Justia Pennsylvania Supreme Court Opinion Summaries

In the case at hand, a group of reproductive health centers and Planned Parenthood affiliates in Pennsylvania challenged the constitutionality of sections of the Pennsylvania Abortion Control Act and corresponding regulations which prohibit the use of state Medicaid funds for abortions except in cases of rape, incest, or to avert the death of the mother. The petitioners argued that the exclusion of abortion from Medicaid coverage violated the Equal Rights Amendment and equal protection provisions of the Pennsylvania Constitution.The Supreme Court of Pennsylvania held that the health centers had standing to bring the lawsuit on behalf of their patients who are enrolled in or eligible for aid under Pennsylvania's Medical Assistance program but whose abortions are not covered because of the exclusion. The court further held that the Commonwealth Court erred in permitting individual members of the Pennsylvania Senate and House of Representatives to intervene in the case.The Supreme Court of Pennsylvania reversed the Commonwealth Court's order dismissing the petition for review. The court concluded that the providers' petition for review was legally sufficient to survive demurrer. The court noted that its precedent may have misstated the breadth of the exclusion and remanded the case to the Commonwealth Court for further proceedings consistent with its opinion. The court did not rule on the constitutionality of the challenged provisions. View "Allegheny Reprod. Health v. PA DHS" on Justia Law

In this case, the Supreme Court of Pennsylvania was tasked with determining whether multiple periods of separation prior to filing a paternity action were enough to preclude the application of the presumption of paternity. The presumption of paternity is a legal doctrine which presumes that a child conceived or born during a marriage is a child of that marriage. The court held that a marital couple's separation prior to the filing of the paternity action does not, per se, preclude the application of the presumption of paternity.In this case, a woman (Mother) and her husband (Husband) were married and separated multiple times. During one of their separations, the woman had unprotected sexual intercourse with another man (B.C.). After the woman became pregnant and gave birth to a child, B.C. filed a paternity action. The woman and her husband, who had since reconciled, argued that the presumption of paternity should apply because they were married at the time of the child's conception and remained married at the time of the paternity action.The lower courts held that the presumption did not apply due to the couple's multiple separations. However, the Supreme Court of Pennsylvania reversed this decision, finding that although temporary separations are a factor to consider in determining whether a marriage is intact, they are not dispositive. The court concluded that the couple's marriage was intact at the time of the paternity action and the presumption of paternity applied, effectively dismissing B.C.’s paternity action. View "B.C. v. C.P. & D.B." on Justia Law

In the case before the Supreme Court of Pennsylvania, the appellant, Jeff Dobson, was a passenger in a vehicle that was stopped by police in a high crime area due to a minor traffic violation. The driver of the vehicle had a suspended license and the other passenger had an active arrest warrant. Dobson had no outstanding warrants and did not exhibit any suspicious behavior. However, the police officer, Officer Duncan, conducted a pat-down search of Dobson solely on the basis of the high crime area designation. During the search, Officer Duncan found a firearm and subsequently arrested Dobson.Dobson was charged with carrying a concealed firearm without a license, persons not to possess firearms, possession of a controlled substance, and possession of drug paraphernalia. Prior to trial, he filed a suppression motion challenging the constitutionality of the pat-down and the subsequent seizure of the gun and drugs. The trial court denied Dobson's suppression motion. Dobson was subsequently convicted on all charges and sentenced to an aggregate of six to fifteen years in prison.On appeal, the Superior Court affirmed the denial of Dobson’s suppression motion. The Supreme Court of Pennsylvania, however, held that the officer's justification for the frisk, being the high crime area designation, was insufficient to support reasonable suspicion that Dobson was armed and dangerous. The fact that Dobson was a passenger in a vehicle that was lawfully stopped in a high crime area for a minor traffic violation did not, by itself, establish reasonable suspicion. The court held that the evidence found should have been suppressed and the convictions vacated. The case was remanded for a new trial without the unconstitutionally obtained evidence. View "Commonwealth v. Dobson" on Justia Law

In a case brought before the Supreme Court of Pennsylvania, Michael and Melissa Sullivan sued Werner Company and Lowe's Companies, Inc. over a mobile scaffold that collapsed and caused serious injury to Michael Sullivan. The Sullivans claimed the scaffold was defectively designed because it was possible for a user to inadvertently rotate the deck pins off the platform during normal use.Before trial, the Sullivans filed a motion to preclude Werner and Lowe’s from admitting into evidence any industry or government standards, which the trial court granted. The jury ultimately found Werner and Lowe’s liable for the design defect and awarded the Sullivans $2.5 million in damages.Werner and Lowe's appealed, arguing that they should have been allowed to present evidence that the mobile scaffold complied with industry and governmental safety standards. The Supreme Court of Pennsylvania affirmed the lower courts' decisions, ruling that such compliance evidence remained inadmissible in products liability cases.The court applied the risk-utility test, which asserts that a product is in a defective condition if a ‘reasonable person’ would conclude that the probability and seriousness of harm caused by the product outweigh the burden or costs of taking precautions. The court concluded that evidence of a product’s compliance with governmental regulations or industry standards is inadmissible in design defect cases to show a product is not defective under the risk-utility theory because such evidence goes to the reasonableness of the manufacturer’s conduct in making its design choice, not to whether the product was defectively designed. View "Sullivan v. Werner Co." on Justia Law

The Supreme Court of Pennsylvania held that the Pennsylvania Department of Corrections (DOC) had violated the procedural due process rights of an inmate, Thomas Washington. The DOC had increased the rate at which it garnished Washington’s prison account to pay for his court-ordered financial obligations, without giving him prior notice or an opportunity to challenge this increase. The court rejected the DOC's argument that the increase was mandated by a legislative amendment and that no discretion was available for the DOC to alter the rate. The court held that the amendment to the law did not remove the obligation for the DOC to follow due process requirements before increasing the rate of deductions from inmates' accounts. The court reversed the lower court's decision, which had dismissed Washington's complaint, and remanded the case for further proceedings. The court noted that even if Washington was not ultimately entitled to a return of the additional funds, he had a right to make his case before the increased deductions occurred. View "Washington v. PA Dept. of Corrections" on Justia Law

In Pennsylvania, a group of casinos, including Greenwood Gaming and Entertainment, Inc., Mountainview Thoroughbred Racing Association, LLC, and Chester Downs and Marina, LLC, sued the Pennsylvania Department of Revenue. The casinos claimed that online games offered by the state lottery simulated slot machines, violating restrictions imposed by the state legislature and infringing on the casinos' share of the online market. The Commonwealth Court disagreed and dismissed their complaint.Upon appeal, the Supreme Court of Pennsylvania found that the Commonwealth Court erred in its interpretation of the law by focusing on individual components of an online lottery game. The Supreme Court held that determining whether an online lottery game violates the prohibition against simulating a slot machine requires a subjective assessment of the game's overall appearance and effect when in play.The Supreme Court vacated the order of the Commonwealth Court and remanded the case for further proceedings, instructing the lower court to focus on the overall presentation and effect of the challenged game, not on individual features. View "Greenwood Gaming v. Dept. of Rev." on Justia Law

In this case, the Supreme Court of Pennsylvania was called upon to determine whether the ascension of an unclassified service employee to a classified service position with higher pay with the same public employer is a promotion under the Civil Service Reform Act (CSRA) and the Veterans’ Preference Act (VPA). The case arose when Ralph E. Lynn, a classified service employee, and Aaron Novotnak, an unclassified service employee, both veterans, applied for a classified service position with the Department of Corrections (DOC). The Office of Administration (OA) deemed the position a promotion for Lynn and did not apply veterans’ preference, while it deemed the position an appointment for Novotnak and applied veterans’ preference. The DOC selected Novotnak for the position, and Lynn appealed to the State Civil Service Commission.The Supreme Court of Pennsylvania held that the ascension of an unclassified service employee to a classified service position with higher pay with the same public employer is not a promotion under the CSRA and the VPA, but rather an appointment. Therefore, it is not discriminatory under section 2704 of the CSRA to award a veterans’ preference to an unclassified service employee seeking an appointment but not to a classified service employee seeking a promotion. The court affirmed the order of the Commonwealth Court in part and reversed in part. The court ruled that Lynn was not entitled to veterans’ preference as he was seeking a promotion, not an appointment. However, Lynn will remain in his position due to a separate issue of technical discrimination that was not reviewed by the court. View "Department of Corrections v. Lynn" on Justia Law

In this case before the Supreme Court of Pennsylvania, Joseph Tambellini, Inc. and HTR Restaurants, Inc., along with other businesses, had their business interruption insurance claims related to the COVID-19 pandemic denied by their insurer, Erie Insurance Exchange. The businesses had sued Erie in various courts across Pennsylvania. Due to the factual and legal overlap among these claims, the businesses moved for all state-wide litigation to be coordinated in Allegheny County for all pre-trial and trial purposes under Rule of Civil Procedure 213.1.Erie appealed to the Superior Court, which affirmed in part and reversed in part. According to the Superior Court, the trial court exceeded the authority of Rule 213.1 by ordering the coordination of similar actions against Erie that had not yet been filed. The Superior Court further held that the businesses were parties who were empowered by Rule 213.1 to file the motion for coordination.Upon the parties’ cross-appeals, the Supreme Court of Pennsylvania granted review of both holdings. The Supreme Court of Pennsylvania agreed with the Superior Court that the trial court lacked authority to coordinate actions that had not yet been filed. Furthermore, the Supreme Court found that Erie had waived any argument that the businesses could not seek coordination when it failed to raise this issue in the trial court. Therefore, the Supreme Court affirmed the Superior Court’s order. View "Tambellini v. Erie Insurance" on Justia Law

In a dispute arising from insurance coverage for business interruption losses during the COVID-19 pandemic in the Supreme Court of Pennsylvania, various businesses, including Joseph Tambellini, Inc. and HTR Restaurants, Inc., had sued their insurer, Erie Insurance Exchange, for denial of their claims. The businesses moved for the coordination of all state-wide litigation, including future filings, in Allegheny County under Rule 213.1 of the Pennsylvania Rules of Civil Procedure, which allows for the coordination of actions in different counties that involve a common question of law or fact. The motion was granted by the trial court, but on appeal, the Superior Court held that the trial court exceeded the authority of Rule 213.1 by ordering the coordination of similar actions against Erie that had not yet been filed.On further appeal, the Supreme Court of Pennsylvania agreed with the Superior Court. The court found that the term "pending" in Rule 213.1 clearly refers to cases that have already been filed, and does not include cases that are imminent or impending. The court further noted that Erie had waived the argument that the plaintiffs were not entitled to seek coordination as it had not raised this issue in the trial court. The Superior Court's order was affirmed, holding that Rule 213.1 does not permit the coordination of actions that have not been filed at the time of the coordination motion and Erie had waived its argument that the plaintiffs were not entitled to seek coordination. View "HTR Restaurants v. Erie Insurance" on Justia Law

In April 2017 and June 2017, Appellant Diane Zilka filed petitions with the Philadelphia Department of Revenue (the “Department”), seeking refunds for the Philadelphia Tax she paid from 2013 to 2015, and in 2016, respectively. During the relevant tax years, Appellant resided in the City, but worked exclusively in Wilmington, Delaware. Thus, she was subject to four income taxes (and tax rates) during that time: the Philadelphia Tax; the Pennsylvania Income Tax (“PIT”); the Wilmington Earned Income Tax (“Wilmington Tax”); and the Delaware Income Tax (“DIT”). The Commonwealth granted Appellant credit for her DIT liability to completely offset the PIT she paid for the tax years 2013 through 2016; because of the respective tax rates in Pennsylvania versus Delaware, after this offsetting, Appellant paid the remaining 1.93% in DIT. Although the City similarly credited against Appellant’s Philadelphia Tax liability the amount she paid in the Wilmington Tax — specifically, the City credited Appellant 1.25% against her Philadelphia Tax liability of 3.922%, leaving her with a remainder of 2.672% owed to the City — Appellant claimed that the City was required to afford her an additional credit of 1.93% against the Philadelphia Tax, representing the remainder of the DIT she owed after the Commonwealth credited Appellant for her PIT. After the City refused to permit her this credit against her Philadelphia Tax liability, Appellant appealed to the City’s Tax Review Board (the “Board”). The issue this case presented for the Pennsylvania Supreme Court's review as whether, for purposes of the dormant Commerce Clause analysis implicated here, state and local taxes had to be considered in the aggregate. The Court concluded state and local taxes did not need be aggregated in conducting a dormant Commerce Clause analysis, and that, ultimately, the City’s tax scheme did not discriminate against interstate commerce. Accordingly, the Court affirmed the Commonwealth Court order. View "Zilka v. Tax Review Bd. City of Phila." on Justia Law