Justia Pennsylvania Supreme Court Opinion Summaries

In the Commonwealth of Pennsylvania v. Daniel D. Chisebwe, the Supreme Court of Pennsylvania considered whether the evidence was sufficient to support the summary convictions of Daniel Chisebwe for violating two provisions of the Motor Vehicle Code: 75 Pa.C.S. §1511 (Carrying and exhibiting driver’s license on demand) and 75 Pa.C.S. §1311 (Registration card to be signed and exhibited on demand). Chisebwe repeatedly refused to produce his driver’s license and registration card after being stopped for speeding and did so only about twenty-five minutes into the traffic stop, when the police were about to remove him from his car and take him to the police station.The Court held that the evidence was sufficient to support the convictions. The Court found that the phrase "upon demand" in the relevant statutory provisions required Chisebwe to produce his driver’s license and registration card immediately or nearly immediately when requested by a police officer. Chisebwe's delayed production of these documents, about twenty-five minutes into the traffic stop, was far from prompt and therefore did not satisfy the statutes.The Court also held that the safe-harbor provisions of the statutory provisions did not apply to Chisebwe. These provisions permit a driver to produce his license and registration card either at the office of the police officer or the office of the issuing authority, which did not happen in this case. Instead, Chisebwe produced the documents on the side of the road, which did not comport with the specific office-production requirements of the safe-harbor provisions. The Court affirmed the order of the Superior Court upholding Chisebwe’s judgment of sentence. View "Commonwealth v. Chisebwe" on Justia Law

The Supreme Court of Pennsylvania upheld a township ordinance that regulated the discharging of firearms within the township, except at indoor and outdoor shooting ranges. The plaintiff, a resident of the township, challenged the ordinance, claiming it violated his Second Amendment rights by limiting his ability to practice and maintain proficiency in firearm use. The court determined that the ordinance does not violate the Second Amendment. Applying the historical tradition test outlined by the United States Supreme Court in New York State Rifle & Pistol Assoc., Inc. v. Bruen, the court found the ordinance to be consistent with the nation's historical tradition of firearm regulation, which includes restrictions on when and where firearms can be discharged. The court also found that the ordinance does not interfere with the plaintiff's right to bear arms as it does not prevent him from owning or possessing firearms, but simply regulates where they can be discharged. The court also noted that the ordinance allows for shooting ranges in certain areas of the township, providing opportunities for individuals to gain proficiency in firearm use. View "Barris v. Stroud Township" on Justia Law

The case involves KEM Resources, LP and Ryvamat, Inc., who both own a fifty percent interest in the oil, gas, and mineral rights of a property located in Wyoming County. Ryvamat entered into a gas lease covering the entirety of the property’s oil and gas rights, including the half owned by KEM, receiving a substantial monetary payment. KEM's predecessors in interest filed a claim for an accounting, requesting Ryvamat account for the portion of the lease payment it received attributable to KEM’s fifty percent interest. Ryvamat argued that KEM’s action was barred by the statute of limitations. The Superior Court disagreed and found that the applicable statute of limitations for KEM’s accounting claim is six years, and the original complaint was timely filed. The Supreme Court of Pennsylvania agreed with the Superior Court, affirming its holding. The court ruled that KEM's accounting claim is properly considered a statutory claim for an accounting between co-tenants under Section 101. The court further found that the statute of limitations for such a claim is six years. Therefore, KEM filed its accounting claim within the statute of limitations for a claim under Section 101. View "KEM Resources, LP v. Ryvamat, Inc." on Justia Law

In a dispute between two IT staffing firms, Vinculum, Inc. and Goli Technologies, LLC, the Supreme Court of Pennsylvania held that the trial court erred by not awarding attorney fees to Vinculum, as stipulated in their contract, after it found that Goli Technologies breached the contract. The court further held that the trial court did not err by limiting Vinculum's damages to the one-year non-compete period specified in the contract.The case originated from Goli Technologies' breach of a consulting agreement that contained a one-year non-compete provision. Vinculum sued for breach of contract, seeking both attorney fees and lost-profit damages. The trial court found for Vinculum but denied attorney fees and limited the award of damages to the one-year non-compete period. The Superior Court affirmed the trial court's decision.Reversing the Superior Court's decision regarding attorney fees, the Supreme Court held that the trial court should have awarded Vinculum attorney fees as stipulated in the contract. The court remanded the case to the trial court for a hearing to determine the reasonable amount of attorney fees to be awarded to Vinculum.Regarding the lost-profit damages, the Supreme Court agreed with the trial court and the Superior Court that Vinculum's damages were limited to the period of the non-compete clause. The court held that although damages beyond the non-compete period are not absolutely barred, Vinculum did not establish at trial that it suffered lost-profit damages extending beyond the non-compete period. Thus, the court affirmed the lower courts' decisions on this issue. View "Vinculum, Inc. v. Goli Technologies, LLC" on Justia Law

In a case before the Supreme Court of Pennsylvania, Ursinus College utilized financing from the Montgomery County Health and Higher Education Authority (Authority) to undertake a construction project. The International Brotherhood of Electrical Workers, Local No. 98 (IBEW) asserted that this project was a public work under the Pennsylvania Prevailing Wage Act (PWA), which would require workers on the project to receive prevailing minimum wages. The court was tasked with determining whether this project constituted a public work under the PWA. The court found that the project was not a public work as defined in the PWA, as the funds for the project did not come from a public body. Rather, the Authority served as a conduit for financing, with private funds generated from the Authority's ability to issue bonds being used to pay for the project. The Authority did not hold or disburse these funds, nor did it bear any risk or liability with respect to the repayment of the bonds. Therefore, the court held that the project was not subject to the PWA's prevailing wage requirements. View "Ursinus College v. Prevailing Wage Appeals Board" on Justia Law

The Supreme Court of Pennsylvania ruled in favor of the Ivy Hill Congregation of Jehovah’s Witnesses, finding that the Commonwealth Court violated the coordinate jurisdiction rule by dismissing the Congregation's petition against the Department of Human Services. According to the faith's tenets, congregation elders are obligated to maintain the confidentiality of confessions, which might include confessions of child abuse. The Pennsylvania Child Protective Services Law (“CPSL”) identifies certain individuals, including clergymen, as mandated reporters of child abuse. The Congregation filed a petition for review, asking for a declaration on whether their elders are entitled to the clergyman privilege, which would protect them from the mandatory reporting requirements of the CPSL. The Commonwealth Court dismissed the petition, reasoning that the Department of Human Services was not a proper defendant and that declaratory relief would not terminate the controversy. However, the Supreme Court of Pennsylvania held that this dismissal violated the coordinate jurisdiction rule as it directly contradicted the Commonwealth Court's prior determination on the same issues. The case was remanded for further proceedings. View "Ivy Hill Cong. of Jehovah Witnesses v. DHS" on Justia Law

The Supreme Court of Pennsylvania affirmed the decision of the Commonwealth Court confirming certain modifications to a recovery plan for the City of Chester under the Municipalities Financial Recovery Act, commonly known as Act 47. The case arose from the City of Chester's financial distress, which led to the appointment of a receiver. The receiver sought to modify the existing recovery plan due to the City’s challenges and the failure of local officials to cooperate with his efforts. The City objected to several initiatives in the modified plan, arguing they unlawfully deprived its elected officials of their authority to govern on behalf of the residents. The Supreme Court held that the modifications were necessary to achieve financial stability in the City and were not arbitrary, capricious, or wholly inadequate to alleviate the City's fiscal emergency. The court emphasized that the financial health of the municipality was paramount and that local officials must accept the measures necessary for recovery, whether they like it or not. View "Dept of Comm and Econ Dev v. City of Chester" on Justia Law

In a case concerning the Senior Health Insurance Company of Pennsylvania ("SHIP"), the Supreme Court of Pennsylvania upheld a rehabilitation plan devised by the Pennsylvania Insurance Commissioner. SHIP, which sold long-term care policies in multiple states, became insolvent due to the high cost of care against inadequate premiums. The rehabilitation plan was designed to correct the company’s financial condition by adjusting the premiums and benefits of the existing policies. However, insurance regulators from Maine, Massachusetts, and Washington ("Regulators") objected to the plan, arguing that it exceeded the Insurance Commissioner's statutory authority and violated their states' regulatory authority over rates. The court rejected these claims, finding that the plan did not exhibit a "policy of hostility" to the public acts of other states and thus did not violate the Full Faith and Credit Clause of the U.S. Constitution. The court concluded that the Commonwealth Court, holding exclusive jurisdiction over the distribution of SHIP's assets, did not abuse its discretion by approving the plan. View "In Re: Senior Health Ins. Co. of PA" on Justia Law

The Supreme Court of Pennsylvania considered whether a violation of a juvenile defendant's Fifth Amendment right is subject to appellate review for harmless error. The case involved Nazeer Taylor, who was charged with several serious felony offenses as a juvenile. The juvenile court transferred Taylor's case to adult criminal court, considering Taylor's refusal to admit guilt for his alleged offenses as a factor in its decision. The Supreme Court of Pennsylvania previously held that such consideration violated Taylor's Fifth Amendment right. In this appeal, the Supreme Court concluded that the violation constituted a structural error, not subject to a harmless error review. Given Taylor's current age of 27, neither the juvenile nor the adult criminal court had the statutory authority to conduct a new certification hearing. Consequently, the Supreme Court affirmed the order of the Superior Court reversing Taylor's conviction and discharging him. View "Commonwealth v. Taylor" on Justia Law

The Supreme Court of Pennsylvania ruled that a "regular use" exclusion in a motor vehicle insurance policy does not violate the Motor Vehicle Financial Responsibility Law (MVFRL), thereby reversing the order of the Superior Court. The case involved Matthew Rush, a detective, who was injured in a motor vehicle accident while driving a city-owned car insured under the city's policy. Rush had his personal vehicles insured with Erie Insurance. When Rush's injuries exceeded the liability insurance limits of the other drivers involved in the accident and the underinsured motorist (UIM) coverage limits of the city's policy, he filed a claim for UIM benefits under his Erie policies. Erie denied coverage based on the "regular use" exclusion in the Erie Policies. The Supreme Court of Pennsylvania held that the "regular use" exclusion was valid and enforceable, and did not violate the MVFRL. The court reasoned that UIM coverage was not universally portable and could, therefore, be subject to policy exclusions. View "Rush v. Erie Insurance Exchange" on Justia Law