Justia Pennsylvania Supreme Court Opinion Summaries

In March 2016, Appellant Jose Vellon was arrested for DUI of alcohol pursuant to Subsection 3802(a)(1) of the Pennsylvania Vehicle Code, 75 Pa.C.S. § 3802(a)(1) (general impairment). A violation of this statute constituted an “ungraded misdemeanor.” Vellon was accepted into the Accelerated Rehabilitation Disposition (“ARD”) Program. Several months later, police charged Vellon with another DUI. As a result of the Second DUI, the trial court entered an order removing Vellon from ARD. Vellon pleaded guilty to the First and Second DUIs, and in October 2017, he was sentenced on both DUI violations. Appellee Commonwealth of Pennsylvania, Department of Transportation, Bureau of Driver Licensing (“PennDOT”) informed Vellon that it would be suspending his driving privileges as a collateral consequence of his DUI convictions pursuant to Section 3804 of the Vehicle Code. Vellon appealed only his license suspension for the First DUI. In this appeal, the Pennsylvania Supreme Court was asked whether the Commonwealth Court erred in concluding that, in drafting Section 3806, the General Assembly intended to mandate that, when a defendant is sentenced for two driving-under- the-influence (“DUI”) offenses on the same day, both offenses had be considered prior offenses to each other with each warranting civil recidivist collateral consequences, despite the facts that the defendant committed the DUI violations at different points in time and had never previously been convicted of DUI. To this, the Supreme Court disagreed with the Commonwealth Court and reversed that court’s order. View "Vellon v. Dept of Transportation" on Justia Law

The Pennsylvania Secretary of the Commonwealth decertified certain voting equipment that Fulton County acquired from Dominion Voting Systems, Inc. (“Dominion”) in 2019 and used in the 2020 general election. The Secretary decertified the voting equipment after learning that, following the 2020 election, Fulton County had allowed Wake Technology Services, Inc. (“Wake TSI”), to perform a probing inspection of that equipment as well as the software and data contained therein. The Secretary maintained that Wake TSI’s inspection had compromised the integrity of the equipment. Fulton County and the other named Petitioner-Appellees petitioned in the Commonwealth Court’s original jurisdiction to challenge the Secretary’s decertification authority generally and as applied in this case. During the pleading stage, the Secretary learned that Fulton County intended to allow another entity, Envoy Sage, LLC, to inspect the allegedly compromised equipment. The Secretary sought a protective order from the Commonwealth Court barring that inspection and any other third-party inspection during the litigation. The court denied relief. The Secretary appealed that ruling to the Pennsylvania Supreme Court, which entered a temporary order on January 27, 2022, to prevent the inspection and to preserve the status quo during the Court's review of the Secretary’s appeal. Months later—and with no public consideration, official proceedings, or notice to the courts or other parties to this litigation—the County allowed yet another party, Speckin Forensics, LLC to inspect the voting equipment and electronic evidence at issue in this litigation. Upon learning of this alleged violation of the temporary order, the Secretary filed an “Application for an Order Holding [the County] in Contempt and Imposing Sanctions.” The Supreme Court found Fulton County willfully violated the Supreme Court's order. The Court found Fulton County and its various attorneys engaged in a "sustained, deliberate pattern of dilatory, obdurate, and vexatious conduct and have acted in bad faith throughout these sanction proceedings." Taken as a whole, that behavior prompted the Court to sanction both the County and the County Attorney. View "County of Fulton, et al. v. Sec. of Com." on Justia Law

Appellants Robert and Kelly Franks sought automobile insurance from Appellee, State Farm Mutual Automobile Insurance Company in 2013 for their two vehicles. Appellants included underinsured motorist coverage (“UIM”) in their policy but completed a form rejecting stacked UIM coverage in compliance with Section 1738(d)(2) of the Motor Vehicle Financial Responsibility Law (“MVFRL”). Absent such waiver, stacked coverage would be the default. Appellants removed one of the original vehicles and added a third vehicle to the policy effective 2014, and again rejected stacked UIM coverage. They made another change to the policy in 2015, removing the other of the original insured vehicles with a different car. No additional form rejecting stacked UIM coverage was offered or sought to be completed on the occasion of the removal of the last vehicle, and the ongoing premiums paid by Appellants reflected the lower rate for non-stacked UIM overage on two vehicles. Robert was injured in an accident caused by the negligence of a third party. That party had insufficient liability coverage to cover Robert's injuries. Appellants initiated a claim for UIM benefits under their policy with State Farm, but the parties disagreed on the limit to their benefits. Appellants contended with the last change to the policy, there was no valid waiver of stacked UIM coverage, resulting in a default stacked coverage mandated by statute. The issue presented for the Pennsylvania Supreme Court's review in this matter was whether the Superior Court erred as a matter of law by holding that removal of a vehicle from a multiple motor vehicle insurance policy, in which stacked coverage had previously been waived, did not require a renewed express waiver of stacked coverage pursuant to Section 1738(c). The Supreme Court concluded the Superior Court did not err and affirmed its judgment. View "Franks, et al. v. State Farm Mutual" on Justia Law

In Commonwealth v. Eid, 249 A.3d 1030 (Pa. 2021), the Pennsylvania Supreme Court found Section 1543(b)(1.1)(i) of the Vehicle Code unconstitutionally vague in contravention of state and federal due process principles because it failed to specify a maximum term of imprisonment. The Court granted allowance of appeal in this case to determine whether another subsection of that same statute, Section 1543(b)(1)(iii), was unconstitutional for similarly failing to specify a maximum term of imprisonment. The Court declined to find this provision unconstitutional and therefore affirmed the Superior Court’s order. View "Pennsylvania v. Rollins" on Justia Law

This appeal concerned whether Dr. Timothy Shrom and Debra Shrom were eligible under the Pennsylvania Storage Tank and Spill Prevention Act (Act) for payment from the Underground Storage Tank Indemnification Fund (Fund) for costs they incurred in remediating contamination caused by fuel releases from underground storage tanks (USTs or tanks) located on their property. The Fund concluded, and the Underground Storage Tank Indemnification Board (Board) ultimately agreed, that the Shroms were ineligible for such payment because the subject USTs were not registered with the Pennsylvania Department of Environmental Protection (DEP) as required by Section 503 of the Act and the registration fees were not paid at the time of the fuel releases that gave rise to the Shroms’ claim for remediation costs. The Commonwealth Court reversed the Board’s decision on appeal, concluding that: (1) the Shroms were eligible to receive payment from the Fund for remediation costs under the Act; (2) the Board’s holding relative to the timing of the payment of the Section 503 registration fees constituted an unlawful de facto regulation; and (3) contrary to the Board’s finding, payment of the Shroms’ claim did not appear to pose any imminent risk to the Fund’s solvency. Finding no error in the Commonwealth Court’s decision, the Pennsylvania Supreme Court affirmed. View "Shrom, et al v PA Underground Storage Tank" on Justia Law

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