Justia Pennsylvania Supreme Court Opinion Summaries

Mark R. Schmidt, a workers' compensation attorney, sustained a work-related injury while loading files into a trial bag. His treatment included pain management with medications like OxyContin and Oxycodone. To avoid increasing his medication dosage, his physician, Dr. Murphy, prescribed CBD oil. Schmidt purchased CBD oil and lotion over the counter and used them as directed. He sought reimbursement from his employer, Schmidt, Kirifides and Rassias, PC, for the CBD oil costs, which the employer refused, arguing that CBD oil is not a pharmaceutical drug.A Workers' Compensation Judge (WCJ) granted Schmidt's penalty petition, ordering the employer to reimburse him for the CBD oil costs. The Workers' Compensation Appeal Board (Board) reversed this decision, stating that Schmidt did not follow the necessary rules for reimbursement and that CBD oil is not a "supply" under the Workers' Compensation Act (WCA) due to the lack of FDA approval. The Commonwealth Court reversed the Board's decision, concluding that CBD oil is a "medicine" or "supply" under the WCA and that Schmidt, not being a provider, was not required to submit standard billing forms for reimbursement.The Supreme Court of Pennsylvania reviewed the case and held that any item prescribed by a health care provider as part of a treatment plan for a work-related injury falls within the meaning of "medicines and supplies" under Section 306(f.1)(1)(i) of the WCA. The court also held that the cost containment provisions of the WCA and related regulations do not apply to claimants who are not providers. Therefore, Schmidt was entitled to reimbursement for the CBD oil costs, and the Commonwealth Court's order was affirmed. View "Schmidt v. Schmidt, Kirifides & Rassias" on Justia Law

Chanel Glover and Nicole Junior, a same-sex married couple, decided to conceive a child using assistive reproductive technology (ART) and a sperm donor. They entered into various contracts with a fertility clinic and a sperm bank, and both signed affidavits expressing their intent for Junior to adopt the child. However, their relationship deteriorated before the child was born, and Glover filed for divorce. Junior sought a court order to establish her parentage of the child, which the family court granted.The Court of Common Pleas of Philadelphia County confirmed Junior as the legal parent of the child, ordered Glover to inform Junior when she went into labor, and required Junior's name to appear on the child's birth certificate. Glover appealed, and the Superior Court affirmed the trial court's decision, holding that Junior established parentage through contract principles, equitable estoppel, and intent-based parentage.The Supreme Court of Pennsylvania reviewed the case and held that none of the existing pathways to establish legal parentage—biology, adoption, equity, or contract—applied to the facts of this case. The court adopted the doctrine of intent-based parentage into Pennsylvania common law, recognizing that the parties' mutual intent to conceive and raise the child together, as evidenced by their actions and agreements, established Junior's parentage. The court affirmed the Superior Court's decision on the ground of intent-based parentage, emphasizing that this doctrine aligns with public policy and the evolving concept of family. View "Glover v. Junior" on Justia Law

Keith Lamar Foster was interviewed by Detective Bryan Sellers regarding a sexual assault case. Foster voluntarily went to the police station, was not restrained, and was allowed to use his cell phone. During the interview, Detective Sellers told Foster he was not a suspect, despite having obtained a search warrant for Foster’s DNA. Foster provided a DNA sample, which later matched the DNA found on the victim, leading to his arrest and charges of rape and sexual assault.The Court of Common Pleas of Allegheny County granted Foster’s motion to suppress his statements, ruling that the detective’s misrepresentation rendered Foster’s statement involuntary. The court found that the detective’s statement deprived Foster of his ability to make a free and unconstrained choice to undergo the interview.The Superior Court of Pennsylvania reversed the suppression order, concluding that under the totality of the circumstances, Foster’s statement was voluntary. The court noted that Foster was not in custody, the interview was non-coercive, and Foster voluntarily provided his DNA sample.The Supreme Court of Pennsylvania affirmed the Superior Court’s decision. The court held that a misrepresentation by police that an interviewee is not a suspect does not per se render a statement involuntary under the Fifth Amendment. The court emphasized that the totality of the circumstances test remains the proper standard for determining voluntariness. The court found that Foster’s statement was voluntary, considering the non-coercive nature of the interview, Foster’s voluntary presence, and his consent to provide a DNA sample. View "Commonwealth v. Foster" on Justia Law

Dr. Omar Almusa, a licensed medical physician and surgeon in Pennsylvania, unlawfully distributed hydrocodone between 2014 and 2018. He pleaded guilty to unlawful dispensing and distributing a controlled substance, conspiracy to distribute, and health care fraud. In 2019, he was sentenced to 24 months in prison followed by three years of supervised release. Consequently, the State Board of Medicine automatically suspended his medical license for at least ten years, effective August 15, 2019.Almusa did not appeal the suspension. In 2020, the General Assembly enacted Act 53, redefining how licensing boards consider criminal offenses, specifying that only drug trafficking offenses (involving at least 100 grams of a controlled substance) warrant automatic suspension. Almusa's offense did not meet this threshold. In 2021, Almusa petitioned for reinstatement of his license, arguing that Act 53 should apply to his case, allowing him to seek reinstatement without waiting ten years.The Board denied his petition, stating that Act 53 did not apply retroactively to suspensions imposed before its enactment. The Commonwealth Court affirmed the Board's decision, interpreting the suspension and reinstatement as a single action requiring a ten-year suspension period.The Supreme Court of Pennsylvania reversed the Commonwealth Court's decision. It held that automatic suspension and reinstatement are separate actions under the Medical Practice Act. The Court found that Act 53, effective December 28, 2020, applies to reinstatement proceedings initiated after this date. Since Almusa's offense did not qualify as drug trafficking under Act 53, the ten-year waiting period did not apply to his reinstatement petition. The Court concluded that Almusa was entitled to have his reinstatement petition considered under the new law. View "Almusa v. State Board of Medicine" on Justia Law

Cedric Galette initiated a negligence action against Julie McCrey and New Jersey Transit (NJ Transit) in the Court of Common Pleas of Philadelphia County. Galette alleged that he was injured when a vehicle operated by McCrey, in which he was a passenger, was struck by an NJ Transit vehicle. NJ Transit, an instrumentality of the State of New Jersey, filed a motion to dismiss the suit, invoking interstate sovereign immunity. The trial court denied the motion.NJ Transit appealed to the Superior Court, which affirmed the trial court's decision. The Superior Court held that NJ Transit is not an instrumentality or arm of the State of New Jersey and, therefore, is not entitled to sovereign immunity protections. The court applied a six-factor test from Goldman v. Southeastern Pennsylvania Transportation Authority to determine NJ Transit's status and concluded that the factors did not support NJ Transit's claim to sovereign immunity.The Supreme Court of Pennsylvania reviewed the case to determine whether the United States Supreme Court's decision in Franchise Tax Board of California v. Hyatt (Hyatt III) compels a conclusion that interstate sovereign immunity bars Galette’s suit against NJ Transit. The court held that NJ Transit is indeed an arm of the State of New Jersey, emphasizing the statutory classification of NJ Transit as an instrumentality of the state, the degree of control the state exercises over it, and its core function of providing public transportation, which is a governmental function. Consequently, the court reversed the Superior Court's judgment, resulting in the dismissal of Galette’s suit against NJ Transit. The case was remanded to the trial court for further proceedings regarding Galette’s claims against McCrey. View "Galette v. New Jersey Transit" on Justia Law

In 2007, Richard Roland Laird was sentenced to death following his retrial for first-degree murder, having originally been convicted and sentenced to death in 1988 for the same offense. Laird's most recent appeal challenges the denial of his latest Post Conviction Relief Act (PCRA) petition as untimely. He requested the Pennsylvania Supreme Court to create an equitable exception to the PCRA’s time-bar, citing the decision in Commonwealth v. Bradley, and also argued that Article 7 of the International Covenant on Civil and Political Rights (ICCPR) precluded the dismissal of his petition as untimely.The Court of Common Pleas of Bucks County denied Laird’s PCRA petition, finding it untimely and not meeting any statutory exceptions. The court also rejected Laird’s claims on the merits, including ineffective assistance of counsel (IAC) claims and an illegal sentencing claim. Laird’s appeal to the Pennsylvania Supreme Court followed.The Pennsylvania Supreme Court affirmed the lower court’s decision, holding that Bradley did not establish an equitable exception to the PCRA’s time-bar and that its rationale could not be extended to create one. The court emphasized that the PCRA’s time limitations are jurisdictional and not subject to equitable principles. Additionally, the court held that the ICCPR could not be invoked to circumvent the PCRA’s timeliness requirements, reaffirming that exceptions to the PCRA’s time-bar are strictly limited to those set forth in the statute.Thus, the Pennsylvania Supreme Court affirmed the order denying Laird’s PCRA petition as untimely, concluding that neither Bradley nor the ICCPR provided a basis to bypass the PCRA’s jurisdictional time-bar. View "Commonwealth v. Laird" on Justia Law

A police detective was charged with multiple criminal offenses, including unsworn falsification to authorities, tampering with or fabricating physical evidence, tampering with public records or information, and obstructing administration of law or other governmental function. The charges stemmed from allegations that the detective assisted his cousin in stalking a woman and attempted to cover up his misconduct by using police databases to obtain her information and then lying about it during an internal affairs investigation.The Municipal Court of Philadelphia dismissed the charges against the detective for lack of evidence. The Commonwealth refiled the charges, but the Court of Common Pleas of Philadelphia County also dismissed them, concluding that the Commonwealth failed to establish a prima facie case. The Superior Court of Pennsylvania affirmed the dismissal, agreeing that the evidence was insufficient to support the charges.The Supreme Court of Pennsylvania reviewed the case and reversed the Superior Court's decision. The Court held that the Commonwealth had presented sufficient evidence to establish a prima facie case for each of the charges. The Court found that the detective's actions, including his false statements during the internal affairs investigation and the suspicious addition of a second folder to the homicide file, supported the charges. The Court emphasized that at the preliminary hearing stage, the evidence must be viewed in the light most favorable to the Commonwealth, and all reasonable inferences must be drawn in its favor. The case was remanded for further proceedings. View "Commonwealth v. Williams" on Justia Law

Daniel Garcia purchased cloth facemasks from several retail stores in late 2020. The retailers collected sales tax on these masks, which Garcia believed to be nontaxable. Garcia filed a class action complaint in the Court of Common Pleas of Allegheny County against the retailers, alleging that they collected sales tax on items they knew or should have known were nontaxable, violating the Unfair Trade Practices and Consumer Protection Law (UTPCPL).The Court of Common Pleas overruled the retailers' preliminary objections, which argued that the complaint was legally insufficient. The Superior Court granted the retailers permission to appeal and reversed the trial court's order. The Superior Court concluded that the collection of sales tax did not occur "in the conduct of any trade or commerce" as contemplated by the UTPCPL. The court reasoned that the collection of sales tax is a statutory obligation distinct from the conduct of trade or commerce and that merchants act as agents of the Commonwealth when collecting sales tax.The Supreme Court of Pennsylvania reviewed the case and affirmed the Superior Court's decision. The court held that a merchant’s collection of sales tax does not occur "in the conduct of any trade or commerce" under the UTPCPL. The court emphasized that the collection of sales tax is a statutory obligation imposed on merchants, who act as agents of the Commonwealth, and is distinct from their commercial activities. The court also noted that the Pennsylvania Code requires a clear separation between the advertising of a product’s price and the sales tax due, further supporting the conclusion that tax collection is not part of trade or commerce. View "Garcia v. Foot Locker" on Justia Law

Jennifer Jackiw, while working for Soft Pretzel Franchise, sustained an injury that led to the amputation of her right forearm. The employer acknowledged liability, and at the time of the injury, Jackiw's average weekly wage was $322.05. The parties agreed that the injury was a "specific loss" under the Pennsylvania Workers' Compensation Act, entitling her to a healing period of up to 20 weeks followed by 370 weeks of compensation. However, they disagreed on how to calculate the weekly benefit amount for the 370 weeks.A workers' compensation judge (WCJ) concluded that Jackiw's benefit should be calculated according to the formula for total disability under Section 306(a) of the Act. The Workers' Compensation Appeal Board (WCAB) affirmed this decision, despite acknowledging arguments that the specific-loss benefits should be calculated differently. The WCAB felt bound by the Commonwealth Court's decision in Walton v. Cooper Hosiery Co., which had interpreted the Act to harmonize benefits for specific loss and total disability.The Commonwealth Court, in a divided en banc panel, affirmed the WCAB's decision, applying the rule of stare decisis and agreeing with the interpretation in Walton. The dissenting judges argued that the statutory text provided more generous benefits for specific-loss injuries than for total disability without the loss of a body part.The Supreme Court of Pennsylvania reviewed the case to determine the correct statutory formula for calculating workers' compensation benefits for the loss of a body part. The court concluded that the plain text of the statute indicated that specific-loss benefits should be calculated under Section 306(c), not Section 306(a). The court vacated the Commonwealth Court's order and remanded the case for further proceedings consistent with this interpretation. View "Jackiw v. Soft Pretzel Franchise" on Justia Law

A group of individuals and West Rockhill Township challenged the Pennsylvania Department of Environmental Protection (DEP) regarding its approval of a compressor station project by Adelphia Gateway, LLC. The DEP's approval was part of the federal Clean Air Act (CAA) and the Pennsylvania Air Pollution Control Act (APCA) enforcement. The challengers sought review from the Pennsylvania Environmental Hearing Board (EHB), which dismissed the appeals, citing the Third Circuit's exclusive jurisdiction under the Natural Gas Act (NGA) for such federal law-related decisions.The Commonwealth Court of Pennsylvania reversed the EHB's dismissal, holding that the EHB had jurisdiction to review the DEP's decision. The court reasoned that an appeal to the EHB is not a "civil action" under the NGA, which grants the Third Circuit exclusive jurisdiction over civil actions challenging state agency decisions under federal law. The court distinguished administrative proceedings from civil actions, noting that EHB appeals are administrative in nature and not subject to the NGA's jurisdictional provision.The Supreme Court of Pennsylvania reviewed the case and affirmed the Commonwealth Court's decision. The court held that the EHB has jurisdiction to review the DEP's permitting decisions under the CAA and APCA. It concluded that EHB appeals are not "civil actions" as defined by the NGA, and thus, the Third Circuit's exclusive jurisdiction does not preempt EHB's review. The court also emphasized that the DEP's decisions are not final until the opportunity for EHB review has passed, aligning with Pennsylvania's statutory framework and the federal Clean Air Act's delegation of authority to state agencies. The case was remanded to the EHB for substantive review of the challengers' appeals. View "Cole v. DEP" on Justia Law