Justia Pennsylvania Supreme Court Opinion Summaries

Several voters in Washington County, Pennsylvania, submitted mail-in ballots for the 2024 Primary Election that contained obvious errors, such as missing signatures or dates on the declaration envelope, or missing secrecy envelopes. Under a previous policy, the county board of elections notified voters of such defects and allowed them to correct the errors or vote provisionally. However, in April 2024, the board adopted a new policy eliminating notice and cure procedures. Instead, all returned mail-in ballots, including those with disqualifying errors, were coded identically in the state’s SURE system, which triggered an email to voters stating their ballot had been received and that they could not vote at the polls, regardless of whether their ballot was valid. As a result, voters whose ballots were set aside for errors were not informed of the disqualification and did not attempt to vote provisionally.The Washington County Court of Common Pleas found that the board’s policy violated voters’ procedural due process rights under the Pennsylvania Constitution by failing to provide notice that their ballots would not be counted, thus depriving them of the opportunity to challenge the decision or vote provisionally. The court issued an injunction requiring the board to notify affected voters, accurately code ballots in the SURE system, and ensure poll books reflected that such voters had not “voted,” allowing them to cast provisional ballots. The Commonwealth Court affirmed, holding that the right to vote and the statutory right to cast a provisional ballot are protected liberty interests, and that the board’s policy risked erroneous deprivation of those rights.The Supreme Court of Pennsylvania affirmed in large part, holding that the right to vote and the statutory right to cast a provisional ballot when a mail-in ballot is void are protected liberty interests under the Pennsylvania Constitution. The court held that due process requires county boards to provide accurate notice—via correct SURE system coding—when a mail-in ballot is segregated for a disqualifying error, so affected voters have the opportunity to vote provisionally. The court vacated the requirement for additional notice beyond accurate SURE coding and clarified that the right to challenge under 25 P.S. §3157 does not require pre-canvass challenges. The injunction otherwise remains in effect. View "Center for Coalfield Justice v. Washington County Board of Elections" on Justia Law

The case concerns James Smith, who was charged with multiple counts of child sexual assault involving two minor victims, the daughters of a friend, in Philadelphia. Before trial, Smith requested that the jury panel be asked during voir dire whether they were more likely to believe the testimony of a child alleging sexual abuse because they did not believe a child could lie about such abuse. The trial court declined to ask this specific question but did inform jurors about the nature of the charges, asked about their ability to be impartial, and conducted individual voir dire regarding experiences with sexual assault or child abuse, dismissing several jurors for cause based on their responses.Smith was convicted on all counts, including rape of a child, unlawful contact with a minor, corruption of minors, involuntary deviate sexual intercourse with a child, and aggravated indecent assault of a person less than thirteen years of age. He appealed to the Superior Court of Pennsylvania, arguing that the trial court erred in refusing his proposed voir dire question and that the evidence was insufficient to support his convictions for unlawful contact with a minor. The Superior Court affirmed the trial court’s judgment, finding no error in the voir dire process and concluding that Smith’s communications with the victims met the statutory requirements for unlawful contact.On further appeal, the Supreme Court of Pennsylvania reviewed two issues: whether the trial court abused its discretion in refusing to ask the proposed voir dire question about bias toward child victim testimony, and whether the Superior Court had impermissibly expanded the scope of criminal liability under the unlawful contact statute. The Supreme Court held that, on the record presented, the trial court did not abuse its discretion in refusing the voir dire question. Regarding the unlawful contact conviction, the Supreme Court vacated the Superior Court’s judgment and remanded for reconsideration in light of its recent decision in Commonwealth v. Strunk, which clarified the scope of the relevant statute. View "Commonwealth v. Smith" on Justia Law

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 the minor child. The Agreement included a release of liability and an arbitration provision requiring all claims to be resolved by arbitration, waiving the right to a jury trial. After the injuries, lawsuits were filed by both the injured minors’ non-signing parents and the minors themselves, seeking damages for the injuries sustained.The Court of Common Pleas of Philadelphia County reviewed the cases and denied Sky Zone’s petitions to compel arbitration. The trial courts found that the Agreements were enforceable only against the signing parent, not the non-signing parent or the minor child. The courts reasoned that there was no evidence of agency between spouses that would allow one parent to bind the other, and 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. The Superior Court of Pennsylvania affirmed these rulings, emphasizing that agency cannot be inferred from marriage alone and that parents, as natural guardians, lack authority over a minor’s property interests, including legal claims, without court approval.The Supreme Court of Pennsylvania reviewed the consolidated appeals. It held that the arbitration agreement signed by one parent is not enforceable against the non-signing parent or the minor child. The Court found that a marital relationship alone does not create an agency relationship, and there was no evidence of express, implied, apparent, or estoppel-based agency. Additionally, the Court held that parents, as natural guardians, lack inherent authority to bind their minor children to arbitration agreements that forfeit the right to a judicial forum and the procedural protections afforded to minors in court. The orders of the Superior Court were affirmed. View "Santiago v. Philly Trampoline Park" on Justia Law

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