Justia Pennsylvania Supreme Court Opinion Summaries

In this case of first impression, the Pennsylvania Supreme Court granted allocatur to determine whether Jack Satterfield raised a meritorious challenge to the legality of the sentences imposed on three counts of leaving the scene of an accident involving death or personal injury, stemming from a multi-vehicle crash that resulted in three fatalities. The Supreme Court concluded two of Satterfield’s three sentences were illegal. Accordingly, the Court reversed the order of the Superior Court, vacated the judgment of sentence, and remanded for resentencing. View "Pennsylvania v. Satterfield" on Justia Law

The Sixth Circuit Court of Appeals certified two questions to the Pennsylvania Supreme Court: (1) whether time spent on an employer’s premises waiting to undergo, and undergoing, mandatory security screening is compensable as “hours worked” within the meaning of the Pennsylvania Minimum Wage Act1 (“PMWA”); and (2) whether the doctrine of de minimis non curat lex, as described in Anderson v. Mt. Clemens Pottery Co., 328 U.S. 680 (1946), applied to bar claims brought under the PMWA. This case arose out of a class action suit for unpaid wages brought by Appellants Neil Heimbach and Karen Salasky (“Employees”) who worked for Appellees (collectively “Amazon”) at Amazon’s warehouse facility in Pennsylvania. The Supreme Court replied: (1) time spent on an employer’s premises waiting to undergo, and undergoing, mandatory security screening constituted “hours worked” under the PMWA; and (2) there exists no de minimis exception to the PMWA. View "Heimbach, et al. v. Amazon.com, et al." on Justia Law

The Pennsylvania Supreme Court granted discretionary review in this case to determine whether the superior court properly determined language in the 2010 amendment to the corruption of minors statute, "in violation of Chapter 31," was an essential element of an offense under the statute. Upon review, the Supreme Court agreed with the superior court's assessment. And, because appellee James Baker-Myers was acquitted of all Chapter 31 sexual offenses charged in the indictment and submitted to the jury, the Supreme Court further agreed that, under these circumstances, appellee's conviction for third-degree felony corruption of minors, could not stand. View "Pennsylvania v. Baker-Myers" on Justia Law

Appellant, the City of Johnstown ("Johnstown"), contended that a party asserting a firefighter cancer claim had to satisfy the requirements of both Section 301(c)(2) and Section 301(f) of the Pennsylvania Workers' Compensation Act to establish a viable claim. Michael Sevanick was a firefighter for Johnstown for twenty-nine years. After retirement, he worked a a car dealership. Nine years after he retired, Sevanick was diagnosed with kidney cancer. In 2016, he filed a claim for workers' compensation benefits, alleging that his cancer was caused by exposure to a carcinogen recognized as a Group 1 carcinogen by IARC during his time as a firefighter. The Workers' Compensation Judge found in Sevanick's favor, and Johnstown appealed. The Workers' Compensation Appeals Board found that Section 301(c)(2) did not apply, but rather that the limitations of Sevanick's claim were governed by Section 301(f). The Board reasoned that Section 301(f) created a new timeframe for cancer-related occupational disease claims made by firefighters. Because Sevanick raised his claim well within 600 weeks from his last date of employment as a firefighter, the Board concluded the claim was timely. The Commonwealth Court agreed with that determination. Johnstown petitioned for Allowance of Appeal for the Pennsylvania Supreme Court to determine whether a firefighter making a claim under Section 108(r) of the Act had to comply with the timing requirements of Section 301(c)(2). The Supreme Court concluded that the time for filing a Section 108(r) firefighter cancer claim was governed by Section 301(f) alone. Therefore, the Commonwealth Court's ruling was affirmed. View "City of Johnstown v. WCAB (Sevanick)" on Justia Law

The issue this case presented for the Pennsylvania Supreme Court's review centered on the proper application of the statute of limitations to a tort action filed by Renee’ Rice against the Diocese of Altoona-Johnstown and its bishops (collectively, the “Diocese”) for their alleged role in covering up and facilitating a series of alleged sexual assaults committed by the Reverend Charles Bodziak. Rice alleged that Bodziak sexually abused her from approximately 1974 through 1981. She did not file suit against Bodziak or the Diocese until June 2016, thirty-five years after the alleged abuse stopped. The Supreme Court concluded that a straightforward application of Pennsylvania’s statute of limitations required that Rice’s complaint be dismissed as untimely. View "Rice v. Diocese of Altoona-Johnstown" on Justia Law

In consolidated cases, the Commonwealth Court reversed determinations of the Pennsylvania Public Utility Commission (“PUC”), holding that Section 1301.1(a) required public utilities to revise their DSIC calculations to include income tax deductions and credits to reduce rates charged to consumers. Several public utilities sought to add or adjust DSICs to recover expenses related to repairing, improving, or replacing their distribution system infrastructure, and the Office of Consumer Advocate (“OCA”), through Acting Consumer Advocate Tanya McCloskey, raised challenges to these DSIC computations seeking to add calculations to account for income tax deductions and credits and thereby reduce the rates charged to consumers. The parties disputed whether and, if so, how the addition of Section 1301.1(a) into Subchapter A of Chapter 13 of the Code, requiring inclusion of “income tax deductions and credits” in rate calculations, should apply to the DSIC rate adjustment mechanism of Subchapter B of Chapter 13, 66 Pa.C.S. sections 1350- 1360. Broadly, the PUC and the public utilities argued: (1) ambiguity existed as to whether the General Assembly intended Section 1301.1 to apply to the DSIC mechanism; and, assuming for argument that it did apply; (2) that the Commonwealth Court’s application of Section 1301.1(a) improperly created conflicts with the statutory provisions governing the DSIC calculation; and/or (3) that certain existing DSIC statutory provisions could be read to satisfy the requirements of Section 1301.1(a). Though the Pennsylvania Supreme Court differed in its reasoning, it affirmed the outcome of the Commonwealth Court's judgment. View "McCloskey v. PUC" on Justia Law

U.S. Venture, Inc. (“Venture”) appealed a Commonwealth Court decision affirming the determination of the Pennsylvania Board of Claims (“Board”) that its dispute with the Commonwealth involving two grant agreements was not within the subject matter jurisdiction of the Board and that its claim was barred by sovereign immunity. The Pennsylvania Supreme Court found that any ambiguity within the relevant statutory provisions had to be resolved in favor of preserving sovereign immunity. Alternatively, the Court found these written grant agreements were in fact “grants,” which were not subject to the limited waiver of sovereign immunity. View "U.S. Venture Inc. v. Dep of Comm & Econo Dev" on Justia Law

In May 2017, a PennLive reporter, PennLive, and the Patriot-News (collectively, “Appellees”) requested disclosure of all of the medical marijuana business permit applications in Pennsylvania pursuant to the Right- to-Know Law (“RTKL”). The Medical Marijuana Act, as well as the Department of Health’s temporary regulations, explicitly provided that permit applications were public records subject to disclosure under the RTKL. The applications for the issuance of permits required extensive information pertaining to various facets of the applicant’s intended business, including, inter alia, financial and operational capabilities; community impact plans; site and facility plans; the verification of an applicant’s principals, operators, financial backers, and employees; a description of the business activities in which the applicant intended to engage; and a statement that the applicant was able to maintain effective security and prevent diversion or other illegal conduct related to their medical marijuana business. The Department denied Appellees’ RTKL request, in part, referring Appellees to redacted copies of applications posted on its website. Access to the certain other applications, which had not yet been posted, were denied. The Department did not independently review the applicants’ redactions, but accepted all applicants’ redactions that applicants deemed confidential or proprietary, or otherwise subject to redaction under the RTKL. This resulted in a disparity in redactions across the various applications. Appellees appealed to the Office of Open Records, claiming the Department lacked a legal basis for its redactions. The Department and Applicants filed petitions for review with the Commonwealth Court, asserting various claims of error with respect to the OOR’s ultimate application of the exemptions under the RTKL to their respective applications. The Pennsylvania Supreme Court affirmed the Commonwealth Court in two aspects: (1) rejecting the Department’s request to be relieved of its obligations to review all requests and determine what parts of a record are subject to disclosure and what parts are subject to redaction; and (2) rejecting Applicant Harvest’s contention that, its entire application should be deemed to be exempt from disclosure. The Court vacated parts of the Commonwealth Court's decision regarding Applicant Terrapin's claim its application was exempt from disclosure. The matter was remanded the Commonwealth Court for reconsideration of Terrapin's arguments for exemption. View "PennLive v. Dept of Health, Aplt." on Justia Law

The Pennsylvania Supreme Court granted discretionary review of a Superior Court’s decision to invalidate the involuntary termination of a father’s parental rights. The child’s mother voluntarily relinquished her own rights, but continued to reside with the pre-adoptive maternal grandparents and maintain her parental role. The panel viewed the matter to involve unlawful custody gamesmanship in conflict with the Supreme Court's decision in In re Adoption of M.R.D., 145 A.3d 1117 (Pa. 2016). Although the Supreme Court found no direct conflict between the proposed adoption and M.R.D., and disapproved of the Superior Court’s holding to the contrary, the Supreme Court affirmed the panel’s disposition on the alternative grounds. View "Adoption of C.M." on Justia Law

In 2007, Ryan Mortimer was seriously and permanently injured when an intoxicated driver collided with her car. The driver recently had been served by employees of the Famous Mexican Restaurant (“the Restaurant”) in Coatesville, Pennsylvania. The owners of the Restaurant had a contractual management agreement with the owner of the Restaurant’s liquor license (“the License”), Appellee 340 Associates, LLC. The Restaurant was located in a large, mixed-use building owned by Appellee McCool Properties, LLC. At the time of the injury, Appellees Michael Andrew McCool (“Andy”) and Raymond Christian McCool (“Chris”) were the sole owners of 340 Associates. With their father, Raymond McCool (“Raymond”), they also owned McCool Properties. In an underlying “dram shop action,” Mortimer obtained a combined judgment of $6.8 million against 340 Associates and numerous other defendants. Under the Liquor Code, 340 Associates as licensee was jointly and severally liable for Mortimer’s entire judgment. 340 Associates had no significant assets beyond the License itself, and neither carried insurance for such actions nor was required by law to do so. Seeking to collect the balance of the judgment, Mortimer filed suit against 340 Associates, McCool Properties, Chris, Andy, and the Estate of Raymond (who died after the collision but before this lawsuit). Mortimer sought to "pierce the corporate veil" to hold some or all of the individual McCool defendants and McCool Properties liable for her judgment. While the Pennsylvania Supreme Court concluded that a narrow form of “enterprise liability” might be available under certain circumstances, it could not apply under the facts of this case: "We believe that our restrained, equitable posture toward veil-piercing cases has enabled Pennsylvania courts to do substantial justice in most cases, and that there is no clear reason to preclude per se the application of enterprise liability in the narrow form described herein." View "Mortimer v. McCool, et al." on Justia Law