Justia Pennsylvania Supreme Court Opinion Summaries

A group of individuals and West Rockhill Township challenged the Pennsylvania Department of Environmental Protection's (DEP) approval of a compressor station project by Adelphia Gateway, LLC. The DEP's approval was issued under the federal Clean Air Act (CAA) and Pennsylvania's Air Pollution Control Act (APCA). The challengers sought review of the DEP's decision before the Pennsylvania Environmental Hearing Board (EHB).The EHB dismissed the appeals, agreeing with Adelphia that the United States Court of Appeals for the Third Circuit had exclusive jurisdiction over the matter under the Natural Gas Act (NGA), which grants federal courts original and exclusive jurisdiction over civil actions for the review of state administrative agency decisions made pursuant to federal law.The Commonwealth Court of Pennsylvania reversed the EHB's dismissal, holding that the EHB had jurisdiction to hear the appeals. The court reasoned that an appeal to the EHB is not a "civil action" as defined by the NGA, and thus, the EHB's review was not preempted by federal law. The court also noted that the DEP's decision was not final until the opportunity for EHB review had expired or been exhausted.The Supreme Court of Pennsylvania 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. The court found that the EHB's review process is an administrative proceeding, not a civil action, and therefore, it does not fall under the exclusive jurisdiction of the federal courts as outlined in the NGA. The court also emphasized that the DEP's decision is not final until the EHB review process is complete or the time to seek such review has expired. View "West Rockhill Twp v. DEP" on Justia Law

Appellants CKHS, Inc. and The Foundation for Delaware County sought a preliminary injunction to prevent Appellees Prospect Medical Holdings, Inc. and Prospect Crozer, LLC from converting Delaware County Memorial Hospital from an emergency and acute care facility to a behavioral health hospital. The asset purchase agreement (APA) between the parties included clauses requiring Prospect to maintain key service lines, including emergency medicine, for five years and to consult with a local advisory board before making significant changes after that period. Additionally, the APA stipulated that any breach would cause irreparable damage.The Delaware County Court of Common Pleas granted the preliminary injunction, finding that Appellants demonstrated the necessary prerequisites, including irreparable harm. The court relied on the APA's irreparable harm clause and expert testimony from Melissa Lyon, who testified that removing healthcare access points from a community almost always negatively impacts health outcomes, particularly for socioeconomically disadvantaged and elderly populations.The Commonwealth Court reversed the trial court's order, concluding that the trial court abused its discretion by finding irreparable harm based on speculative and hypothetical evidence. The Commonwealth Court held that the APA's irreparable harm clause alone was insufficient and required concrete evidence of harm, which it found lacking in Lyon's testimony.The Supreme Court of Pennsylvania reviewed the case and determined that the Commonwealth Court misapplied the appellate standard of review, which requires a highly deferential approach to the trial court's decision. The Supreme Court found that the trial court had apparently reasonable grounds to issue the preliminary injunction based on Lyon's testimony and the APA's irreparable harm clause. Consequently, the Supreme Court reversed the Commonwealth Court's order and remanded the case for further proceedings to address the remaining factors for preliminary injunctive relief. View "CKHS, Inc. v. Prospect Med Hldgs, Inc." on Justia Law

William Herold worked for the University of Pittsburgh as a stationary engineer from 1976 to 2004, during which he was exposed to asbestos. He later became a foreman, a position without asbestos exposure, and retired in 2015. In 2019, Herold was diagnosed with mesothelioma, attributed to his asbestos exposure, and he died in 2022. His estate filed a common law negligence action against the University and other defendants in the Allegheny County Court of Common Pleas.The trial court denied the University’s motion for summary judgment, which argued that the Occupational Disease Act (ODA) provided the exclusive remedy for Herold’s claim. The court found that Herold’s mesothelioma, manifesting more than four years after his last exposure, was not compensable under the ODA. The Commonwealth Court affirmed, holding that the ODA’s exclusivity provision did not apply to Herold’s non-compensable claim, allowing the common law action to proceed.The Supreme Court of Pennsylvania reviewed the case, focusing on whether the ODA’s exclusivity provision barred Herold’s common law action. The Court held that the ODA’s exclusivity provision extends only to claims asserting compensable disability or death, defined as occurring within four years of the last employment. Since Herold’s mesothelioma manifested beyond this period, the exclusivity provision did not apply, and the common law action was permissible. The Court also determined that the doctrine of primary jurisdiction did not require the claim to be adjudicated by the workers’ compensation authorities, as the issues were not complex or technical.The Supreme Court of Pennsylvania affirmed the Commonwealth Court’s decision, allowing the common law negligence action to proceed in the trial court. View "In Re: Estate of W. Herold" on Justia Law

William Roberts was convicted of statutory sexual assault, sexual assault, corruption of the morals of a minor, and indecent assault in 2005. He was sentenced to one and a half to three years in prison and required to register as a sexual offender for life under Megan’s Law III. Roberts complied with his registration obligations until 2019 but failed to report in 2020. The Pennsylvania State Police (PSP) discovered that Roberts no longer lived at his registered address and had not updated his information, leading to his arrest and charges for failing to comply with registration requirements.The Court of Common Pleas of Fayette County convicted Roberts of two counts of failure to comply with registration requirements and sentenced him to five to ten years in prison. Roberts appealed, arguing that the Commonwealth failed to prove he knew he was required to register. The Superior Court affirmed the conviction, holding that the crime occurred when Roberts knowingly failed to register or verify his residence, regardless of whether he knew he was required to do so.The Supreme Court of Pennsylvania reviewed the case to determine if the Commonwealth must prove that a sexual offender knew of their registration obligations to convict them of failure to comply. The Court held that the Commonwealth must prove the offender knew of their SORNA obligations. However, the Court found sufficient evidence that Roberts knew of his lifetime registration requirement, as he had signed forms acknowledging this multiple times. Thus, the Supreme Court affirmed the judgment of sentence. View "Commonwealth v. Roberts" on Justia Law

On May 8, 2020, Sergeant Aaron Scott and Officer Samuel Greco of the Frazer Township Police Department responded to a rollover vehicle accident. They found Jarren Crosby and a female companion near the overturned vehicle. Crosby admitted to driving, and the officers detected signs of marijuana use. Crosby was unsteady and had slurred speech. When the officers detained him for a DUI investigation, Crosby became agitated and resisted arrest. Officer Greco attempted to handcuff Crosby, who resisted by pulling away and screaming. Greco then tackled Crosby and used a taser to subdue him. Crosby was charged with multiple offenses, including DUI and resisting arrest.The Court of Common Pleas of Allegheny County convicted Crosby of DUI, resisting arrest, and careless driving, while acquitting him of other charges. Crosby was sentenced to four days in the DUI Alternative to Jail Program and fifteen months’ probation. Crosby’s post-sentence motions were denied, and he appealed, challenging the sufficiency of the evidence for his resisting arrest conviction.The Superior Court of Pennsylvania affirmed the trial court’s judgment, holding that the evidence was sufficient to support Crosby’s conviction for resisting arrest. The court noted that Crosby’s resistance required substantial force to overcome, as Officer Greco had to tackle him and use a taser.The Supreme Court of Pennsylvania reviewed the case and affirmed the Superior Court’s decision. The court clarified that the offense of resisting arrest under the second variant of the statute involves the defendant employing means that justify or require substantial force to overcome the resistance. The court held that Officer Greco’s tackle of Crosby constituted substantial force, and thus, the evidence was sufficient to support Crosby’s conviction for resisting arrest. The judgment of the Superior Court was affirmed, and the case was remanded to correct a scrivener’s error in the sentencing order. View "Commonwealth v. Crosby" on Justia Law

A law firm, Kleinbard LLC, provided legal services to the Lancaster County District Attorney's Office, led by then-District Attorney Craig Stedman, to challenge the county commissioners over the use of certain forfeiture assets. Stedman and Kleinbard signed an engagement letter, agreeing that Kleinbard would be compensated for its services. The commissioners, however, refused to pay Kleinbard's invoices exceeding the $5,000 budgeted for legal services, arguing that the additional expenses were unauthorized.The Lancaster County Court of Common Pleas sustained preliminary objections from the defendants, allowing only the $5,000 payment and dismissing the remaining claims. The court ruled that the contract for legal services exceeding the budgeted amount was unenforceable under the County Code, which prohibits contracts that exceed appropriated sums without commissioners' approval.The Commonwealth Court affirmed the lower court's decision, agreeing that Stedman lacked authority to enter into a contract exceeding his budget without commissioners' approval. The court also expressed uncertainty about the nature of the Program Accounts, which Kleinbard claimed were controlled by the District Attorney and funded by program participants, not taxpayer money.The Supreme Court of Pennsylvania reviewed the case and found that the lower courts erred by not accepting as true the well-pleaded facts in Kleinbard's complaint at the preliminary objections stage. The Supreme Court held that the allegations, if true, established that the Program Accounts were not subject to the County Code's appropriation limits. Therefore, the court reversed the Commonwealth Court's decision and remanded the case for further proceedings to determine the nature and control of the Program Accounts. View "Kleinbard, LLC v. Lancaster Co. DA" on Justia Law

Prospect Crozer, LLC owned and developed 57.7 acres of real property in Upland Borough, Delaware County, assessed at $80,166,493 for tax years 2017-2019. Prospect appealed the assessment, but the Delaware County Board of Assessment Appeals denied it. Prospect then appealed to the Delaware County Court of Common Pleas, where the Chester Upland School District intervened. Senior Judge John L. Braxton, assigned by the Pennsylvania Supreme Court, presided over the de novo tax assessment proceedings. During this time, Judge Braxton was appointed to the Philadelphia Board of Revision of Taxes and received his first payment from the Board on June 16, 2019. He continued to preside over the tax appeals and issued orders in October 2019.The Delaware County Court of Common Pleas conducted a hearing to determine the timeline of Judge Braxton's dual service and found that he began receiving compensation from the Board on June 16, 2019. The Commonwealth Court then vacated the orders issued by Judge Braxton, concluding that his simultaneous service on the Board and as a judge violated Article V, Section 17(a) of the Pennsylvania Constitution, which prohibits judges from holding an office or position of profit in the government. The court held that this violation resulted in the automatic forfeiture of his judicial office, rendering the orders legal nullities.The Supreme Court of Pennsylvania reviewed the case and agreed that Judge Braxton violated Section 17(a) by holding a position of profit with a municipal corporation while serving as a judge. However, the court rejected the Commonwealth Court's conclusion that this violation resulted in the automatic forfeiture of his judicial office. Instead, the Supreme Court held that the violation created a constitutionally impermissible conflict of duties, requiring the vacatur of the orders entered in the tax appeals. The case was remanded to the Delaware County Court of Common Pleas for reassignment to a new judge. View "In re: Appeal of Prospect Crozer LLC From the Decision of the Board of Assessment Appeals of Delaware County, PA" on Justia Law

Derek Murchison was convicted of first-degree murder for the strangulation of Linda Willis on October 5, 2001, and sentenced to life in prison without parole. Murchison later sought post-conviction DNA testing of items found at the crime scene, arguing that the new DNA results constituted after-discovered evidence warranting a new trial.The Philadelphia County Court of Common Pleas dismissed Murchison's petition, and the Superior Court affirmed. The PCRA court found that the new DNA evidence was cumulative and would not likely compel a different verdict. The court noted that the jury had already been informed that Murchison's DNA was not found at the crime scene and still convicted him based on witness testimony and his confessions.The Supreme Court of Pennsylvania reviewed the case to determine if the lower courts applied the correct legal standard for after-discovered evidence claims based on post-conviction DNA testing. The court held that the same standard applies to all after-discovered evidence claims, including DNA evidence. The court concluded that the new DNA evidence did not establish Murchison's actual innocence and was not likely to result in a different verdict. The court affirmed the lower courts' decisions, emphasizing that the conviction was based on substantial witness testimony and Murchison's confessions, which were not undermined by the new DNA evidence. View "Commonwealth v. Murchison" on Justia Law

On November 18, 2020, Officer Matthew Ibbotson and his partner stopped a silver Honda with heavily tinted windows in a high-crime area of Philadelphia for traffic violations. The driver, Omar Saunders, made suspicious movements, and Officer Ibbotson saw the handle of a gun under the driver’s seat. Saunders admitted he did not have a permit for the gun, which was later found to be stolen. Saunders was arrested, and the gun was seized.The Court of Common Pleas of Philadelphia County denied Saunders’s motion to suppress the gun, ruling that the seizure was justified under the plain view doctrine and the automobile exception, which requires both probable cause and exigent circumstances. Saunders was convicted of firearms offenses and sentenced to three and a half to seven years in prison. The Superior Court affirmed the judgment, holding that the seizure was lawful under the plain view doctrine.The Supreme Court of Pennsylvania reviewed the case to determine the legality of the warrantless seizure. The court held that the seizure was constitutional under the plain view doctrine. It found that the police had a lawful vantage point, the incriminating nature of the gun was immediately apparent, and the police had a lawful right of access to the gun. The court emphasized that the unexpected development of probable cause during a lawful traffic stop justified the seizure without a warrant. Consequently, the court affirmed the Superior Court’s order upholding the denial of suppression of the firearm. View "Commonwealth v. Saunders" on Justia Law

The case involves a group of appellants, including individual citizens, CeaseFirePA, and the City of Philadelphia, who challenged two Pennsylvania statutes that prevent local governments from enacting their own firearms regulations. The appellants argue that these statutes, Section 6120 of the Pennsylvania Uniform Firearms Act and Section 2962(g) of the Home Rule Charter and Optional Plans Law, hinder their ability to address gun violence effectively at the local level.The Commonwealth Court previously reviewed the case and dismissed the appellants' petition, sustaining preliminary objections for failure to state a claim. The court found that the appellants did not sufficiently allege violations of substantive due process under Article I, Section 1 of the Pennsylvania Constitution, the state-created danger doctrine, or improper interference with Philadelphia's delegated duties under the Local Health Administration Law and the Disease Prevention and Control Law of 1955.The Supreme Court of Pennsylvania reviewed the case and affirmed the Commonwealth Court's decision. The court held that the appellants failed to identify a constitutionally protected right that the statutes infringed upon, thus failing to establish a substantive due process claim. The court also concluded that the appellants did not meet the elements required to establish a state-created danger claim, particularly the requirement that the harm caused was foreseeable and fairly direct. Lastly, the court determined that the statutes did not interfere with Philadelphia's delegated public health responsibilities, as the relevant laws did not implicitly or explicitly authorize local firearm regulation.In summary, the Supreme Court of Pennsylvania affirmed the dismissal of the appellants' petition, upholding the statutes that preempt local firearm regulations. View "Crawford v. Commonwealth" on Justia Law