Justia Pennsylvania Supreme Court Opinion Summaries

In July 2012, claimant Charles Chamberlain was unemployed and was receiving unemployment compensation benefits. In October, he pled guilty to the summary offenses of operating a vehicle without a valid inspection, and driving with a suspended license. Relating to the latter conviction, Claimant was sentenced to sixty days in the Keystone House Arrest Program (from November 1, 2012 to December 31, 2012) with the condition that if he failed to comply, he would serve sixty days in the York County Prison. Claimant was also required to attend reemployment eligibility assessment classes. The terms of Claimant’s house arrest restricted him to the home of his sister, but permitted him to work, run errands, and do his Christmas shopping. On November 28, 2012, the local service center of the Office of Unemployment Compensation Benefits issued a notice of determination that Claimant’s sentence of house arrest disqualified him from receipt of benefits because he was “incarcerated after a conviction” under Section 402.6. Claimant appealed the finding of disqualification and, in 2013, a hearing was held before a referee for the Unemployment Compensation Board of Review (UCBR). The referee concluded Claimant was disqualified from receiving benefits, and Claimant appealed. Mindful of the remedial purpose of the Unemployment Compensation (UC) Law, the Commonwealth Court held that a claimant sentenced to house arrest is not “incarcerated” under Section 402.6. Because the terms and conditions of the claimant’s house arrest did not otherwise prevent him from satisfying the statutory requirements for obtaining unemployment compensation benefits, the Commonwealth Court reversed the denial of benefits. Agreeing with the Commonwealth Court's conclusion, the Supreme Court affirmed. View "Chamberlain v. Unemployment Compensation Review Bd." on Justia Law

In 2009, George Lawrence, while employed by Schneider National Inc., suffered a work-related injury when he slipped and fell in a parking lot leased by Domtar Paper Company, and allegedly owned and maintained by Commercial Net Lease Realty Services, Inc., Commercial Net Lease Realty Trust, Commercial Net Lease Realty, Inc., National Retail Properties, Inc., and National Retail Properties Trust. As a result of this injury, Schneider's workers' compensation carrier, Liberty Mutual Insurance Company, paid Lawrence $33,929.23 in workers' compensation benefits. The issue this case presented for the Supreme Court's review centered on whether section 319 of the Pennsylvania Workers' Compensation Act (WCA) conferred on employers or their workers' compensation insurers a right to pursue a subrogation claim directly against a third-party tortfeasor when the injured employee took no action against the tortfeasor. Based on established precedent, the Superior Court held that Section 319 did not permit employers/insurers to commence an action directly against the third-party tortfeasor, and affirmed the trial court's grant of preliminary objections in favor of the tortfeasors. Agreeing with that reasoning, the Supreme Court affirmed. View "Liberty Mutual Ins. Co. v. Domtar Paper Co." on Justia Law

In the Spring of 2014, the supervising judge for the Thirty-Fifth Statewide Investigating Grand Jury found that there were reasonable grounds to believe that an investigation should be conducted into allegations that grand jury secrecy had been compromised. The work of a Special Prosecutor culminated in a grand jury presentment recommending the filing of criminal charges against Pennsylvania Attorney General Kathleen Kane. Through the filing of an action in quo warranto, Attorney General Kane asked the Supreme Court to quash the appointment of a special prosecutor investigating violations of grand jury secrecy requirements. The Supreme Court affirmed, concluding that the supervising judge acted within his authority and sound prerogative in appointing the Special Prosecutor: "although we recognize that there are legitimate concerns arising out of a judicial appointment of a special prosecutor, we follow the approach of the United States Supreme Court and the many other jurisdictions which have found such appointments proper as an essential means to vindicate the courts' own authority." The request for quo warranto relief was denied. View "In Re: 35th Statewide Inv Grand Jury" on Justia Law

The issue this discretionary appeal presented for the Pennsylvania Supreme Court's review centered on whether a county was required to collectively bargain with a union representing county employees before a local workforce investment board could seek competitive bids for the provision of workforce development services previously provided by the same county employees. The issue reduced to whether the local board acted as the county's agent when it sought the bids and ultimately contracted with private entities for the services at issue. The appellant Union argued that the Local Board was to merely "advise and assist" the County in "setting policy to promote workforce investment programs," and that ultimately it was the County who needed to make the decision to bargain with the Union over seeking competitive bids. The Supreme Court found that substantial evidence supported the Pennsylvania Labor Relations Board's finding that the County lacked control over the Local Board's decision to contract for the services through a competitive bid process, and that the decision was well within the statutory authority granted to the Local Board. As such, the Commonwealth Court's decision to affirm the Labor Relations Board's decision was affirmed. View "AFSCME, Council 87 v. Labor Relations Board" on Justia Law

Appellee Maria Brady had a lengthy history of foot problems. By 2007, both of her feet were in pain due to toe deformities. Appellee’s podiatrist, William Urbas, D.P.M., successfully treated toes on her left foot with surgery; he then turned his attention to her right foot. One of Appellee’s primary complaints on her right foot pertained to a hammer-toe condition of her second toe: this deformity caused the middle of Appellee’s second toe to rise above the plane of the foot, which in turn caused rubbing and pain when Appellee wore shoes. Dr. Urbas performed a total of four operations between March 2008 and January 2010. Before each surgery, he explained the risks and complications that could occur, and Appellee signed a consent form acknowledging her awareness of these possible outcomes. The first operation did not finally alleviate Appellee’s condition, and Dr. Urbas eventually performed three more surgeries, each involving, among other things, the removal of additional bone material with the expectation that the foot would, over time, generate soft tissue to fill the gap and provide flexibility. Nevertheless, Appellee’s pain persisted and, in the end, her toe was less stable and significantly shorter than it had been initially. In August 2010, Appellee consulted a different podiatrist, Dr. Harold Schoenhaus, who performed a bone-graft operation which returned the toe to approximately ninety percent of its original length. This procedure also had the effect of restoring some of the toe’s stability and substantially reducing the pain. Appellee testified that she was pleased with the outcome of Dr. Schoenhaus’ surgery and that she returned to all levels of activity. In December 2010, Appellee filed a complaint against Dr. Urbas, alleging that he negligently treated her toe in the three follow-up surgeries performed after March 2008. In this appeal by allowance involving alleged medical negligence, the issue before the Supreme Court centered on whether a doctor may introduce evidence that the patient was informed of and acknowledged various risks of surgery, although the complaint does not assert a cause of action based on a lack of informed consent. After unsuccessfully moving for a new trial on the basis that the trial court erred in admitting the consent evidence, Appellee appealed. The Superior Court vacated and remanded for a new trial. In concluding that the trial court had abused its discretion, the Superior Court court adopted the reasoning of the Supreme Court of Virginia regarding the relevancy of consent evidence in a medical malpractice case: assent to treatment does not amount to consent to negligence, regardless of the enumerated risks and complications of which the patient was made aware. In a trial on a malpractice complaint that only asserts negligence, and not lack of informed consent, evidence that a patient agreed to go forward with the operation in spite of the risks of which she was informed is irrelevant and should be excluded. The Supreme Court affirmed, holding that evidence that a patient affirmatively consented to treatment after being informed of the risks of that treatment is generally irrelevant to a cause of action sounding in medical negligence. View "Brady v. Urbas" on Justia Law

The Post Conviction Relief Act (PCRA) court, after a hearing, rendered an opinion in which it resolved several issues on remand from the Supreme Court. Pertinent to this appeal, the issue was whether appellant received ineffective assistance of trial counsel, and was therefore entitled to relief. With the remand proceedings complete, the Supreme Court considered the issue of whether appellant was entitled to relief based on the cumulative prejudicial effect of all of the alleged errors he set forth in his petition. The Court held that the PCRA court properly resolved the ineffectiveness claims before it, and the Supreme Court concluded that appellant was not entitled to relief on his claim of cumulative prejudice. Thus, the Court affirmed the order of the PCRA court and dismissed all of appellant's claims. View "Pennsylvania v. Simpson" on Justia Law

The Pennsylvania Supreme Court granted review in this case to consider whether the Superior Court exceeded its scope and standard of review by substituting its judgment for that of the trial court in determining whether the child at issue in this case suffered abuse and whether that abuse was perpetrated by his mother. In 2011, twenty-one-month-old L.Z. was brought to Abington Memorial Hospital by L.F., his mother, and R.F., his maternal-aunt, who lived and cared for child together, to be treated for a deep cut nearly halfway around the base of his penis. The physicians also observed a dark bruise in the buckle area (above the jawbone and below the cheekbone) of Child's right cheek and another on his left cheekbone, as well as a severe diaper rash and yeast infection on the front of his body. The child was also unkempt with very dirty legs and feet. The presentation of these injuries was consistent with abuse and inconsistent with several explanations given by Mother and Aunt, which led the treating physicians to suspect that the injuries were non-accidental. The hospital staff filed a report with the Philadelphia Department of Human Services (DHS). After initial emergency proceedings, the court placed the child in protective custody, with physical custody given to Child's maternal grandfather. At an adjudicatory hearing at which Mother was present and represented by counsel but did not testify, the court considered DHS's dependency and aggravated circumstances petitions. The trial court determined that the Mother perpetrated the abuse, and that medical evidence presented by DHS demonstrated the child's injuries were neither accidental nor self-inflicted. The Superior Court reversed the trial court, and the Supreme Court's review of this matter centered on whether the Superior Court misapplied the Child Protective Services Law's (CPSL) definition of child abuse and whether the court misconstrued the evidentiary presumption of 23 Pa.C.S. 6381(d), which provided that when a child incurs abuse not ordinarily suffered absent acts or omissions of a parent or other person responsible, the fact of abuse suffices to establish prima facie evidence of abuse by the parent or person responsible. The Supreme Court concluded that the Superior Court indeed misapplied the CPSL and misconstrued the evidentiary presumption of 23 Pa.C.S. 6381(d). Accordingly, the decision of the Superior Court was reversed and the trial court's order reinstated. View "In the Matter of: L.Z." on Justia Law

The Third Circuit Court of Appeals certified a question of Pennsylvania law to the Pennsylvania Supreme Court. In August 2007, Appellee Wayne Harrison entered into a lease with Appellant Cabot Oil & Gas Corporation, per which Cabot obtained the exclusive right to explore oil-and-gas resources on Harrison's property. In exchange, the company agreed to pay an initial bonus plus a one-eighth royalty on oil or gas successfully produced from the land. Approximately halfway through the primary lease term, Harrison and his wife commenced a civil action against Cabot in a federal district court, seeking a declaration that the lease was invalid. The Harrisons alleged the company had fraudulently induced Mr. Harrison to enter into the lease via an agent's representation that Mr. Harrison would never receive any more than $100 per acre as a threshold bonus payment from a gas producing company. The Harrisons learned of other landowner-lessors receiving higher payments. The Pennsylvania Court accepted certification from the Third Circuit to address whether the primary term of an oil-and-gas lease should have been equitably extended by the courts, where the lessor pursued an unsuccessful lawsuit challenging the validity of the lease. In its counterclaim, Cabot sought a declaratory judgment that, in the event the Harrisons' suit failed, the primary term of the lease would be equitably tolled during the period of time during which the suit was pending, and, concomitantly, the lease would be extended for an equivalent period of time beyond what was provided by its actual terms. The district court awarded summary judgment in Cabot's favor on the suit to invalidate the lease. The court, however, resolved the counterclaim in the Harrisons' favor, concluding that Pennsylvania law does not provide for equitable extensions of oil and gas leases under the circumstances. Cabot appealed, arguing that it would be deprived of the full benefit of the bargained-for terms of its contract with the Harrisons by their "meritless lease challenges." Cabot contended Pennsylvania law provided that a party repudiates a contract, and thus effectuates an essential breach, when he makes an unequivocal statement that he will not perform in accordance with his agreement. The Pennsylvania Supreme Court disagreed with Cabot's contention, holding that the Harrisons' lease challenge was not an anticipatory breach of the lease. "Our reluctance, in this respect, is bolstered by the Harrisons' observation that oil-and-gas-producing companies are free to proceed according to their own devices to negotiate express tolling provisions for inclusion in their leases. [. . .] Certainly, in light of the voluminous decisional law, such companies are on sufficient notice of the prospect for validity challenges to warrant their consideration of such protective measures. [ . . .] Our determination is only that, consistent with the prevailing substantive law of this Commonwealth, the mere pursuit of declaratory relief challenging the validity of a lease does not amount to such." View "Harrison v. Cabot Oil & Gas Corp." on Justia Law

After state police seized over two and one-half pounds of marijuana from appellee Dreama Stotelmyer's residence pursuant to a search warrant, she was charged with possession of a controlled substance with intent to deliver (PWID) and possession of drug paraphernalia. Appellee entered an open guilty plea to PWID, and the Commonwealth nolle prossed the remaining charge. After entry of the plea, the Commonwealth entered notice of its intent to seek application of the mandatory minimum one-year sentence of incarceration. After a hearing, the trial court determined the Commonwealth proved by a preponderance of the evidence that appellee possessed over two pounds of marijuana with the intent to distribute it, invoking 18 Pa.C.S. 7508's mandatory minimum sentencing provisions. However, the trial court instead sentenced appellee to county intermediate punishment, imposing six months of work release from the county jail followed by six months of electronic home monitoring. Following the denial (by operation of law) of its motion to modify sentence, the Commonwealth appealed to the Superior Court, and then to the Supreme Court. The Supreme Court, after review, concluded the Superior Court erred in holding that appellee was eligible for the intermediate punishment sentence when the mandatory minimum sentence under 18 Pa.C.S. 7508 applied. View "Pennsylvania. v. Stotelmyer" on Justia Law

Appellants, twenty-four Pennsylvania voters, filed this action in 2006 in the Commonwealth Court's original jurisdiction to challenge the certification of six direct-recording electronic voting systems (DREs) models in use in Pennsylvania. Seeking declaratory, mandamus, and injunctive relief, Appellants claimed the Secretary of the Commonwealth should have been ordered to decertify the DREs which did not comply with the Election Code and compelled to adopt more rigorous testing standards. In this appeal, the issue presented for the Supreme Court's review centered on whether the Commonwealth Court erred in upholding the decision of the Secretary to certify certain DREs for use in Pennsylvania elections. The Commonwealth Court found that the DREs satisfied the certification requirements set forth in the Election Code and did not infringe on the fundamental right to vote as protected by the Pennsylvania Constitution. The Supreme Court concluded that the Commonwealth Court did not err in granting the Secretary's petition for summary relief. In particular, the Court found the Secretary exercised proper discretion in determining that the certified DREs satisfied the requirements for electronic voting systems set forth in the Election Code and the use of the DREs did not violate Appellants' fundamental right to vote as embodied within Article I, Section 5 of the Pennsylvania Constitution or the uniformity requirement in Article VII, Section 6 of the Pennsylvania Constitution. View "Banfield v. Sec'y of Commonwealth" on Justia Law