Justia Pennsylvania Supreme Court Opinion Summaries

Plaintiff-Respondent Lindsay Franczyk, was working at a Home Depot store when a customer’s dog bit her. Franczyk reported the bite promptly to her supervisors, Philip Rogers and Thomas Mason (collectively with Home Depot, “Defendants”). Franczyk later was diagnosed with cubital tunnel syndrome, which required surgical repair. Franczyk claimed and received Workers’ Compensation Act ("WCA") benefits. Franczyk sued Defendants. In her relevant claim, Franczyk asserts that Defendants failed to investigate the incident sufficiently, and that they negligently allowed the dog owner and witnesses to leave without obtaining identifying information. She contended these acts and omissions denied her the opportunity to file a third-party suit against the dog owner. After the pleading and discovery phases of the litigation concluded, Defendants filed a motion for summary judgment, claiming immunity under the WCA’s exclusivity provision. The trial court recognized a novel exception and denied the employer’s motion for summary judgment. The Superior Court affirmed the trial court’s decision. However, the Pennsylvania Supreme Court disagreed: "the exception proffered by the lower courts cannot be reconciled with the Act’s design, purpose, or plain language." Thus, judgment was reversed. View "Franczyk v. Home Depot, et al." on Justia Law

Appellant Damien Green appealed a superior court order which quashed his appeal of a Court of Common Pleas order. The superior court concluded the trial court’s order, granting decertification to a juvenile who was to be tried as an adult for murder, constituted a legal nullity because the decertification order was not filed within the time constraints set forth in Section 6322(b) of the Juvenile Act, 42 Pa. C.S. § 6322(b), and Pennsylvania Rule of Criminal Procedure 597 (Rule 597). The Pennsylvania Supreme Court accepted review in this case to consider, as a matter of first impression, whether a transfer order filed after the 20-day limitation in Section 6322 of the Juvenile Act and Rule 597 was a legal nullity or should exceptions created by Pennsylvania jurisprudence under similar rules and statutes be applicable. Following oral argument, the Supreme Court entered a per curiam order October 28, 2022, affirming the Superior Court’s order quashing the appeal. The order also remanded the matter to the trial court for immediate entry of an order by the clerk of courts pursuant to Rule 597(D). View "Pennsylvania v. Green" on Justia Law

The underlying proceedings took place before the Pennsylvania Lawyers Fund for Client Security, an entity created by the Pennsylvania Supreme Court to reimburse clients for financial losses caused by their attorneys. Daryl Yount, Esquire, an attorney involved in these proceedings, sought access to an audio recording of a hearing conducted on October 19, 2021, before a Hearing Committee appointed by the Fund’s Board of Trustees. Yount attempted to obtain this recording via the subpoena process in Pa.R.D.E. 521(c), an effort that the Hearing Committee rejected. The Supreme Court determined the subpoena was only valid for the purpose of summoning witnesses to testify at a hearing: he attempted to use it to require the production of an audio recording. For this reason alone, the Hearing Committee did not err in determining that Attorney Yount’s subpoena was invalid. The Supreme Court affirmed the Hearing Committee’s determination that the subpoena was invalid without prejudice, so that Attorney Yount could seek the requested item through other means. View "Yount v. Pa. Lawyers Fund Client Sec." on Justia Law

In 2010, Appellant Dontez Perrin was convicted after a non-jury trial of conspiracy, aggravated assault, robbery, possessing instruments of crime, simple assault, recklessly endangering another person, receiving stolen property, firearms not to be carried without a license, and possession of firearm by minor for his role in the robbery and assault of victim Rodney Thompson when Thompson arrived at an apartment to deliver a pizza. The trial court imposed an aggregate sentence of five to ten years’ imprisonment. In an appeal by allowance, the Pennsylvania Supreme Court was tasked with determining whether the trial court erred in refusing to accept a proposed stipulation as to witness credibility in the context of a post-sentence motion for a new trial. As the Supreme Court determined the trial court was well within its right to reject the proposed stipulation, it affirmed its denial of Appellant’s motion. View "Pennsylvania v. Perrin" on Justia Law

The U.S. Third Circuit Court of Appeals certified a question of law to the Pennsylvania Supreme Court. The question centered on the single issue of whether Pennsylvania’s first-degree aggravated assault provision, codified at 18 Pa.C.S. § 2702(a)(1), required some use of physical force. Appellant Marc Harris pled guilty to possession of a firearm by a convicted felon. The United States District Court for the Eastern District of Pennsylvania sentenced Appellant pursuant to the federal Armed Career Criminal Act (“ACCA”). Notably, the ACCA defines the term “violent felony” as including any crime punishable by a term of imprisonment exceeding one year that, inter alia: (1) “has as an element the use, attempted use, or threatened use of physical force against the person of another” (“element of force clause”). The Supreme Court answered this inquiry in the negative, holding that the offense of aggravated assault under Section 2702(a)(1) did not require the actor to exercise physical force when inflicting or attempting to inflict serious bodily injury upon the victim. View "United States v. Harris" on Justia Law

This case arose from the April 2008 murder of D.B., a two-year-old child living with her mother and appellant Harve Johnson, mother’s boyfriend. Johnson appealed a Court of Common Pleas denying his first, timely petition for post-conviction relief pursuant to the Post Conviction Relief Act (PCRA). Johnson raised twenty-two claims; following a comprehensive review, the Pennsylvania Supreme Court concluded none entitled him to relief and affirmed the denial of post-conviction relief. View "Pennsylvania v. Johnson" on Justia Law

In a discretionary appeal, the Pennsylvania Supreme Court considered whether Global Positioning System (“GPS”) data compiled from a GPS monitoring device on a parolee, was inadmissible hearsay. After careful consideration, the Court held that the challenged evidence was not hearsay because it does not constitute a statement made by a declarant, as outlined in Pennsylvania Rule of Evidence 801, as it is not an assertion (or the nonverbal conduct) of a person. View "Pennsylvania v. Wallace" on Justia Law

This case centered upon how Appellee Synthes USA HQ, Inc. should apportion its income between Pennsylvania and other states in order to calculate its Pennsylvania corporate net income tax. The two issues presented were: (1) does the Pennsylvania Office of the Attorney General (“OAG”) have the authority to represent the Commonwealth in this litigation, where it asserted an interpretation of the relevant tax provision contrary to the reading forwarded by the Pennsylvania Department of Revenue (“Department”); and (2) whether the allocation of a corporation's sales of services between Pennsylvania and other states for purposes of calculating the corporation’s income that was taxable in Pennsylvania. After review, the Pennsylvania Supreme Court concluded the Commonwealth Attorneys Act permitted the OAG to take a position on behalf of the Commonwealth that was inconsistent with the position adopted by the Department, but the Court ultimately rejected the OAG’s reading of the relevant tax provision in favor of the interpretation presented by the Department. Accordingly, the Court affirmed the order of the Commonwealth Court remanding this case to the Board of Finance and Revenue for calculation and issuance of a tax refund by the Department to Synthes for the 2011 tax year. View "Synthes USA HQ v. Pennsylvania" on Justia Law

An agency's self-imposed limitation at issue in these cases consolidated for argument was the Environmental Hearing Board’s rule that no private party to an appeal could be compelled to reimburse another party unless it has pursued or defended the appeal in bad faith or for an improper purpose. The Pennsylvania Supreme Court concluded that the to-all-appearances per se bad-faith standard that the Board applied to any effort to recover fees against a private party was incompatible with the intent embodied in the Clean Streams Law (“CSL”). The Board justified its contrary view with an overbroad reading of Pennsylvania case law, relying upon an assumed equivalency between permit applicants and citizen objectors that the Supreme Court could not reconcile with the parties’ respective roles and incentives in pursuing or defending such appeals under the CSL. The Supreme Court further concluded that the Department of Environmental Protection should stand on an equal footing with all other parties at the outset of a fee-shifting inquiry, subject to disparate treatment only when it bears disparate responsibility for whatever prompted a successful appeal. View "Clean Air Council, et al. v. Dept. Env. Prot. et al." on Justia Law

This direct appeal to the Pennsylvania Supreme Court centered on the efforts of Appellee John Myers to obtain a refund of 38 cents in sales tax he paid on purchases he made with redeemed coupons at BJ’s Wholesale Club, Inc. (BJ’s). The parties petitioned the Pennsylvania Supreme Court to interpret Section 33.2(b) of the Pennsylvania Department of Revenue Code, which excluded “from the taxable portion of the purchase price, if separately stated and identified." A vendor owes the state sales tax on the full price of the item unless it can establish a “new purchase price” of the item, which may be established where “both the item and the coupon are described on the invoice or cash register tape.” The Pennsylvania Department of Revenue Board of Appeals (BOA) relied on Section 33.2, which permitted amounts represented by coupons to establish a new purchase price “if both the item and the coupon are described on the invoice or cash register tape.” The BOA concluded that the coupons were not adequately described on the receipts, and nothing indicated which items the coupons were related. A unanimous three-judge panel of the Commonwealth Court reversed the Board’s order and found Appellee was entitled to a refund of overpaid sales tax. The Supreme Court reversed the Commonwealth Court, finding none of the receipts at issue here satisfied subsection 33.2(b)(2)’s description requirement. Because it was Appellee’s burden to prove that he was entitled to a refund of sales tax, he did not meet his burden. View "Myers v. Pennsylvania" on Justia Law