Justia Pennsylvania Supreme Court Opinion Summaries

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

In this appeal by allowance, the Supreme Court considered whether the "separate disease" rule (also referred to as the "two-disease" rule) allows an individual to bring separate lawsuits for more than one malignant disease which allegedly resulted from the same asbestos exposure. The matter arose from Appellee Herbert Daley's 1989 diagnosis of pulmonary asbestosis and squamous-cell carcinoma in his right lung. He filed suit against several defendants seeking compensatory damages for work-related injuries and settled. In 2005, Appellee filed suit against US Supply, Duro-Dyne and A.W. Chesterson alleging that a late diagnosis of mesothelioma was caused by the same exposure that resulted in his lung cancer. The companies argued that Pennsylvania had not adopted the two-disease rule, and that his mesothelioma diagnosis was barred by a two-year statute of limitations. Upon review, the Court concluded that the rule did apply, and, accordingly, the Court affirmed an order of the Superior Court, which reversed the trial court's grant of summary judgment in favor of U.S. Supply Co. and Duro-Dyne Corp. View "Daley v. A.W. Chesterton" on Justia Law

In this discretionary appeal, the Supreme Court considered whether 18 Pa.C.S.A. 4914, which prohibits a person from furnishing false identification to law enforcement authorities, requires proof that those law enforcement authorities first identify themselves to the person and advise the person that he was the subject of an official investigation for a violation of law. The record revealed that in 2009, Pittsburgh City Police officers were investigating an armed robbery. According to the victim, a young boy pointed a gun at him as he was standing at an intersection and robbed him of $10. The victim gave police a description of his assailant, and the police developed a list of individuals they knew matched the description. D.S. was one of those individuals. Plain clothes detectives then "went out actively looking for [D.S.] in essence to field contact him." The officers did not identify themselves as police officers, nor did they state their purpose for stopping D.S. Upon review, the Supreme Court found that the evidence was insufficient to support D.S.'s adjudication of delinquency. The Court reversed the Superior Court's order that affirmed D.S.'s adjudication of delinquency. View "In the Interest of D.S." on Justia Law

This case raised the question of whether an uninsured driver who was injured in a motor vehicle accident with an insured driver, may sue the insured driver in tort for economic damages. "The question highlight[ed] a tension" in the Motor Vehicle Financial Responsibility Law, (MVFRL), 75 Pa.C.S. 1701-1799, and Pennsylvania decisional precedent, as noted by the United States Court of Appeals for the Third Circuit. On the one hand, Section 1714 of the MVFRL prohibits uninsured drivers from recovering first-party benefits, which include medical and income loss benefits. On the other, Section 1705 of the MVFRL deems uninsured drivers to have chosen the limited tort alternative, which permits recovery of damages for economic loss sustained in a motor vehicle accident as the consequence of the fault of another person. Loss is commonly understood as being comprised of damages for medical expenses and wage loss. "Thus, it may appear as though the MVFRL both prohibits and permits insurance recovery to uninsured drivers for this category of damages or loss." The Supreme Court answered the question posed by the Third Circuit in the negative: Section 1714 of the MVFRL does not preclude an uninsured motorist from recovering tort damages for economic loss from an alleged third-party tortfeasor under the torfeasor’s liability coverage. View "Corbin v. Khosla" on Justia Law

Appellant, the mother of G.L.M., filed a complaint seeking support from Appellee, whom she believed to be G.L.M.'s biological father. Appellee responded with a motion to dismiss, relying upon Mother's intact marriage to H.M.M. at the time of G.L.M.'s birth as establishing a presumption of paternity and on H.M.M.'s assumption of parental responsibilities as implicating paternity by estoppel. The common pleas court granted Appellee's motion to dismiss the support action against Appellee, finding that the presumption of paternity was controlling and, alternatively, that H.M.M. should be regarded as G.L.M.’s father via paternity by estoppel. The court elaborated that under the presumption, a party who denied paternity of a child born during an intact marriage had the burden to show by clear and convincing evidence that the presumptive father lacked access to the mother or was incapable of procreation. Based on the hearing record, the common pleas court determined that H.M.M. had held himself out as G.L.M.'s father. The Supreme Court allowed this appeal to consider the application of the doctrine of paternity by estoppel in this case and more broadly, its continuing application as a common law principle. The Court held that paternity by estoppel continues to pertain in Pennsylvania, but it will apply only where it can be shown, on a developed record, that it is in the best interests of the involved child. The Court reversed the Superior Court and remanded the case for further proceedings. View "K.E.M. v. P.C.S." on Justia Law