Justia Pennsylvania Supreme Court Opinion Summaries

The Supreme Court of Pennsylvania ruled in favor of the Ivy Hill Congregation of Jehovah’s Witnesses, finding that the Commonwealth Court violated the coordinate jurisdiction rule by dismissing the Congregation's petition against the Department of Human Services. According to the faith's tenets, congregation elders are obligated to maintain the confidentiality of confessions, which might include confessions of child abuse. The Pennsylvania Child Protective Services Law (“CPSL”) identifies certain individuals, including clergymen, as mandated reporters of child abuse. The Congregation filed a petition for review, asking for a declaration on whether their elders are entitled to the clergyman privilege, which would protect them from the mandatory reporting requirements of the CPSL. The Commonwealth Court dismissed the petition, reasoning that the Department of Human Services was not a proper defendant and that declaratory relief would not terminate the controversy. However, the Supreme Court of Pennsylvania held that this dismissal violated the coordinate jurisdiction rule as it directly contradicted the Commonwealth Court's prior determination on the same issues. The case was remanded for further proceedings. View "Ivy Hill Cong. of Jehovah Witnesses v. DHS" on Justia Law

The Supreme Court of Pennsylvania affirmed the decision of the Commonwealth Court confirming certain modifications to a recovery plan for the City of Chester under the Municipalities Financial Recovery Act, commonly known as Act 47. The case arose from the City of Chester's financial distress, which led to the appointment of a receiver. The receiver sought to modify the existing recovery plan due to the City’s challenges and the failure of local officials to cooperate with his efforts. The City objected to several initiatives in the modified plan, arguing they unlawfully deprived its elected officials of their authority to govern on behalf of the residents. The Supreme Court held that the modifications were necessary to achieve financial stability in the City and were not arbitrary, capricious, or wholly inadequate to alleviate the City's fiscal emergency. The court emphasized that the financial health of the municipality was paramount and that local officials must accept the measures necessary for recovery, whether they like it or not. View "Dept of Comm and Econ Dev v. City of Chester" on Justia Law

In a case concerning the Senior Health Insurance Company of Pennsylvania ("SHIP"), the Supreme Court of Pennsylvania upheld a rehabilitation plan devised by the Pennsylvania Insurance Commissioner. SHIP, which sold long-term care policies in multiple states, became insolvent due to the high cost of care against inadequate premiums. The rehabilitation plan was designed to correct the company’s financial condition by adjusting the premiums and benefits of the existing policies. However, insurance regulators from Maine, Massachusetts, and Washington ("Regulators") objected to the plan, arguing that it exceeded the Insurance Commissioner's statutory authority and violated their states' regulatory authority over rates. The court rejected these claims, finding that the plan did not exhibit a "policy of hostility" to the public acts of other states and thus did not violate the Full Faith and Credit Clause of the U.S. Constitution. The court concluded that the Commonwealth Court, holding exclusive jurisdiction over the distribution of SHIP's assets, did not abuse its discretion by approving the plan. View "In Re: Senior Health Ins. Co. of PA" on Justia Law

The Supreme Court of Pennsylvania considered whether a violation of a juvenile defendant's Fifth Amendment right is subject to appellate review for harmless error. The case involved Nazeer Taylor, who was charged with several serious felony offenses as a juvenile. The juvenile court transferred Taylor's case to adult criminal court, considering Taylor's refusal to admit guilt for his alleged offenses as a factor in its decision. The Supreme Court of Pennsylvania previously held that such consideration violated Taylor's Fifth Amendment right. In this appeal, the Supreme Court concluded that the violation constituted a structural error, not subject to a harmless error review. Given Taylor's current age of 27, neither the juvenile nor the adult criminal court had the statutory authority to conduct a new certification hearing. Consequently, the Supreme Court affirmed the order of the Superior Court reversing Taylor's conviction and discharging him. View "Commonwealth v. Taylor" on Justia Law

The Supreme Court of Pennsylvania ruled that a "regular use" exclusion in a motor vehicle insurance policy does not violate the Motor Vehicle Financial Responsibility Law (MVFRL), thereby reversing the order of the Superior Court. The case involved Matthew Rush, a detective, who was injured in a motor vehicle accident while driving a city-owned car insured under the city's policy. Rush had his personal vehicles insured with Erie Insurance. When Rush's injuries exceeded the liability insurance limits of the other drivers involved in the accident and the underinsured motorist (UIM) coverage limits of the city's policy, he filed a claim for UIM benefits under his Erie policies. Erie denied coverage based on the "regular use" exclusion in the Erie Policies. The Supreme Court of Pennsylvania held that the "regular use" exclusion was valid and enforceable, and did not violate the MVFRL. The court reasoned that UIM coverage was not universally portable and could, therefore, be subject to policy exclusions. View "Rush v. Erie Insurance Exchange" on Justia Law

In the case at hand, a group of reproductive health centers and Planned Parenthood affiliates in Pennsylvania challenged the constitutionality of sections of the Pennsylvania Abortion Control Act and corresponding regulations which prohibit the use of state Medicaid funds for abortions except in cases of rape, incest, or to avert the death of the mother. The petitioners argued that the exclusion of abortion from Medicaid coverage violated the Equal Rights Amendment and equal protection provisions of the Pennsylvania Constitution.The Supreme Court of Pennsylvania held that the health centers had standing to bring the lawsuit on behalf of their patients who are enrolled in or eligible for aid under Pennsylvania's Medical Assistance program but whose abortions are not covered because of the exclusion. The court further held that the Commonwealth Court erred in permitting individual members of the Pennsylvania Senate and House of Representatives to intervene in the case.The Supreme Court of Pennsylvania reversed the Commonwealth Court's order dismissing the petition for review. The court concluded that the providers' petition for review was legally sufficient to survive demurrer. The court noted that its precedent may have misstated the breadth of the exclusion and remanded the case to the Commonwealth Court for further proceedings consistent with its opinion. The court did not rule on the constitutionality of the challenged provisions. View "Allegheny Reprod. Health v. PA DHS" on Justia Law

In this case, the Supreme Court of Pennsylvania was tasked with determining whether multiple periods of separation prior to filing a paternity action were enough to preclude the application of the presumption of paternity. The presumption of paternity is a legal doctrine which presumes that a child conceived or born during a marriage is a child of that marriage. The court held that a marital couple's separation prior to the filing of the paternity action does not, per se, preclude the application of the presumption of paternity.In this case, a woman (Mother) and her husband (Husband) were married and separated multiple times. During one of their separations, the woman had unprotected sexual intercourse with another man (B.C.). After the woman became pregnant and gave birth to a child, B.C. filed a paternity action. The woman and her husband, who had since reconciled, argued that the presumption of paternity should apply because they were married at the time of the child's conception and remained married at the time of the paternity action.The lower courts held that the presumption did not apply due to the couple's multiple separations. However, the Supreme Court of Pennsylvania reversed this decision, finding that although temporary separations are a factor to consider in determining whether a marriage is intact, they are not dispositive. The court concluded that the couple's marriage was intact at the time of the paternity action and the presumption of paternity applied, effectively dismissing B.C.’s paternity action. View "B.C. v. C.P. & D.B." on Justia Law

In the case before the Supreme Court of Pennsylvania, the appellant, Jeff Dobson, was a passenger in a vehicle that was stopped by police in a high crime area due to a minor traffic violation. The driver of the vehicle had a suspended license and the other passenger had an active arrest warrant. Dobson had no outstanding warrants and did not exhibit any suspicious behavior. However, the police officer, Officer Duncan, conducted a pat-down search of Dobson solely on the basis of the high crime area designation. During the search, Officer Duncan found a firearm and subsequently arrested Dobson.Dobson was charged with carrying a concealed firearm without a license, persons not to possess firearms, possession of a controlled substance, and possession of drug paraphernalia. Prior to trial, he filed a suppression motion challenging the constitutionality of the pat-down and the subsequent seizure of the gun and drugs. The trial court denied Dobson's suppression motion. Dobson was subsequently convicted on all charges and sentenced to an aggregate of six to fifteen years in prison.On appeal, the Superior Court affirmed the denial of Dobson’s suppression motion. The Supreme Court of Pennsylvania, however, held that the officer's justification for the frisk, being the high crime area designation, was insufficient to support reasonable suspicion that Dobson was armed and dangerous. The fact that Dobson was a passenger in a vehicle that was lawfully stopped in a high crime area for a minor traffic violation did not, by itself, establish reasonable suspicion. The court held that the evidence found should have been suppressed and the convictions vacated. The case was remanded for a new trial without the unconstitutionally obtained evidence. View "Commonwealth v. Dobson" on Justia Law

In a case brought before the Supreme Court of Pennsylvania, Michael and Melissa Sullivan sued Werner Company and Lowe's Companies, Inc. over a mobile scaffold that collapsed and caused serious injury to Michael Sullivan. The Sullivans claimed the scaffold was defectively designed because it was possible for a user to inadvertently rotate the deck pins off the platform during normal use.Before trial, the Sullivans filed a motion to preclude Werner and Lowe’s from admitting into evidence any industry or government standards, which the trial court granted. The jury ultimately found Werner and Lowe’s liable for the design defect and awarded the Sullivans $2.5 million in damages.Werner and Lowe's appealed, arguing that they should have been allowed to present evidence that the mobile scaffold complied with industry and governmental safety standards. The Supreme Court of Pennsylvania affirmed the lower courts' decisions, ruling that such compliance evidence remained inadmissible in products liability cases.The court applied the risk-utility test, which asserts that a product is in a defective condition if a ‘reasonable person’ would conclude that the probability and seriousness of harm caused by the product outweigh the burden or costs of taking precautions. The court concluded that evidence of a product’s compliance with governmental regulations or industry standards is inadmissible in design defect cases to show a product is not defective under the risk-utility theory because such evidence goes to the reasonableness of the manufacturer’s conduct in making its design choice, not to whether the product was defectively designed. View "Sullivan v. Werner Co." on Justia Law

The Supreme Court of Pennsylvania held that the Pennsylvania Department of Corrections (DOC) had violated the procedural due process rights of an inmate, Thomas Washington. The DOC had increased the rate at which it garnished Washington’s prison account to pay for his court-ordered financial obligations, without giving him prior notice or an opportunity to challenge this increase. The court rejected the DOC's argument that the increase was mandated by a legislative amendment and that no discretion was available for the DOC to alter the rate. The court held that the amendment to the law did not remove the obligation for the DOC to follow due process requirements before increasing the rate of deductions from inmates' accounts. The court reversed the lower court's decision, which had dismissed Washington's complaint, and remanded the case for further proceedings. The court noted that even if Washington was not ultimately entitled to a return of the additional funds, he had a right to make his case before the increased deductions occurred. View "Washington v. PA Dept. of Corrections" on Justia Law