under Commonwealth case law, and "[i]n the absence of policy arguments or a request for an opportunity to develop a record, the [trial] court did not err in applying the default approach of declining to impose upon professional undertakings new affirmative common-law duties running to third-parties to the professional relationship." The Court reversed the superior court and reinstated the trial court's order. View "Seebold v. Prison Health Services" on Justia Law

The issue before the Supreme Court in this case centered on whether the "voluntary layoff option" proviso ("VLO Proviso") contained in Section 402(b) of the Unemployment Compensation Law ("UC Law"), permits employees to receive unemployment compensation benefits when they accept an early retirement plan offered pursuant to an employer-initiated workforce reduction. Upon application of our rules of statutory construction, the Supreme Court reversed the decision of the Commonwealth Court and concluded that the UC Law does not preclude application of the VLO Proviso to early retirement plans offered pursuant to employer-initiated workforce reductions. View "Diehl v. Unemp. Comp. Bd. of Review" on Justia Law

The Supreme Court granted allowance of appeal in this consolidated case to consider whether a plaintiff may recover delay damages on the full amount of a jury verdict in his favor, or whether delay damages are limited to the amount of the legally-recoverable molded verdict, as it was adjusted by the trial court to reflect insurance policy limits. This case stemmed from a 2002 accident in which the vehicle operated by Richard and Marleen Marlette, stopped in traffic, was hit when vehicle operated by Herman Jordan crossed the center line and sideswiped them. Mr. Marlette sustained serious physical injuries, as well as lost wages and impairment of his earning capacity. The Marlettes filed suit against Jordan, who was uninsured, and their own insurer, State Farm Mutual Automobile Insurance Company ("State Farm"), for uninsured motorist ("UM") coverage. Liability was uncontested, and the case proceeded to trial on damages. Upon review of the matter, the Supreme Court concluded that a plaintiff may recover delay damages only on the amount of legally-recoverable damages to which he is entitled pursuant to the molded verdict. The Court remanded the case to the Superior Court for remand to the trial court for reinstatement of its original award of delay damages. View "Marlette v. State Farm Mutual Automobile Ins. Co. " on Justia Law