Justia Pennsylvania Supreme Court Opinion Summaries

The issue before the Supreme Court was the determination of the proper test for evaluating whether an oil or gas lease has produced "in paying quantities," as first discussed "Young v. Forest Oil Co.," (194 Pa. 243, 45 A. 1 (1899)). Appellant Ann Jedlicka owned a parcel of land consisting of approximately 70 acres. The Jedlicka tract is part of a larger tract of land consisting of approximately 163 acres, which was conveyed to Samuel Findley and David Findley by deed dated 1925. In 1928, the Findleys conveyed to T.W. Phillips Gas and Oil Co. an oil and gas lease covering all 163 acres of the Findley property which included the Jedlicka tract. The lease contained a habendum clause which provided for drilling and operating for oil and gas on the property so long as it was produced in "paying quantities." Notably, the term "in paying quantities" was not defined in the lease. Subsequently, the Findley property was subdivided and sold, including the Jedlicka tract, subject to the Findley lease. A successor to T.W. Philips, PC Exploration made plans to drill more wells on the Jedlicka tract. Jedlicka objected to construction of the new wells, claiming that W.W. Philips failed to maintain production "in paying quantities" under the Findley lease, and as a result, the lease lapsed and terminated. After careful consideration, the Supreme Court held that when production on a well has been marginal or sporadic, such that for some period profits did not exceed operating costs, the phrase "in paying quantities" must be construed with reference to an operator's good faith judgment. Furthermore, the Court found the lower courts considered the operator's good faith judgment in concluding the oil and gas lease at issue in the instant case has produced in paying quantities, the Court affirmed the order of the Superior Court which upheld the trial court's ruling in favor of T.W. Phillips Gas and Oil Co. and PC Exploration, Inc. View "T.W. Phillips Gas and Oil Co. v. Jedlicka" on Justia Law

The Supreme Court assumed plenary jurisdiction over this matter as a sua sponte exercise of its extraordinary jurisdiction to determine the proper forum for adjudicating appeals from the suspension of the certification of an official emission inspection mechanic under section 4726(c) of the Vehicle Code. Appellant Maher Ahmed Mohamed was a certified emission inspector by the Bureau of Motor Vehicles (PennDOT). In 2007, a Quality Assurance Officer for PennDOT (Auditor), conducted a records audit at Keystone. The Auditor’s report concluded that Appellant performed faulty emission inspections on four vehicles by connecting the emission equipment to a vehicle other than the one being tested in order to obtain a passing result. The report further indicated that two of the vehicles tested and the vehicle used to obtain the passing results were owned by taxicab companies partly owned by Appellant. The Auditor also found that Appellant falsified the records of the four tested vehicles. Appellant failed to appear at a subsequent agency hearing to answer the charges against him, and the Auditor provided the only testimony by presenting the findings of his report. PennDOT sent Appellant an order notifying him that his certification as an official emission inspector was suspended. Instead of following the directions in the order regarding the filing of an appeal, Appellant filed a petition for review from PennDOT's suspension order in the Commonwealth Court. The Commonwealth Court affirmed PennDOT's decision. Upon review, the Supreme Court reversed the Commonwealth Court: "it may be the established practice to file appeals under section 4726(c) in the courts of common pleas; however, such practice remains inconsistent with . . . statutory language. While the Commonwealth Court potentially may have been correct in concluding that the General Assembly intended to enact something different from the actual text of section 933 [of the Administrative Agency Law], the Commonwealth Court was without authority to correct an omission and, therefore, violated established legal principles by disregarding the clear statutory language." Accordingly, the Court remanded the case for PennDOT to conduct an administrative hearing on the question of Appellant's suspension in accordance with the terms of the Administrative Agency Law. View "Mohamed v. Pennsylvania" on Justia Law

The Supreme Court addressed an Application for Relief in an Election Code matter, over which it retained limited jurisdiction following a remand on October 4, 2010. The issue involved the effect of the District Court's decision in "Morrill v. Weaver," (224 F.Supp.2d 882 (E.D. Pa. 2002)). In "Morrill," Section 2911(d) of the Election Code (25 P.S. 2600 et seq.), which the federal court construed as imposing a district residency requirement for affiants circulating nomination papers violated the First Amendment. The district court permanently enjoined the Commonwealth from enforcing the statutory provision, and the Commonwealth did not appeal that decision. The question of the constitutionality of Section 2911(d) and the effect of Morrill arose in connection with a challenge to the nomination paper submitted by Carl Stevenson as an independent candidate for the office of State Representative in Pennsylvania’s 134th Legislative District in the 2010 general election. Michael Gibson and Robert Mader filed a petition to set aside in the Commonwealth Court, raising both signature challenges and a global challenge to Stevenson’s nomination paper. The objectors' global challenge alleged that signatures on three pages of the nomination paper were invalid because the circulator of those pages resided outside the 134th Legislative District, in supposed violation of Section 2911(d). Upon review, the Supreme Court held that the Commonwealth and the Secretary are bound by the district court decision in "Morrill" and may not enforce Section 2911(d) as written. View "In Re: Nomination Petitions and Papers of Carl Stevenson" on Justia Law

The issue on appeal in this case pertained to a question of corporate successor liability under the "de facto" merger doctrine or exception. The trial court concluded that XLNT Software Solutions, Inc. was liable for a judgment owed by XLN, Inc., pursuant to this exception. XLNT and XLN lacked common shareholders and higher management; however, the corporations each employed the same two key employees in positions of authority and who, at all relevant times, were principal owners of the essential asset around which the business of the two corporations operated. The Superior Court determined that the trial court misapplied the de facto merger exception and reversed. The Supreme Court concluded the Superior Court erred by (1) applying an overly-narrow and mechanical continuity of ownership analysis; and (2) substituted its own factual findings for those of the trial court in several instances in its review of the remaining prongs of the de facto merger exception, the Supreme Court. Accordingly, the Superior Court’s order was vacated, and the matter was remanded for further proceedings. View "Fizzano Bros. Concrete v. XLN, Inc." on Justia Law

The Commonwealth appealed a superior court order that affirmed a trial court's dismissal of charges against Appellee William Wilgus for a violation of Megan's Law requirements. Appellee was convicted in 1998 of aggravated indecent assault; he received a sentence of five years to life imprisonment, was found to be a sexually violent predator, and was ordered to comply with Megan’s Law registration requirements. The Superior Court vacated this sentence and remanded for resentencing without application of Megan’s Law registration requirements; appellee was resentenced to five to 10 years imprisonment. He became subject to lifetime registration requirements because he was incarcerated when revisions to Megan’s Law became effective in 2007. The trial court found evidence submitted against him at trial insufficient to support his convictions, granted his motions for post-sentence relief and the court dismissed the charges against him. Upon review, the Supreme Court reversed: "Pennsylvania’s Megan’s Law clearly requires sexually violent predators to notify Pennsylvania State Police of all current and intended residences, and to notify police of a change of residence. Unlike some other states that have ruled on this issue, Pennsylvania clearly defines 'residence' for registration purposes. Appellee reported an intended residence to prison authorities, and was in violation of registration requirements when he failed to report a change of residence when he no longer intended to live there. There is no exception for homeless offenders, and the Superior Court was incorrect in reading such an exception into the statute." View "Pennsylvania v. Wilgus" on Justia Law

In this case, the Supreme Court considered whether deputy sheriffs of second class counties were "police officers" for collective barganing purposes under "Act 111." The Commonwealth Court determined they are not after hearing the Allegheny County Deputy Sheriffs' Association filed a petition with the Pennsylvania Labor Relations Board (PLRB) seeking to represent the deputies employed by Allegheny County. The Association twice before had attempted to attain this same objective, only to fail before the PLRB and the Commonwealth Court. However, following those decisions, the General Assembly amended the Crimes Code in 1995, and then the Municipal Police Education and Training Law (MPETL) in 1996, to define deputy sheriffs in a second-class county (i.e., the Deputy Sheriffs) as police officers. Concluding that the aforesaid legislative action was not dispositive of the issue, the PLRB hearing examiner here determined that the Deputy Sheriffs were not "police officers" as contemplated by Act 111 because he found that their primary duties were not those of typical police officers, but rather were those directly related to the operation of the courts. "[The Supreme Court's] inquiry with respect to the question accepted for review ends with the recognition that the General Assembly expressly defined -- and thus authorized -- deputy sheriffs of counties of the second class to be police officers. . . . Thus, the PLRB’s and Commonwealth Court’s application of a judicially and administratively created test to examine whether the Deputy Sheriffs are police officers, after they have been defined as such by the General Assembly, was erroneous." View "Allegheny Cty Sheriffs' Ass'n v. Pa. Labor Relations Bd." on Justia Law

This appeal arose out of a medical-device product liability action in which a strict liability, design-defect theory was asserted. Given that the surgical instrument at issue was said to have multiple applications, the Supreme Court was asked to determine whether the trial court's threshold risk-utility analysis should have been limited to the particular one alleged to have caused the decedent harm. Additionally, the appeal was allowed to consider the degree to which an appellate court is bound by such weight and credibility determinations as may be made by a trial court in a risk-utility assessment. The decedent Sandra Selepec, underwent gastric bypass surgery in August 2002. The surgeon used a product manufactured by Appellee Ethicon Endo-Surgery, Inc. known as an ETS-Flex45 Articulating Endoscopic Linear Cutter, or an "endocutter." Appellee also marketed its product as being useful in more traditional surgery, in which larger incisions are made to expose organs to open view and accessibility. Mrs. Selepec's surgery was of this latter kind. During recovery, Mrs. Selepec experienced complications, and surgeons reentered her abdomen to discover that two of the bypass staples failed. On the merits, Appellee argued that courts applying the risk-utility analysis have always considered the risks, benefits, and design constraints associated with all intended uses of a product; to artificially limit the risk utility analysis to the particular use to which a plaintiff put a product in a particular case would be to ignore the inherent, essential characteristics that informed the design; and to hold multi-use products to the same standard as single-use products would be tantamount to requiring the sale of multiple single-use products, which would be inefficient and impractical, if not impossible. Upon review, the Supreme Court held that trial courts are not restricted to considering a single use of a multiuse product in design defect, threshold, risk-utility balancing. The Court also declined to disturb the Superior Court's legal determination as to the appropriate risk-utility calculus. View "Beard v. Johnson & Johnson, Inc." on Justia Law

The central issue in this case focused on whether the term "compensation" as used in Section 314(a) of the Workers' Compensation Act, includes medical benefits as well as wage loss benefits. Claimant Quila Givner suffered a work-related injury in 1998 while working for Appellant Giant Eagle, Inc. She received workers' compensation benefits that were calculated for partial disability. In 2007, Giant Eagle filed a suspension petition pursuant to Section 314(a), alleging that Claimant had failed to attend a physical examination that it scheduled. The Workers' Compensation Judge (WCJ) suspended Claimant's wage loss benefits because of her failure to submit to the examination, but Giant Eagle appealed to the Workers' Compensation Appeal Board (WCAB), contending that the WCJ had erred by suspending only wage loss benefits and not medical expense benefits too. The WCAB rejected Employer’s argument, and the Commonwealth Court affirmed. Upon review, the Supreme Court held that "compensation" must include medical benefits as well as wage loss benefits under Section 314(a). However, the Court held that "compensation," as used in Section 314(a) need not always include medical expenses, and accordingly affirmed the Commonwealth Court. View "Giant Eagle, Inc. v. Workers' Compensation Appeals Board" on Justia Law

The Department of Public Welfare (DPW) and the Office of the Budget of the Commonwealth of Pennsylvania appealed a Commonwealth Court order which granted summary judgment to Appellees the Pennsylvania Medical Society and its individual members, and the Hospital and Healthsystem Association of Pennsylvania and its individual members. The court declared that the Commonwealth had an obligation under the Health Care Provider Retention Law (the Abatement Law) to transfer monies to the Medical Care Availability and Reduction of Error Fund (MCARE Fund) in an amount necessary to fund dollar for dollar, all abatements of annual assessments granted to health care providers for the years 2003-2007. Upon review of the Commonwealth Court record, the Supreme Court held that the Abatement Law gave the Secretary of the Budget the discretion, but not the obligation, to transfer monies into the MCARE Fund in an amount up to the total amount of abatements granted. Furthermore, the Court concluded that Apellees had no statutory entitlement to the funds held in abatement, nor a vested right to them. View "Pa. Medical Society v. Pennsylvania" on Justia Law

Defendant Andre Staton appealed the death sentence he received in 2006 in connection with the stabbing death of Beverly Yohn. Defendant was charged with a single count of criminal homicide, two counts of aggravated assault, and one count each of burglary, criminal trespass, receiving stolen property and theft by unlawful taking. Appellant testified at trial. He admitted that he stabbed Ms. Yohn, and caused her death, but denied that he had gone to the residence with the intent to harm her. On appeal, Defendant raised a single claim of error related to the penalty phase of his trial. Upon review, the Supreme Court found no error and affirmed Defendant's conviction and judgment of sentence. View "Pennsylvania v. Staton" on Justia Law