Justia Pennsylvania Supreme Court Opinion Summaries

The Pennsylvania Supreme Court granted discretionary review to consider whether a notice of appeal filed at a single docket number corresponding to the lead case of multiple consolidated civil cases should have been quashed for failing to satisfy the requirements of Pa.R.A.P. 341(a) as interpreted in Commonwealth v. Walker, 185 A.3d 969 (Pa. 2018). The Superior Court relied on Walker to quash the appeal below at one docket number, but the Supreme Court held Walker was inapplicable to the particular facts of this case and therefore reversed. View "Always Busy Consulting v. Babford & Company" on Justia Law

In an appeal by allowance, the Pennsylvania Supreme Court considered whether the Commonwealth, by the Office of Attorney General (OAG), could bring claims under the Pennsylvania Unfair Trade Practices and Consumer Protection Law (UTPCPL) on behalf of private landowners against a natural gas exploration and production company for its alleged deceptive, misleading, and unfair practices in obtaining natural gas leases from the landowners. The Supreme Court concluded the OAG could not bring claims under the UTPCPL on behalf of private landowners against Anadarko Petroleum Corporation and Anadarko E&P Onshore, L.L.C. (Anadarko) for its alleged unfair and deceptive practices in acquiring natural gas leases from the landowners. Furthermore, the Court found its resolution of the first issue rendered the second issue moot. The Court affirmed the portion of the Commonwealth Court’s decision that reversed the trial court order overruling Anadarko’s preliminary objections to Count III of the OAG’s second amended complaint, and otherwise reversed the order of the Commonwealth Court. View "Com. v. Chesapeake Energy, et al (Anadarko, Aplt.)" on Justia Law

In 1999, Gary and Mary Gregg sought the expertise of Robert Kovalchik, a financial advisor and insurance salesperson for Ameriprise Financial, Inc. Engaging in what the trial court concluded was deceptive sales practices, Kovalchik made material misrepresentations to the Greggs to induce them to buy certain insurance policies. The Greggs ultimately sued Ameriprise Financial, Inc., Ameriprise Financial Services, Inc., Riversource Life Ins. Co., and Kovalchik (collectively, Ameriprise) under Pennsylvania’s Unfair Trade Practices and Consumer Protection Law (“CPL”). The Greggs’ complaint also asserted, inter alia, common law claims for negligent misrepresentation and fraudulent misrepresentation. The case proceeded to a jury trial on the common law claims, resulting in a defense verdict. The CPL claim proceeded to a bench trial. After the trial court ruled in favor of the Greggs on that CPL claim, Ameriprise filed a motion for post-trial relief arguing (among other points) that the Greggs failed to establish that Kovalchik’s misrepresentations were, at the very least, negligent, a finding that Ameriprise asserted was required to establish deceptive conduct under the CPL. The trial court denied relief, and the Superior Court affirmed. Like the trial court, the Superior Court concluded that the Greggs were not required to prevail on the common law claims of fraudulent misrepresentation or negligent misrepresentation in order to succeed on their CPL claim. The issue this case presented for the Pennsylvania Supreme Court's review centered on whether, as the Superior Court held, a strict liability standard applied to the Greggs’ CPL claim. The Court determined the relevant statutory provision lead it to conclude deceptive conduct under the CPL was not dependent in any respect upon proof of the actor’s state of mind. "The Superior Court’s holding is consistent not only with the plain language of the CPL, but also with our precedent holding that the CPL is a remedial statute that should be construed broadly in order to comport with the legislative will to eradicate unscrupulous business practices." View "Gregg v. Ameriprise Financial, et al." on Justia Law

Upon completion of an investigation of a report of child abuse, the Pennsylvania Department of Human Services (DHS) or its designated county children and youth agency (county agency) categorizes the investigated report as “indicated,” “founded,” or “unfounded.” When a report of child abuse was substantiated as either indicated or founded, or amended from indicated or founded, the named perpetrator is provided with notice of the status, including the effect of a substantiated report upon future employment opportunities involving children, and the individual’s name was added to the statewide child abuse database where it could remain indefinitely. On July 6, 2017, the county agency filed two identical indicated reports (CPS reports) identifying J.F. as a perpetrator of abuse of her fifteen-month-old twin children. While her administrative appeal of the CPS reports was pending, J.F. entered into an Accelerated Rehabilitative Disposition (ARD) for both criminal counts of endangering the welfare of children. As a result of J.F.’s entry into ARD, the county agency changed the status of the CPS reports from “indicated” to “founded,” then filed a motion to dismiss J.F.’s administrative appeal, attaching the criminal court docket, and averring the factual circumstances of the ARD were the same as the CPS reports which authorized the county agency to change the reports’ status to founded. The Pennsylvania Supreme Court granted discretionary review to determine whether J.F., seeking to challenge the founded report, was entitled an administrative hearing. The Court held that in the absence of another appropriate forum to challenge DHS’s adjudication of child abuse in a recorded evidentiary hearing, a named perpetrator in a report designated as “founded” based upon the perpetrator’s voluntary entry into an accelerated rehabilitative disposition was entitled to an administrative hearing. View "J.F. v. Department of Human Services" on Justia Law

In 2012, Appellee Carl Sadler was injured while working as a production manager for Philadelphia Coca-Cola Company (“PCCC”). PCCC issued a notice of compensation payable, acknowledging Sadler’s injuries as a right pinky finger amputation and a low back sprain, and providing that Sadler was entitled to a weekly disability rate of $652 based upon an average weekly wage of $978. On August 13, 2013, Sadler was charged with a crime in New Jersey. Because he could not post bail, Sadler remained incarcerated for 525 days, until January 22, 2015, when he pled guilty. At sentencing, immediately after accepting Sadler’s plea, the trial court sentenced him to 525 days of incarceration, gave him credit for time served, and immediately released him from custody. Months later, Sadler filed a petition seeking review of his average weekly wage. PCCC responded with a suspension petition, contending that Sadler was not entitled to retain the benefits he received while incarcerated and asking that his benefits be adjusted to prevent him from being unjustly enriched for the amounts received during that time. The petitions were heard by a workers’ compensation judge, who concluded that PCCC was entitled to reimbursement for benefits paid to Sadler during his pre-conviction incarceration. The judge did not provide for a future credit against benefits to be paid to Sadler, but rather ordered that PCCC should petition the Supersedeas Fund for reimbursement. PCCC appealed to the Workers’ Compensation Appeals Board, and Sadler cross-appealed. The Board modified the workers’ compensation judge’s decision by allowing PCCC to seek a credit against Sadler’s future payments, but affirmed in all other respects. Sadler appealed to the Commonwealth Court. He maintained that his workers’ compensation benefits had been improperly suspended because he spent no time in incarceration after his conviction, as is required pursuant to the clear language of Section 306(a.1). The Commonwealth Court agreed. PCCC appealed, asking the Pennsylvania Supreme Court whether the Commonwealth Court erred in concluding it was not entitled to a reimbursement of the benefits paid to Sadler during his pre-conviction incarceration while awaiting trial. Finding no merit to PCCC's arguments, the Supreme Court affirmed the Commonwealth Court. View "Sadler v. WCAB (Apl of: Phila Coca-Cola Co.)" on Justia Law

The Pennsylvania Supreme Court granted certiorari review in this matter to determine whether the Department of Transportation (PennDOT) was precluded from suspending an individual’s driving privileges based on a DUI conviction, where there was a lengthy delay between the conviction and the time the driver was notified of the suspension. Under the facts of this case, the Court concluded the trial court’s finding – that Appellee would suffer prejudice if the suspension were to be imposed at this juncture – was supported by competent evidence of record, and moreover, it demonstrated that prejudice would follow from the fact of the delay itself. Additionally, there was no dispute that Appellee did not accrue any additional Vehicle Code violations after his predicate DUI conviction. The Court therefore agreed with the Commonwealth Court majority that a suspension at this late date will have lost much of its effectiveness with regard to its underlying legislative purposes, result in prejudice which can be attributed to the delay, and ultimately deny fundamental fairness. View "PennDOT Bureau of Driver Lic. v. Middaugh" on Justia Law

Two taxing districts undertook parallel challenges to a property’s partial tax exemption. Appellee Huston Properties, Inc. (“Taxpayer”), owned the subject property (the “Property”). In 2013, Taxpayer, claiming to be a charitable institution, sought tax-exempt status for the Property for the 2014 tax year. After a hearing, the Chester County Board of Assessment Appeals granted a partial exemption, reasoning that that portion of the Property was used for charitable purposes. The City of Coatesville appealed that decision to the Court of Common Pleas. Six days later, the Coatesville Area School District, another taxing authority encompassing the Property, lodged its own appeal, also challenging the Property’s partially-tax-exempt status. The School District also intervened in the City's case. Ultimately, the trial court affirmed the Board's grant of a partial exemption. Both the City and the School District appealed to the Commonwealth Court, and Taxpayer cross-appealed as to each, seeking fully-exempt status for the Property. In a memorandum decision, the Commonwealth Court vacated and remanded to the trial court for more specific findings to support the partial tax exemption. On remand, the trial court set forth particularized findings and conclusions, and re-affirmed its earlier decision assessing the Property. At this juncture, the City elected not to appeal to the Commonwealth Court. The School District appealed the ruling in its own case, but it did not appeal the identical, simultaneous ruling which contained the City’s docket number. Taxpayer moved to quash the School District’s appeal. The Commonwealth Court granted the motion and dismissed the appeal observing that the common pleas court’s ruling in the City’s case became final after no party appealed it. Because the School District had intervened in that matter, it was a party to those proceedings. With that premise, the court found that res judicata and collateral estoppel barred it from reaching the merits. The Pennsylvania Supreme Court found that issue preclusion under the rubric of collateral estoppel should not have been applied to defeat the School District’s ability to obtain merits review of its substantive arguments in the intermediate court. The Commonwealth Court's judgment was vacated and the matter remanded for a merits disposition of the consolidated cross-appeals. View "In Re: Appeal of Coatesville Area Sch Dist" on Justia Law

The issue presented for the Pennsylvania Supreme Court's review centered on whether a line of superior court cases changed the procedural requirements of Section 1106 of the Pennsylvania Judicial Code requiring restitution be set at the time of sentencing. Appellant Steven Cochran, II, briefly stayed at a vacation home owned by his grandparents. In late 2016, Appellant’s grandparents visited the home and found Appellant intoxicated. An altercation ensued, during which Appellant threatened and assaulted his grandmother, and deliberately destroyed various items of personal property. Also during the altercation, a fire was ignited, causing additional damage to the premises and personal property. Appellant was arrested and charged with terroristic threats, simple assault, two counts of criminal mischief, and three counts of harassment. At the beginning of the plea hearing, both counsel informed the trial court that the total restitution claimed exceeded $65,000.00, but that Appellant disputed whether he was responsible for that total amount because some of the destroyed or damaged property had belonged to him. Appellant entered a plea of guilty to one count each of terroristic threats, simple assault, and criminal mischief. In the non-restitution proceedings on June 29, 2017, the trial court sentenced Appellant to an aggregate terms of three to 23 months' incarceration, minus time served. A restitution hearing was set for August 28, 2017. Appealing the eventual amount of restitution ordered, Appellant objected to the trial court's jurisdiction, arguing more than 30 days had passed since the June 2017 order, and that the Commonwealth failed “to make a recommendation for restitution and the trial court failed to set restitution at the time of sentencing on June 29, 2017, as required by 18 Pa.C.S. 1106(c)(2).” A panel of the superior court agreed the trial court erred in failing to set restitution at the time of sentencing, reversed, and remanded fur resentencing. The Supreme Court determined that the superior court erroneously presumed that the “time of sentencing” for the purpose of section 1106 occurred solely on June 29, 2017. Because the final complete sentencing order was entered on September 15, 2017, the Supreme Court concluded Appellant had no basis to challenge the sentencing court’s jurisdiction under Section 1106 (c)(2). View "Pennsylvania v. Cochran II" on Justia Law

A court of common pleas granted Appellant Noel Montalvo's petition for post-conviction relief by granting a new guilt-phase trial. The Commonwealth appealed the PCRA court’s grant of a new guilt-phase trial; it did not challenge the PCRA court’s grant of a new penalty-phase trial. Appellant cross-appealed to challenge the trial court's rejection of "a myriad of additional bases for granting him a new guilt-phase trial." Appellant was accused of killing, or acting as an accomplice to the killing of his brother's estranged common law wife and the man she may have briefly dated. Appellant's brother was convicted on two counts of first-degree murder and one count of burglary, for which he was sentenced to death. Appellant would be convicted by jury on first-degree murder charges for the death of his brother's wife, the second-degree murder of her companion, conspiracy to commit murder and burglary. The jury determined the aggravating circumstances outweighed the mitigating circumstances in Appellant's case, and recommended a sentence of death. The PCRA court granted appellant's petition for relief on grounds of ineffective assistance of trial counsel. After review, the Pennsylvania Supreme Court agreed with the PCRA court that appellant established his ineffectiveness claim, and therefore, a new guilt-phase trial was warranted. In light of this conclusion, the Court did not address the issues raised by appellant in his cross-appeal. View "Pennsylvania v. Montalvo" on Justia Law

The Pennsylvania Supreme Court granted the Pennsylvania Department of Transportation (“PennDOT”)’s petition seeking review of a Commonwealth Court holding that a de facto taking of an unmined coal estate, owned by Penn Pocahontas and leased to PBS Coals, Inc. (collectively “the Coal Companies”), occurred under the Eminent Domain Code, 26 Pa.C.S. sections 101-1106 (“Code”), when PennDOT’s construction of Highway 219 on an adjoining parcel destroyed options for constructing rights-of-ways to the coal estate’s surface. In reaching that conclusion, the Commonwealth Court held that the feasibility of mining the coal, as measured by the probability of obtaining a legally required permit from the Department of Environmental Protection (“DEP”), was relevant only to damages. The Supreme Court reversed the Commonwealth Court’s decision, agreeing with PennDOT that the legality of extracting the coal went directly to the trial court’s duty to determine whether a taking occurred. Furthermore, the Court held the Commonwealth Court erred by failing to remand the case for consideration of whether consequential damages are available to the Coal Companies. The matter was remanded to the Commonwealth Court with instructions to remand to the trial court with respect to the Coal Companies’ consequential damages claim. View "PBS Coals, et al v. PennDOT" on Justia Law