Justia Pennsylvania Supreme Court Opinion Summaries

This discretionary appeal concerned discovery in a medical negligence lawsuit in which the patient suffered complications following surgery at a hospital. The issue was whether certain portions of the hospital’s credentialing file for the doctor who performed the surgery were protected from discovery. The hospital claimed protection under the Peer Review Protection Act and the federal Health Care Quality Improvement Act. The Supreme Court held: (1) a hospital’s credentials committee qualified as a “review committee” for purposes of Section 4 of the Peer Review Protection Act to the extent it undertakes peer review; and (2) the federal Health Care Quality Improvement Act protects from disclosure the responses given by the National Practitioner Data Bank to queries submitted to it – and this protection exists regardless of any contrary aspect of state law. The order of the Superior Court was reversed insofar as it ordered discovery of the NPDB query responses. It was vacated in all other respects and the matter was remanded for further proceedings. View "Leadbitter v. Keystone, et al." on Justia Law

Appellant Gregory Jordan was arrested for his alleged participation in the robbery of Tishana Nowlin. He was charged at docket number 2017-1702 with criminal attempt - homicide, robbery, aggravated assault, criminal conspiracy, persons not to possess a firearm, carrying a firearm without a license, terroristic threats, theft by unlawful taking, and disorderly conduct. At appellant’s request, the persons not to possess a firearm charge was severed and charged at docket number 2018-12031. In fall 2018, at appellant’s request, the parties proceeded to a simultaneous jury and bench trial where the court sat as factfinder for the persons not to possess a firearm charge at 2018-12031 and the disorderly conduct offense at 2017-1702, and the jury served as factfinder for all remaining charges. The issue this case presented for the Pennsylvania Supreme Court's review centered on whether inconsistent verdicts rendered by separate factfinders in a simultaneous jury and bench trial implicated double jeopardy and collateral estoppel concerns, such that a defendant, who was acquitted by the jury on the charges it considered, could not also be found guilty by the trial court of other charges. The Supreme Court concluded that a defendant who elects to proceed with a simultaneous jury and bench trial during a single prosecution is subjected to only one trial and therefore double jeopardy and collateral estoppel do not apply to preclude the guilty verdict rendered by the judge. View "Pennsylvania v. Jordan" on Justia Law

The United States Third Circuit Court of Appeals certified a question of law to the Pennsylvania Supreme Court involving the state's Motor Vehicle Financial Responsibility Law (“MVFRL”). In July 2015, Corey Donovan (“Corey”) suffered significant injuries due to a collision between a motorcycle, which he owned and was operating, and an underinsured vehicle. He recovered the $25,000 limit of coverage available under the policy insuring the underinsured vehicle as well as the $50,000 per person limit of UIM coverage available under Corey’s policy insuring the motorcycle, issued by State Farm Automobile Insurance Company. Corey then sought coverage under a policy issued by State Farm to his mother, Linda Donovan (“Linda”), under which he was insured as a resident relative. Linda’s Auto Policy insured three automobiles but not Corey’s motorcycle. Linda’s policy had a UIM coverage limit of $100,000 per person, and Linda signed a waiver of stacked UIM coverage on her policy which complied with the waiver form mandated by Section 1738(d) of the MVFRL. First, the Pennsylvania Court considered whether an insured’s signature on the waiver form mandated by 75 Pa.C.S. 1738(d) resulted in the insured’s waiver of inter-policy stacking of UIM coverage where the relevant policy insured multiple vehicles. To this, the Supreme Court held the waiver invalid as applied to inter-policy stacking for multi-vehicle policies in light of its decision in Craley v. State Farm Fire and Casualty Co., 895 A.2d 530 (Pa. 2006). The Court then determined whether the policy’s household vehicle exclusion was enforceable following its decision in Gallagher v. GEICO Indemnity Company, 201 A.3d 131 (Pa. 2019). Finally, after concluding that the household vehicle exclusion was unenforceable absent a valid waiver of inter-policy stacking, the Court addressed the third question posed by the Court of Appeals regarding the applicability of the policy’s coordination of benefits provision for unstacked UIM coverage. After review, the Supreme Court held that the policy’s coordination of benefits provision for unstacked UIM coverage did not apply absent a valid waiver of inter-policy stacking. Having answered these questions of law, the matter was returned to the Third Circuit. View "Donovan, et al. v. State Farm Mutual Ins. Co." on Justia Law

In August 2015, just before 7:00 p.m., a tan 2004 Ford Mercury Grand Marquis occupied by a single male driver travelled at a high rate of speed and struck a moving vehicle occupied by two adults and one child in a residential neighborhood in Northeast Philadelphia. After hitting numerous parked cars, witnesses saw this same vehicle strike a six-year-old child who had been riding her bike and playing on the sidewalk near her home located within the same block. The force of this collision sent the child flying into the air and landing head first in a neighbor’s side garden. The driver was then observed unsuccessfully attempting to escape by driving the vehicle into another parked car, which blocked his exit. The driver was seen immediately thereafter leaping from the driver’s side of the car and running on foot away from the path of destruction he caused. Appellant Mark Edwards was identified as the driver; he was found guilty on all charges, which included one count of aggravated assault, and one count of recklessly endangering another person ("REAP"). Appellant was sentenced to an aggregate term of ten to twenty-five years' imprisonment. Among other things, Appellant argued his sentence for aggravated assault and REAP should have merged if: (1) the two offenses met the elements test set out in 42 Pa.C.C. 9756; and (2) assuming arguendo the elements test was not met, Section 9756 was unconstitutional on its face and as applied, as it conflicted with the Pennsylvania judicial test for merger and violated separation of powers and double jeopardy rights under the Pennsylvania Constitution. Since the Superior Court abided by the language of the statute, it did not, as both Appellant and the Commonwealth suggested, "construe the statute in an overly broad manner to bar merger," the Pennsylvania Supreme Court affirmed the Superior Court’s decision. View "Pennsylvania v. Edwards" on Justia Law

In this matter, the trial court instructed the jury, prior to deliberations, that one of the prerequisites necessary to establish the crime of witness intimidation as a first-degree felony had been fulfilled. The Pennsylvania Supreme Court allowed appeal to consider whether that instruction violated the defendant’s right to a jury trial under the Sixth Amendment to the United States Constitution as interpreted in Apprendi v. New Jersey, 530 U.S. 466 (2000). The Supreme Court found that that the jury found Appellant’s conduct to have encompassed one or more aggravating factors as set forth in paragraph 18 Pa.C.S. 4952(b)(1); the trial court told the jury that, to return a guilty verdict, it would have to find one of the (b)(1) aggravators. That being the case, the verdict, when purged of the taint stemming from the erroneous instruction, established guilt on the witness-intimidation charge at the third-degree-felony level. The maximum prison sentence Appellant would have faced at that level was seven years. Because Appellant was sentenced to twelve years, for Apprendi purposes the sentence was greater than the otherwise-imposable statutory maximum. Judgment was reversed and remanded for further proceedings. View "Pennsylvania v. Dixon" on Justia Law

The victim in this case, Annemarie Fitzpatrick wrote a note in her day planner on the day before she died. The note read: “If something happens to me—JOE,” an apparent reference to her husband, Joseph Fitzpatrick, III. Both the trial court and the Superior Court held that Annemarie’s statement was admissible as an expression of her then-existing state of mind under Rule 803(3). The Pennsylvania Supreme Court concluded the statement was admitted in error, and that the error was not harmless. Hence, judgment was reversed, and the case remanded for a new trial. View "Pennsylvania v. Fitzpatrick III" on Justia Law

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