Justia Pennsylvania Supreme Court Opinion Summaries

Several minors were injured at trampoline parks operated by Sky Zone in Philadelphia. In each instance, only one parent signed a “Participation Agreement, Release and Assumption of the Risk” on behalf of their child, which included an arbitration provision waiving the right to sue in court. After the injuries, both the signing and non-signing parents, along with the injured minors, brought lawsuits seeking damages for the injuries sustained at the facilities.The Court of Common Pleas of Philadelphia County reviewed petitions by Sky Zone to compel arbitration and stay the litigation, relying on the signed agreements. The trial courts denied these petitions, finding that the agreements were enforceable only against the signing parent. The courts determined that a spouse does not have authority to act as the agent of the other simply by virtue of marriage, and Sky Zone had not provided evidence of agency. Additionally, the courts held that parents do not have the legal authority to waive a minor’s right to pursue personal injury claims or to bind a minor to an arbitration agreement that would require waiving the right to a judicial forum.The Superior Court of Pennsylvania affirmed the trial courts’ decisions, holding that neither the non-signing parents nor the minors were bound by the arbitration provisions. The Superior Court reasoned that agency cannot be inferred from family ties alone and that parents, as natural guardians, lack inherent authority to manage a minor’s property, including legal claims, without court approval.The Supreme Court of Pennsylvania reviewed the case and affirmed the Superior Court’s orders. The Court held that a parent who signs an arbitration agreement cannot bind a non-signing spouse or a minor child to its terms. Specifically, parents lack the authority to bind a minor to an agreement to arbitrate, as this would deprive the minor of judicial protections and oversight designed to safeguard their interests. View "Shultz v. Sky Zone, LLC" on Justia Law

Police officers on patrol in Philadelphia observed a group of men on the 1200 block of West Dauphin Street who appeared to be gambling, an activity prohibited by city ordinance. As the officers approached, Anthony Lewis, who was among the group and carrying a black leather bag, made eye contact with one of the officers, appeared startled, and fled. The officers pursued Lewis, who was apprehended after discarding his bag over a fence. The bag was recovered and found to contain a loaded firearm, and DNA evidence later linked Lewis to the gun.Lewis moved to suppress the firearm, arguing that the police lacked reasonable suspicion to pursue him. At the suppression hearing in the Philadelphia County Court of Common Pleas, the Commonwealth presented testimony from the officers, who described the area as known for gambling, narcotics sales, and recent violent crimes. The trial court credited the officers’ testimony, found the area to be high in crime, and concluded that Lewis’s unprovoked flight in that context gave rise to reasonable suspicion. The court denied the suppression motion, and Lewis was subsequently convicted of several firearm offenses. The Superior Court of Pennsylvania affirmed, holding that the officers’ observations, combined with the high-crime nature of the area and Lewis’s flight, supported reasonable suspicion for the stop and that the firearm was not the product of coerced abandonment.The Supreme Court of Pennsylvania reviewed whether the evidence was sufficient to establish the area as high in crime and whether the firearm should have been suppressed. The court held that the Commonwealth bears the burden of proving an area is high in crime but declined to impose a rigid, multi-element test for such a designation. Instead, the court left the determination to the discretion of suppression courts, emphasizing that mere invocation of “high-crime area” is insufficient. The court affirmed the Superior Court’s order, holding that the evidence supported the finding of a high-crime area and that the police had reasonable suspicion to pursue Lewis. View "Commonwealth v. Lewis" on Justia Law

A catastrophic multi-vehicle collision occurred in Westmoreland County, Pennsylvania, involving a motorcoach bus, FedEx and UPS tractor-trailers, and other vehicles. The crash resulted in five deaths and numerous injuries, requiring a large emergency response and extensive investigation. Plaintiffs, who resided in various locations across the country and abroad, filed civil lawsuits in the Philadelphia County Court of Common Pleas against several corporate defendants, all of which conduct business nationwide. The defendants sought to transfer the cases to Westmoreland County, arguing that the majority of witnesses, including first responders and investigators, were located there and would face significant hardship if required to travel over 200 miles to Philadelphia for trial.The Philadelphia County Court of Common Pleas granted the defendants’ petitions to transfer venue, finding that the burden on witnesses was substantial and that the doctrine of forum non conveniens warranted transfer. The court noted that the defendants had identified numerous witnesses whose testimony would be material and who would be significantly inconvenienced by the distance. The plaintiffs appealed, and the Superior Court of Pennsylvania reversed, holding that the defendants failed to show that the identified witnesses were “key witnesses” whose testimony was “critical” to the defense, and that the affidavits did not sufficiently detail the necessity of their testimony.The Supreme Court of Pennsylvania reviewed the case and reversed the Superior Court’s order. The Court held that the Superior Court’s imposition of a “key witness” requirement was inconsistent with Pennsylvania precedent. The Supreme Court clarified that a petitioner seeking transfer for forum non conveniens must identify the burdened witnesses and provide a general statement of their expected testimony, but need not show that their testimony is “critical” or “necessary” to the defense. The trial court’s decision to transfer the cases to Westmoreland County was found to be a proper exercise of discretion. View "Tranter v. Z&D Tour, Inc." on Justia Law

Several companies that supply electricity generation services in Pennsylvania challenged a billing practice used by a regional electric distribution company (EDC), FirstEnergy. FirstEnergy, which is responsible for delivering electricity to customers, offered its own customers the option to pay for non-commodity goods and services—such as smart thermostats and surge protection—through their regular utility bills, a practice known as “on-bill billing.” However, FirstEnergy did not allow competing electric generation suppliers (EGSs) to use this billing method for their own non-commodity goods and services. The EGSs argued that this practice was unlawfully discriminatory under Section 1502 of the Public Utility Code and Section 2804(6) of the Electricity Generation Customer Choice and Competition Act, which prohibit unreasonable preferences or advantages in utility service.An administrative law judge initially found in favor of the EGSs, concluding that FirstEnergy’s practice gave it a significant competitive advantage and violated the anti-discrimination provisions. However, the Pennsylvania Public Utility Commission (PUC) reversed this decision, reasoning that discrimination only occurs if the EDC provides the billing service to third parties but not to EGSs, which was not the case here. The PUC also determined that the relevant statutes did not require EDCs to offer on-bill billing for non-commodity goods and services to EGSs.The Commonwealth Court of Pennsylvania affirmed the PUC’s decision, holding that the statutory provisions at issue did not obligate EDCs to provide on-bill billing for non-commodity goods and services to EGSs. The Supreme Court of Pennsylvania reviewed the case and agreed with the lower courts. The Court held that EDCs have no statutory duty to provide on-bill billing for non-commodity goods and services to EGSs, and that such billing does not constitute “service,” “electric services,” or “transmission and distribution service” under the relevant statutes. The Court affirmed the order of the Commonwealth Court. View "Interstate Gas Supply, Inc. v. Public Utility Commission" on Justia Law

Entities approved to grow, process, or test medical marijuana in Pennsylvania challenged a regulation issued by the Pennsylvania Department of Health. The Department required that growers and processors use one independent laboratory to test marijuana at harvest and a different independent laboratory to test the product after processing, a rule known as the “two-lab requirement.” The challengers argued that this regulation exceeded the Department’s authority under the Medical Marijuana Act, which states that growers and processors must contract with “one or more independent laboratories” for testing.The Commonwealth Court of Pennsylvania, sitting en banc, reviewed the challenge. It focused on the statutory language in Section 704 of the Act, interpreting the phrase “one or more independent laboratories” to mean that growers and processors could choose to use only one laboratory if they wished. The court concluded that the Department’s two-lab requirement conflicted with the Act and declared the regulation unenforceable. A dissenting opinion argued that the Department had broad regulatory authority under the Act, including the power to require multiple laboratories to ensure patient safety.The Supreme Court of Pennsylvania reviewed the case on direct appeal. It held that the Medical Marijuana Act grants the Department of Health discretion to determine the number of laboratories required for testing, in order to fulfill the Act’s explicit goals, including patient safety and high-quality research. The Court found that the Commonwealth Court erred by interpreting Section 704 in isolation and failing to consider the broader context and policy objectives of the Act. The Supreme Court reversed the Commonwealth Court’s order and remanded the case for further proceedings to address the remaining issues, including whether the two-lab requirement is reasonable. View "Green Analytics North, LLC v. Department of Health" on Justia Law

The Housing Authority of the City of Pittsburgh leased a unit in the Northview Heights Complex to Darlene Nash. On January 9, 2021, Nash hosted a birthday party at her unit, which was attended by numerous people, including a juvenile known as “Shooter.” During the party, after Nash asked another guest, Blake Green, to leave, Green was shot and killed inside Nash’s unit. Shooter was identified as the main suspect, though no charges or arrests were made. The Housing Authority served Nash with a notice to terminate her lease, citing the shooting as a violation of lease provisions prohibiting criminal activity and the discharge of deadly weapons by any “Covered Person,” which includes guests and other persons under the tenant’s control.The Magisterial District Court granted the Housing Authority possession of the unit, permitting eviction. Nash appealed to the Allegheny County Court of Common Pleas, where a non-jury trial was held. The trial court found that Shooter was not an unauthorized occupant or a guest, but was an “Other Person Under the Tenant’s Control” (OPTC) due to Nash’s “open house” invitation. The court concluded Nash violated the lease and awarded possession to the Housing Authority. Nash’s post-trial motion was denied, and she appealed to the Commonwealth Court.The Commonwealth Court reversed, reasoning that an invitation to the unit was not the same as an invitation to the premises, and the Housing Authority had not established that Shooter was on the premises due to Nash’s invitation. On appeal, the Supreme Court of Pennsylvania reviewed the lease and relevant law de novo, holding that an invitation to a unit is an invitation to the premises, and Shooter was an OPTC at the time of the shooting. The Supreme Court reversed the Commonwealth Court’s decision, holding that the Housing Authority may evict Nash for the criminal act committed by Shooter in her unit. View "Housing Authority v. Nash" on Justia Law

The City of Pittsburgh imposed a three percent tax, known as the Nonresident Sports Facility Usage Fee, on income earned by nonresidents performing at its publicly funded sports stadiums. Resident performers were subject instead to a one percent earned income tax by the City and a two percent school district tax, while nonresidents were exempt from the school district tax. The plaintiffs, consisting of professional athletes and their unions, challenged the facility fee, arguing that it violated the Uniformity Clause of the Pennsylvania Constitution by taxing nonresident performers at a higher rate than resident performers for similar activities.The Court of Common Pleas of Allegheny County granted summary judgment in favor of the plaintiffs, finding that the facility fee was unconstitutional. The court reasoned that the relevant comparison was between the City’s tax on residents and the facility fee on nonresidents, and that the school district tax paid by residents could not be used to justify the higher tax on nonresidents, since nonresidents were not subject to the school district tax by law. The Commonwealth Court affirmed, agreeing that the City failed to provide a legitimate justification for the disparate treatment and that the school district tax was not relevant to the uniformity analysis.The Supreme Court of Pennsylvania reviewed the case and affirmed the lower courts’ decisions. The Court held that the City’s facility fee violated the Uniformity Clause because it imposed a higher tax burden on nonresident athletes and entertainers without a concrete justification for treating them differently from residents. The Court rejected the City’s argument that the overall tax burden was equalized by including the school district tax, emphasizing that taxes imposed by separate entities for distinct purposes cannot be aggregated to manufacture uniformity. The facility fee was therefore found unconstitutional. View "National Hockey League Players Ass'n v. City of Pittsburgh" on Justia Law

A defendant was arrested on drug charges and initially held on high bail, which was later reduced. A bail bondsman posted the reduced bail, agreeing to be liable if the defendant failed to appear in court. The court scheduled a pretrial conference, but due to administrative errors, the defendant and his counsel were misinformed about the date. As a result, they missed the proceeding, leading the trial court to issue a bench warrant and revoke bail. Days later, when the defendant appeared for what he believed was the correct date, the court vacated the bench warrant and reinstated bail, relying on the defense counsel’s oral representation that the bondsman consented to continue as surety, but did not obtain written consent.Months later, the defendant failed to appear for trial, resulting in another bail revocation and notice of intent to forfeit the bond. The bondsman, after being notified of the impending forfeiture, filed a petition to strike or set aside the forfeiture, arguing that the court had failed to obtain his written consent when bail was previously reinstated. The Cumberland County Court of Common Pleas denied the petition. The Superior Court of Pennsylvania affirmed, reasoning that written consent was not required because the initial bail revocation was due to court error, not the defendant’s fault.The Supreme Court of Pennsylvania reviewed the case to determine whether the statutory requirement for written consent from a bail bondsman applies when bail is reinstated after a revocation caused by court error. The court held that the statute requires written consent from the bail bondsman whenever bail is reinstated after a defendant’s failure to appear, regardless of whether the failure was due to a breakdown in court administration. However, the court found that the bondsman was not entitled to relief because he failed to timely appeal the order reinstating bail. The Supreme Court affirmed the Superior Court’s result, but on different grounds. View "Commonwealth v. Rondon" on Justia Law

A woman, identified as the victim, lived with her mother and infant sister. The mother’s boyfriend, the appellant, would babysit the children at night. The victim testified that, starting at age 10, the appellant repeatedly entered her bedroom and sexually assaulted her. She disclosed the abuse to family members and a doctor, and later to a teacher, which led to police involvement. The appellant was charged with multiple sexual offenses, including rape of a child and related crimes.Before trial in the Court of Common Pleas of Allegheny County, the Commonwealth proposed a voir dire question to potential jurors, asking if they could follow the legal principle that the testimony of an alleged victim alone, if believed, is sufficient to convict in a sexual assault case. The appellant objected, arguing the question was improper and misstated the law. The trial court denied the objection, and the jury convicted the appellant on all charges, resulting in a lengthy prison sentence. The appellant’s post-sentence motion was denied, and he appealed to the Superior Court of Pennsylvania, arguing, among other things, that the voir dire question was improper. The Superior Court affirmed the judgment, finding the question proper and consistent with Pennsylvania law and jury instructions.The Supreme Court of Pennsylvania reviewed whether the trial court erred in allowing the voir dire question. The Court held that the trial court did not abuse its discretion. It found the question was designed to ensure jurors could follow the law that a victim’s uncorroborated testimony, if believed, can be sufficient for conviction in sexual assault cases. The Court concluded that such a question is permissible to identify jurors with fixed beliefs contrary to this legal principle. The judgment of sentence was affirmed. View "Commonwealth v. Walker" on Justia Law

A high school in a Pennsylvania school district displayed approximately 70 books in its library, some of which addressed LGBTQ+ issues in anticipation of Pride Month. A third-party contractor photographed the display and posted it on Facebook. Two school board members, David Valesky and Luigi DeFrancesco, shared the post on their personal Facebook accounts, with Valesky adding commentary critical of the display. This sparked public debate, including a newspaper article and discussions at subsequent school board meetings. Thomas Cagle, a local resident, submitted a request under Pennsylvania’s Right-to-Know Law (RTKL) seeking, among other things, all Facebook posts and comments by the two board members related to homosexuality and the school district.The school district partially denied the request, providing some emails but refusing to disclose any social media content, arguing that the posts were on personal accounts and not within the district’s possession. Cagle appealed to the Pennsylvania Office of Open Records (OOR), which ordered disclosure, reasoning that the content, not the ownership of the account, determined whether the posts were public records. The district sought judicial review in the Court of Common Pleas of Crawford County, which agreed with the OOR and ordered disclosure, finding that the posts documented district business and were thus subject to the RTKL.On appeal, the Commonwealth Court vacated the trial court’s order and remanded for further proceedings, instructing the lower court to consider additional factors to determine whether the posts were “of the agency” under the RTKL. The Supreme Court of Pennsylvania reviewed the case and held that the RTKL’s two-part test—whether the information documents a transaction or activity of an agency and was created, received, or retained in connection with agency business—applies to all forms of communication, including social media. The Court affirmed the Commonwealth Court’s order to remand for further fact-finding, clarifying that no special test applies to social media, but relevant facts must be considered in each case. View "Penncrest SD v. Cagle" on Justia Law