Justia Pennsylvania Supreme Court Opinion Summaries

In this discretionary appeal, the Pennsylvania Supreme Court addressed whether a magisterial district court had jurisdiction over a case proceeding under the Landlord and Tenant Act, where the plaintiff was the purchaser of a property at a sheriff’s sale, and the defendants were the property’s former owners who refused to leave, but where the parties did not have a landlord-tenant relationship. The Supreme Court determined the magistrate court did not have jurisdiction, and so reversed and remanded for dismissal. View "Assouline v. Reynolds" on Justia Law

In this appeal, the issue presented for the Pennsylvania Supreme Court’s consideration was a question of whether excerpts from the mental health treatment reports of Petitioner, a Roman Catholic diocesan priest, which were obtained by the investigating grand jury in this matter via subpoena, could be included in “Report 1” of the 40th Investigating Grand Jury. The subpoenas were issued as part of the grand jury’s investigation into allegations of acts of sexual abuse committed by priests and other church employees in six Catholic dioceses in Pennsylvania. This appeal concerned the last of the 32 challenges made by individuals named in Report 1 who requested redaction of their personal and/or identifying information from that report. After careful review, the Supreme Court concluded that, under the Mental Health Procedures Act (“MHPA”), this information was not subject to public disclosure. Therefore, the Court reversed the supervising judge of the grand jury’s decision allowing inclusion of these matters in Report 1. View "In Re: 40th IGJ of: R.M.L." on Justia Law

In this discretionary appeal, the Pennsylvania Supreme Court considered whether a requested change of beneficiary designation and plan option for benefits payable under the State Employees’ Retirement System (SERS) was effective upon mailing or upon receipt by SERS, where SERS did not receive the required change documentation until after the SERS member’s death. The Court held the change was not effective until receipt by SERS, the common law mailbox rule did not apply, and the Commonwealth Court erred in holding to the contrary. View "Estate of L. Wilson v. State Employees' Retirement Bd." on Justia Law

This appeal involved an airline employee who was injured while riding an airport shuttle bus to an employee parking lot after her shift ended. The question before the Pennsylvania Supreme Court was whether the employee’s injury can be said to have occurred on the airline’s premises for purposes of the Workers’ Compensation Act even though the City of Philadelphia owned both the shuttle bus and the employee parking lot. The Supreme Court concluded the Commonwealth Court, Appeal Board, and WCJ correctly concluded that the lot in which the employee parked her vehicle was integral to the company’s business operations. The employee used the airport parking lot and shuttle service to enter and exit her workplace. As part of the airline’s business relationship with the airport, it clearly was aware that the Division of Aviation would make employee parking available to the airline’s employees. “Indeed, the evidence presented to the WCJ suggests that, had the Division not done so, US Airways would have been obligated under its collective bargaining agreement with the Association of Flight Attendants to reimburse flight attendants like Bockelman for the cost of airport parking.” View "US Airways, et al. v. WCAB (Bockelman)" on Justia Law

In February 2018, a Pennsylvania Department of Corrections prison guard died after an inmate attacked him and kicked him in the head with Timberland boots. Later that month, the Department suspended commissary sales of such boots. Thereafter, prison officials issued a memorandum to all inmates stating that, effective immediately, Timberland and Rocky boots could no longer be purchased by prisoners. In this direct appeal, the issue presented for the Pennsylvania Supreme Court’s review centered on whether the Department of Corrections acted permissibly in mandating that certain types of boots possessed by inmates be surrendered or sent home. The appellant alleged he owned a pair of Timberland boots, previously purchased through the prison’s commissary for approximately $99.00, which was deducted from his inmate account. He averred that, per the Memorandum’s requirements, his boots, and those of approximately 50,000 other inmates, would effectively be confiscated without a refund. Appellant characterized the killing of the prison guard as an isolated incident to which the Department overreacted, describing the seizure of his boots as constitutionally “arbitrary and irrational.” The Commonwealth Court determined Appellant failed to allege that the Department had engaged in any conduct prohibited by law, such as deceptive representation or the breach of a warranty; and the Department and its employees are protected by sovereign immunity from claims based on alleged intentional torts. The Supreme Court concurred with the Commonwealth Court and affirmed its order. View "Sutton v. Dept. of Corr." on Justia Law

In 2014, agents of the Office of Attorney General (“OAG”), as part of their investigation of the electronic dissemination of child pornography, discovered that a computer at an identified Internet Protocol (IP) address registered with Comcast Cable Communications, repeatedly utilized a peer-to-peer file-sharing network, eMule, to share child pornography. The OAG applied for, received, and executed a search warrant at Appellant Joseph Davis’s apartment. After being Mirandized, Appellant informed agents that he lived alone, that he was the sole user of the computer, and that he used hardwired Internet services which were password protected, and, thus, not accessible by the public, such as through Wifi. The agents arrested Appellant for the eMule distributions and seized his computer. Appellant was asked for the password to this computer and Appellant refused to give it. Appellant was charged with two counts of disseminating child pornography, and two counts of criminal use of a communication facility. The Commonwealth filed with the Luzerne County Court of Common Pleas a pre-trial motion to compel Appellant to divulge the password to his HP 700 computer. Appellant responded by invoking his right against self-incrimination. The trial court focused on the question of whether the encryption was testimonial in nature, and, denied the motion as a violation of Appellant’s Fifth Amendment rights. The Superior Court disagreed and reversed. The Pennsylvania Supreme Court found that such compulsion was indeed violative of the Fifth Amendment to the United States Constitution’s prohibition against self-incrimination. Thus, it reversed the Superior Court. View "Pennsylvania v. Davis" on Justia Law

This matter came from two separate lawsuits commenced in the Pennsylvania courts of common pleas which were subsequently removed to federal district courts on the basis of diversity jurisdiction, and thereafter consolidated for disposition by the United States Court of Appeals for the Third Circuit. Appellee William Scott was covered by an automobile insurance policy issued by Appellant Travelers Commercial Insurance Company. Appellee Samantha Sayles was covered by an automobile policy issued by Appellant Allstate Insurance Company. Allstate’s policy contained a clause, similar to the one in Scott’s policy, providing that, in order to receive first-party medical benefits, the insured had to submit to mental and physical examinations by physicians selected by the insurance company at the company’s behest before medical benefits were paid. Both appellees were injured in separate car accidents, and their respective insurance companies refused to pay their medical bills. The United States Court of Appeals for the Third Circuit certified a question of Pennsylvania law to the Pennsylvania Supreme Court: Does an automobile insurance policy provision, which required an insured seeking first-party medical benefits under the policy to submit to an independent medical exam whenever the insurer requires and with a doctor selected by the insurer, conflict with 75 Pa.C.S. Section 1796(a) of the Pennsylvania Motor Vehicle Financial Responsibility Law (“MVFRL”), such that the requirement was void as against public policy? After review, the Supreme Court concluded that the provision indeed conflicted with Section 1796(a), and was void as against public policy. View "Sayles. v. Allstate Ins Co." on Justia Law

In 2016, Pennsylvania State Police troopers initiated a traffic stop of a vehicle driven by Appellant Shane Smith based on their observation that the license plate was not illuminated, a violation of the Motor Vehicle Code. The troopers requested Appellant’s license and registration, at which point either Appellant or his passenger opened the glovebox. When the glovebox was opened, the troopers observed a plastic vial containing marijuana. A subsequent search of the vehicle revealed a firearm, ammunition, and a clip under the driver’s seat. The manufacturer’s number on the firearm appeared to have been scratched, but was still legible. Appellant was arrested and charged with, inter alia, possession of a firearm with an altered manufacturer’s number. In this appeal by allowance, the Pennsylvania Supreme Court considered whether the possession of a firearm with a scratched, but still legible, manufacturer’s number was sufficient to sustain a conviction for possession of a firearm with an “altered” manufacturer’s number. The Court held that, in order to establish that a manufacturer’s number was “altered” for purposes of 18 Pa.C.S Section 6110.2, the Commonwealth must establish that the number was changed in a material way, such as by making it look like a different number, or that it was rendered illegible, in whole or in part, to the naked eye. As the original manufacturer’s number on Appellant’s firearm was, notwithstanding the scratch marks, still legible to the naked eye, it reversed the Superior Court, vacated Appellant’s conviction and judgment of sentence for violating Section 6110.2, and remanded the matter for resentencing. View "Pennsylvania v. Smith" on Justia Law

Appellant Michael Mock was convicted for a 2006 DUI on March 27, 2007. More than ten years after committing this offense, but roughly nine years following his conviction, Appellant committed another DUI on July 10, 2016. He was later charged with DUI ?highest rate of alcohol; the Commonwealth deemed Appellant’s DUI a second offense and graded it as a misdemeanor of the first degree subject to increased penalties. Before proceeding to trial, Appellant filed a motion to quash the information, asserting that the Commonwealth improperly characterized the 2016 DUI as a second offense because his earlier offense did not constitute a prior offense under 75 Pa.C.S Section 3806. The Pennsylvania Supreme Court granted allocatur in this matter to address the relevant date for determining whether an earlier offense constitutes a prior offense. The Court agreed with the Superior Court that the ten-year lookback period ran from the occurrence date of the present offense to the conviction date of the earlier offense, rather than the occurrence date of the earlier offense. View "Pennsylvania v. Mock" on Justia Law

Appellants Jonathan Saksek and Joshua Winter challenged a superior court decision to affirm summary judgment in favor of Appellees Janssen Pharmaceuticals, Inc., Johnson & Johnson Company, and Janssen Research and Development, LLC (collectively, “Janssen”). Saksek and Winter were two of a large number of men who filed suit against Janssen, alleging that they developed gynecomastia as a result of their ingestion of Risperdal, an antipsychotic drug manufactured by Janssen. In 2014, Janssen filed two motions for summary judgment, which were nominally directed at Saksek’s and Winter’s cases, but had language affecting all Risperdal plaintiffs: the companies sought a global ruling that all claims accrued for statute of limitations purposes no later than October 31, 2006, when Janssen changed the Risperdal label to reflect a greater association between gynecomastia and Risperdal. The trial court ruled that all Risperdal-gynecomastia claims accrued no later June 31, 2009. The superior court disagreed, ruling that all such claims accrued no later than Janssen’s preferred date (October 31, 2006). Concluding that the superior court erred in granting summary judgment at all in Saksek’s and Winter’s cases, the Pennsylvania Supreme Court vacated its decision and remanded to the trial court for further proceedings. View "In Re: Risperdal Litig." on Justia Law