Justia Pennsylvania Supreme Court Opinion Summaries

The Pennsylvania Environmental Defense Foundation (“PEDF”) challenged amendments the Pennsylvania General Assembly made to the state Fiscal Code that diverted to the General Fund revenues generated from oil and gas leases on state forest and game lands. PEDF claimed the legislation was unconstitutional, violating the Environmental Rights Amendment (the “ERA”). When this case returned to the Commonwealth Court, the Pennsylvania Supreme Court held that the ERA created a constitutional public trust subject to private trust principles. Applying trust law, the Supreme Court determined that royalty revenue streams generated by the sale of gas extracted from Commonwealth lands represented the sale of trust assets and had to be returned to the corpus of the trust. To the extent that 72 P.S. sections 1602-E and 1603-E diverted royalties to the General Fund, the Court found the provisions violated the ERA. The Court lacked sufficient advocacy to determine if the remaining three revenue streams, consisting of large upfront bonus payments, yearly rental fees, and interest penalties for late payments that were allocated to the General Fund under Sections 1604-E and 1605-E, as well as Section 1912 of the Supplemental General Appropriations Act of 2009, also constituted the sale of trust assets. Thus the case was remanded to the Commonwealth Court for further proceedings. On remand, the Commonwealth Court, sitting en banc, determined that the three revenue streams did not constitute the sale of trust assets. On return to the Supreme Court, it was determined the Commonwealth Court's holding was at odds with the Supreme Court's holding before remand. Another remand was unnecessary; the Supreme Court determined the record was sufficiently developed, and based upon that record it held the incomes generated under these oil and gas leases had to be returned to the corpus. As a result, the decision of the Commonwealth Court was reversed. View "PA. Environ. Defense Fd. v. Pennsylvania" on Justia Law

The primary issue raised in this discretionary appeal was whether the trial court properly excluded evidence that two of Appellant Eric Rogers’ rape victims had a history of prostitution convictions, where Appellant’s defense included a contention that the encounters were consensual instances of prostitution. The Pennsylvania Supreme Court affirmed the superior court’s ruling insofar as it upheld the common pleas court’s denial of Appellant’s motion in limine, thereby excluding from trial any evidence concerning the alleged prostitution convictions of A.P. and M.H. The intermediate court’s order was vacated, however, to the extent it found Appellant’s weight-of-the-evidence claim waived, and the matter was remanded for a merits disposition of that claim. View "Pennsylvania v. Rogers" on Justia Law

In 2018, B.W. went to his primary car provider’s office for “anxiety” and “agitation.” The provider’s notes reflect B.W. discussed making “credible threats of violence against a co-worker.” The provider recommended inpatient treatment, “involuntary if necessary.” B.W. made no threats to the provider’s staff. The provider certified B.W. needed involuntary examination and treatment, and B.W. was transported to another hospital for such examination. The hospital evaluator noted B.W. was “homicidal toward a co-worker,” and was “severely mentally disabled and in need of treatment.” B.W. was involuntarily committed and released after 72 hours. Thereafter, B.W. petitioned to expunge his mental health record, averring there was no basis for the involuntary commitment. A trial court found it undisputed B.W. made threats to harm his co-worker. Though he made no “act in furtherance” of his threats, the court concluded the medical evaluators’ records reflecting B.W.’s statement he would “strangle his co-worker the next time he saw” that person, was sufficient to support B.W. was a clear and present danger to others. The Pennsylvania Supreme Court considered whether the superior court erred in ordering the expungement of B.W.’s records on grounds that the trial court’s conclusion was wrong. The Supreme Court determined the records contained sufficient facts to prove B.W. made a threat to harm another person, and acted in furtherance of that threat, which the physicians found credible. Accordingly, judgment was reversed. View "In Re: B. W., Appeal of: Blair Dept Human Services" on Justia Law

In 2017, United States Marshalls went to the home of appellant Eric Yale’s mother (where Yale resided) to serve an arrest warrant on Larry Thompson. Officer Jeffrey Ference of the Wilkes-Barre Police Department assisted the Marshalls in serving the warrant. While searching the residence for Thompson, Officer Ference entered Yale’s bedroom, where he found Yale, soda bottles containing methamphetamine, and materials commonly used to produce methamphetamine, including lighter fluid, Drano, lithium batteries, and soda bottles with tubes coming out of them. Officer Ference found Thompson hiding in the closet in Yale’s bedroom. He took both Thompson and Yale into custody. After being read his Miranda rights, Yale admitted that the materials found in his bedroom were for the manufacture of methamphetamine. The Commonwealth alleged that Yale and Thompson were liable under both principal and accomplice theories of liability. Yale proceeded to a jury trial, and attempted to prove Thompson was solely responsible for the contraband found in Yale's bedroom. In support of this defense, Yale sought to introduce evidence of Thompson’s previous arrests for methamphetamine-related offenses. The Pennsylvania Supreme Court granted discretionary review to clarify the appropriate standard for the admission of evidence of a third person’s crimes, wrongs or other acts (“third person guilt”) offered by a criminal defendant in an effort to raise a reasonable doubt that he was not the perpetrator of the crime charged. The Superior Court applied the standard of admissibility typically associated with the Commonwealth’s introduction of crimes, wrongs or other acts evidence against a criminal defendant pursuant to Pennsylvania Rule of Evidence (“Pa.R.E.”) 404(b). The Supreme Court held that evidence of a third person’s guilt offered by a defendant is admissible if it is relevant pursuant to Pa.R.E. 4012 and not otherwise excludable pursuant to Pa.R.E. 403. Thus, the Supreme Court vacated the Superior Court order and remanded for further proceedings. View "Pennsylvania v. Yale" on Justia Law

Appellants William "Billy" King, and Melanie (Frantz) King ("the Kings"), hired appellee Terra Firma Builders, LLC ("TF") to perform construction work in the backyard of their home. In December 2012, TF was removed from the project before completion due to a dispute about the work performed up to that point. In 2013, TF filed two lawsuits for breach of contract and unjust enrichment, a mechanics’ lien claim for alleged unpaid labor and materials. TF effectuated service of the mechanics’ lien on the Kings by sheriff, however a month later, TF withdrew the lien and filed a new one for the same amount of the discontinued lien; this lien was assigned a new docket number. TF did not file the required affidavit of service for this lien claim. The Kings answered the suit with their own counterclaim alleging breach of contract; they did not challenge TF’s failure to file an affidavit of service at this time. In 2015, TF sought to enforce and obtain judgment on its lien. The Kings did not file preliminary objections or otherwise raise TF’s failure to file an affidavit of service at this time. In 2017, the trial court consolidated TF’s mechanics’ lien and breach of contract actions and proceeded to a bench trial. The parties agreed that TF failed to complete the project but disputed the amount of work remaining unfinished and the quality of the work completed. The court ultimately found in favor of the Kings on all claims, including the Kings’ counterclaim, and awarded the Kings monetary damages. TF moved for a new trial, which was ultimately granted. At the conclusion of the second trial, the court again found in favor of the Kings on the merits, but did not award damages. In 2018, while the post-trial motions were pending, the Kings moved to strike the mechanics’ lien because TF’ failed to file an affidavit of service to perfect the lien. TF argued the Kings had waived their right to object to the lien when they accepted service of the complaint to enforce, never filed preliminary objections, and appeared in court to defend the action. The trial court granted the petition to strike. On appeal, a divided three-judge panel of the Superior Court reversed. The Pennsylvania Supreme Court reversed, finding the lien remained unperfected and invalid, "and the applicable statutes quite logically do not specify a time limit for objection to such a thing." View "Terra Firma Builders, LLC v. King, et al.." on Justia Law

In this case, jurors could not reach a unanimous verdict on some counts, and the trial court sua sponte declared a mistrial. Defendant Joshua Wardlaw objected to the mistrial, and sought a judgment of acquittal on the unresolved charges. The trial court denied Wardlaw’s motion. Wardlaw filed an interlocutory appeal to the Superior Court, claiming a right to do so pursuant to Pennsylvania Rule of Appellate Procedure 311(a)(6). The Superior Court quashed the appeal, holding that Rule 311(a)(6) did not apply because the trial court’s declaration of a mistrial was not an “award” of a new trial. The Pennsylvania Supreme Court granted Wardlaw’s request for discretionary review to consider whether the Superior Court’s interpretation of Rule 311(a)(6) was erroneous. The Pennsylvania Supreme Court found that Wardlaw did not appeal an order awarding a new trial, and the Superior Court correctly determined that Wardlaw was not entitled to an interlocutory appeal under Pennsylvania Rule of Appellate Procedure 311(a)(6). "One cannot award that which is not sought. Consequently, a new trial is awarded only when the court grants a party’s motion for a new trial. When the new trial flows from the declaration of a mistrial, the court has not awarded a new trial." The Superior Court’s order quashing the appeal was affirmed. View "Pennsylvania v. Wardlaw" on Justia Law

In January 2010, Appellant James Finnecy was sentenced to a maximum term of two years’ imprisonment for unauthorized use of a motor vehicle and theft by unlawful taking, as well as two consecutive terms of eighteen months’ probation for escape, resisting arrest, identity theft, and ten counts of forgery. In October 2011, Appellant was released from custody and placed on probation. He committed multiple probation violations over the next several months and also failed to complete a court supervised drug treatment program. The trial court ultimately revoked Appellant’s probation. In 2014, Appellant was sentenced to twelve to twenty-four months’ imprisonment, to be followed by five years’ probation. Appellant was again released from custody and paroled to a court supervised substance abuse treatment facility. Shortly thereafter, Appellant absconded from parole and committed numerous additional violations of his supervision. As a result, the Commonwealth filed a petition to revoke Appellant’s probation and parole, which was granted. Appellant was sentenced to an aggregate term of twelve and one-half to twenty-five years’ imprisonment. Relevant here, the court found Appellant ineligible for a sentence under the Pennsylvania Recidivism Risk Reduction Act (“RRRI Act”). The issue Appellant's case presented for the Pennsylvania Supreme Court's review centered on whether a single past conviction for violent crime demonstrated “history of present or past violent behavior” for purposes of the RRRI Act, thereby disqualifying an offender from eligibility for a reduced sentence. Before addressing this question, the Court first had to determine whether a trial court’s failure to impose a sentence under the RRRI Act implicated sentencing illegality. The Supreme Court held the trial court’s failure to sentence an eligible offender pursuant to the RRRI Act implicated sentencing illegality. The Court also found that a single prior conviction for a non-enumerated crime demonstrating violent behavior did not qualify as a history of past violent behavior under the Section 4503 of the RRRI Act. Accordingly, the Superior Court judgment was reversed in part and affirmed in part, and the case remanded for further proceedings. View "Pennsylvania v. Finnecy" on Justia Law

Eleanor McLaughlin acquired all oil, gas, and mineral rights underlying two parcels in Watson Township, Warren County, Pennsylvania. In 1985, she leased the oil and gas rights for each parcel to United Land Services. United Land Services in turn assigned the leases to Appellant Mitch-Well Energy, Inc. In 2008, Jack and Zureya McLaughlin sold their interest in the Warrant 3010 to Sheffield Land and Timber Company, which merged into Appellee SLT Holdings, LLC in 2012. During the initial term of the leases, Mitch-Well drilled one well on each lease parcel and produced oil in paying quantities until 1996. Mitch-Well did not drill any additional wells. After 1996, no oil was produced or royalty payments, or delay rental payments made or tendered until 2013. Nor did Mitch-Well tender any minimum payments during that period under either lease. The Pennsylvania Supreme Court granted review to consider the propriety of the Superior Court’s affirmance of the trial court’s grant of partial summary judgment in favor of Appellees in their complaint in equity against Appellant on the grounds of abandonment. Because Appellees had available to them a full and adequate remedy at law, through contract principles generally applicable to oil and gas leases, and through the specific provisions of the subject leases, the Supreme Court concluded it was error to provide recourse through application of the equitable doctrine of abandonment. View "SLT Holdings v. Mitch-Well Energy" on Justia Law

Pittsburgh Logistics Systems, Inc. (“PLS”) was a third-party logistics provider that arranged the shipping of its customers’ freight with selected trucking companies. Beemac Trucking (“Beemac”) was a shipping company that conducted non-exclusive business with PLS. In 2010, PLS and Beemac entered into a one-year Motor Carriage Services Contract (“the Contract”), which automatically renewed on a year to year basis until either party terminated it. The Contract contained both a non-solicitation provision and the no-hire provision. In this appeal, the Pennsylvania Supreme Court considered whether no-hire, or “no poach,” provisions that were ancillary to a services contract between business entities, were enforceable under the laws of the Commonwealth. While the Contract was in force, Beemac hired four PLS employees. PLS sued Beemac, alleging breach of contract, tortious interference with contract, and a violation of the Pennsylvania Uniform Trade Secrets Act. PLS also sued the four former employees, alleging they had breached the non-competition and non-solicitation provisions of their employment contracts. The trial court held the worldwide non-compete clauses in the employees' contracts were “unduly oppressive and cannot be subject to equitable modification.” With respect to the contract between the companies, the trial court held the pertinent no-poach clause was void against public policy. “If additional restrictions to the agreement between employer and employee are rendered unenforceable by a lack of additional consideration, PLS should not be entitled to circumvent that outcome through an agreement with a third party.” Finding no reversible error in the trial court's judgments, the Supreme Court affirmed. View "Pgh. Logistics Systems, Inc. v. Beemac Trucking, et al." on Justia Law

The issue presented for the Pennsylvania Supreme Court's review required the Court to revisit its relatively recent holding that the signature of a registered voter “may not be stricken from a nominating petition solely because the address set forth on the nominating petition is different from the address at which the signer is currently registered to vote.” Following the Court's unanimous decision in In re Vodvarka, 140 A.3d 639 (Pa. 2016), the General Assembly in October of 2019 enacted Act 77, which made significant changes to Pennsylvania’s Election Code, such as the advent of no-excuse mail-in voting. One lesser-known change effected by Act 77 was the amendment of 25 P.S. section 2868, which required a signer of a nominating petition to add certain information. Significantly, only one change was made to the statute by the amendment: the former requirement that a signer add his “residence” was replaced with a new requirement that he add the “address where he is duly registered and enrolled.” After careful review, the Supreme Court concluded this legislative change in statutory text displaced the Court's holding in Vodvarka pertaining to the address requirement. Furthermore, the Court concluded the statute as amended, plainly and unambiguously imposed a mandatory duty on a signer of a nominating petition to add the address where he or she was duly registered and enrolled, and that the failure to comply with this requirement exposes the signature to viable legal challenge. As the Commonwealth Court reached this same conclusion below, the Supreme Court affirmed. View "In Re: Nom. s. of Major, R." on Justia Law