Max Baer

The case involved Viktor Stevenson, who was convicted of indirect criminal contempt for violating a final Protection from Abuse (PFA) order by entering his former fiancé's home. The Pennsylvania Supreme Court affirmed the Superior Court's decision upholding the conviction. The court held that to convict someone of indirect criminal contempt for violating a PFA order, the Commonwealth must prove beyond a reasonable doubt that the defendant had actual knowledge of the order at the time of the violation, regardless of how that knowledge was obtained. In this case, evidence including the prior temporary order, the scheduled hearing that Stevenson skipped, and statements made to him at the scene sufficiently demonstrated his actual knowledge.

criminal lawfamily law

This case involves Albert Reid, who was convicted by a jury of two counts of first-degree murder and sentenced to death; he later filed a PCRA petition challenging his convictions. The primary remaining issue on appeal was whether Reid was incompetent to stand trial and represent himself, and whether prior counsel was ineffective for failing to litigate that issue. The Supreme Court of Pennsylvania held that the PCRA court erred in assessing the substantive competency claim by not properly considering newly proffered post-conviction evidence of mental health issues. The court therefore vacated the PCRA court's order in part and remanded for further proceedings applying the framework from Commonwealth v. Santiago to determine if a meaningful retrospective competency hearing is possible. The decision focused on ensuring due process in evaluating competency based on contemporaneous and new evidence.

criminal lawprocedure

This case is a direct appeal from the dismissal of a Post Conviction Relief Act (PCRA) petition filed by Albert E. Reid, who was convicted of burglary and two counts of first-degree murder for killing his estranged wife Carla Reid and her fourteen-year-old daughter D.M. in 1996, resulting in a death sentence. The Pennsylvania Supreme Court reviewed numerous claims of ineffective assistance of counsel and other alleged errors but affirmed the PCRA court's order in most respects. The court remanded solely for the PCRA court to issue a supplemental opinion explaining its denial of relief on the claims regarding the appellant's competency to stand trial and represent himself, as well as prior counsel's alleged ineffectiveness for not pursuing that issue. The reasoning emphasized that other claims lacked merit or failed to show prejudice, while the competency-related issue required further explanation from the lower court due to its fact-intensive nature.

criminal lawprocedure

The Pennsylvania Environmental Defense Foundation challenged provisions of the 2017 and 2018 General Appropriations Acts and related Fiscal Code amendments, claiming they violated Article I, Section 27 (the Environmental Rights Amendment) of the Pennsylvania Constitution by improperly using oil and gas leasing revenues from state forest and park lands. This was the third in a series of cases in which PEDF contested budgetary transfers and funding decisions following prior rulings that treated such revenues as part of a public trust. The Supreme Court of Pennsylvania affirmed the Commonwealth Court's order denying relief. It held that the challenged provisions either did not involve trust assets or complied with trust principles under Section 27, as some funds came from non-trust sources and others were not shown to breach fiduciary duties.

environment

The case concerned Patrick and Pamela Lutz's application for a dimensional variance to allow an 18-foot encroachment into the rear setback on their undersized lot in Plainfield Township's Farm and Forest Zoning District so they could construct an addition. The Zoning Hearing Board unanimously granted the variance after finding that strict compliance created an unnecessary hardship and that the addition would not harm neighboring properties, and the trial court affirmed based on substantial evidence. The Commonwealth Court reversed, concluding that the Board lacked substantial evidence of hardship. Chief Justice Baer, writing in support of reversal, reasoned that the Commonwealth Court failed to apply the deferential abuse-of-discretion standard applicable when no new evidence is taken and that Hertzberg v. Zoning Board of Adjustment permits a relaxed showing of unnecessary hardship for dimensional variances.

property

This case involved Derrick Edwards, who was convicted of multiple armed robberies in Philadelphia but received a new trial after the prosecutor was found to have violated Batson v. Kentucky by using a peremptory strike against an African American juror based on race. Edwards sought to dismiss the charges entirely on double jeopardy grounds under the Pennsylvania Constitution, arguing that the prosecutor's discriminatory intent constituted overreaching that barred retrial. The Supreme Court of Pennsylvania held that the Batson violation did not rise to the level of prosecutorial overreaching under its prior decision in Commonwealth v. Johnson, which extends double jeopardy protections to reckless misconduct that deprives a defendant of a fair trial. The court reasoned that the single discriminatory strike, after accepting several other African American jurors, did not demonstrate an intentional or reckless disregard for the fairness of the trial process sufficient to preclude retrial, as opposed to mere error warranting a new trial. It therefore affirmed the lower courts' denial of the motion to dismiss.

criminal lawcivil rightsprocedure

This case arose after the 2020 Census reduced Pennsylvania's congressional seats from 18 to 17, necessitating a new districting map for the 2022 elections, but the General Assembly and Governor failed to enact one. The Pennsylvania Supreme Court assumed plenary jurisdiction, appointed a Special Master to evaluate submitted plans, and ultimately selected the Carter Plan over the Special Master's recommendation of vetoed House Bill 2146. The court reasoned that the Carter Plan best met core redistricting criteria including contiguity, compactness, and minimal population deviation, while also showing strong results on partisan fairness metrics such as efficiency gap and responsiveness, and complying with the Voting Rights Act. The plan was ordered into effect for the May 2022 primary and subsequent elections.

elections

This case concerns a challenge to Pennsylvania's congressional redistricting process after the executive and legislative branches failed to agree on a new map following the 2020 census. The Supreme Court granted the petitioners' emergency application for extraordinary jurisdiction under 42 Pa.C.S. § 726 to take up the matter directly. The core reasoning is that the Commonwealth Court's expedited handling still left insufficient time before the May 2022 primary election deadlines, given the possibility of appeals, making immediate Supreme Court resolution necessary for candidates and voters.

elections

The case involved Timothy Oliver Barr II, who was charged with firearm and marijuana possession offenses after police searched his vehicle based on the smell of marijuana during a traffic stop. The trial court suppressed the evidence, finding the search lacked probable cause, but the Superior Court remanded for reconsideration. The Supreme Court held that while the odor of marijuana may be considered as one factor in the totality of circumstances for determining probable cause to search a vehicle, it is not sufficient on its own following the legalization of medical marijuana; thus, the trial court's suppression order was reinstated.

criminal lawgunsprocedure

This case involves a dispute over the termination of a father's parental rights to his two young children under Pennsylvania's Adoption Act. The dissenting opinion concludes that the father failed to perform any parental duties for nearly four years by having no contact whatsoever with the children during his struggle with alcoholism, which satisfies the statutory ground for termination in Section 2511(a)(1). The dissent reasons that the father made a deliberate choice to absent himself rather than facing insurmountable obstacles, and that a parent's rights are not preserved by waiting for a more convenient time to resume responsibilities while others care for the children. It finds the trial court's denial of termination to be manifestly unreasonable, warranting reversal despite deference to trial courts in such matters.

family law

This case concerns a petition to terminate the parental rights of C.K. (Father) with respect to his children L.A.K. and A.L.K. under 23 Pa.C.S. § 2511(a)(1) to facilitate their adoption, based on Father's alleged failure to perform parental duties for at least six months preceding the petition. The dissenting opinion concludes that the facts establish by clear and convincing evidence that Father deliberately had no contact with the children for nearly four years while struggling with alcoholism, without demonstrating reasonable firmness in resisting obstacles to the parent-child relationship. The dissent reasons that this absolute lack of engagement satisfies the statutory criteria for termination, as parental rights cannot be preserved by intentionally absenting oneself until a personally convenient time, and finds the trial court's denial of termination to be manifestly unreasonable.

family law

This case involved a dispute in Pennsylvania's workers' compensation system over whether a non-treating provider, such as a pharmacy, could challenge a utilization review (UR) determination that medications were unreasonable and unnecessary for a work injury through the fee review process. The Bureau of Workers' Compensation Fee Review Hearing Office and the Commonwealth Court ruled that such providers lack standing to contest UR findings in fee review proceedings. The Pennsylvania Supreme Court affirmed this outcome, holding that the Workers' Compensation Act limits UR participation to treating providers, employers, employees, and insurers, and that non-treating providers have no constitutionally protected property interest in payment when treatment is deemed unreasonable. The Court rejected the Commonwealth Court's prospective requirement that non-treating providers receive notice and an opportunity to intervene in future UR proceedings, reasoning that the Act's structure already resolves payment entitlements based on UR results without granting such rights.

labor & employmentprocedurehealthcare

The case concerned whether a non-treating healthcare provider such as a pharmacy could challenge a utilization review determination that medications prescribed for a work-related injury were unreasonable and unnecessary, and whether such providers have due process rights to notice and intervention in utilization review proceedings under Pennsylvania's Workers' Compensation Act. The Supreme Court of Pennsylvania affirmed the Bureau of Workers' Compensation Fee Review Hearing Office and Commonwealth Court rulings that non-treating providers cannot contest utilization review outcomes through the fee review process. The court held that the Act restricts payment obligations to reasonable and necessary treatments, so non-treating providers have no protected property interest in reimbursement when treatment is deemed unreasonable, and thus no right to participate in or receive notice of utilization review. It rejected the intermediate court's prospective requirement that non-treating providers be given notice and intervention opportunities in future utilization reviews, while confirming that fee review remains available solely for disputes over payment amount or timeliness once treatment is approved.

labor & employmenthealthcareprocedure

This case arose after Brady DiStefano was charged with aggravated assault (following dismissal of a homicide charge) in connection with the death of fellow student Caleb Zweig during a brief physical altercation. The trial court granted a pretrial motion excluding any evidence at trial suggesting that DiStefano caused Zweig’s death, concluding under Pennsylvania Rule of Evidence 403 that the evidence’s minimal probative value was outweighed by the risk of unfair prejudice. The Superior Court reversed that ruling on appeal. The Pennsylvania Supreme Court granted review and held that the Superior Court misapplied the deferential “abuse of discretion” standard of review; it therefore vacated the Superior Court’s order, reinstated the trial court’s exclusionary order, and remanded for further proceedings.

criminal lawprocedure

This case concerned whether orders issued under the Pennsylvania Wiretap Act authorizing law enforcement to obtain real-time cell site location information (CSLI) from a defendant's phone during a heroin trafficking investigation complied with the Fourth Amendment. The Pennsylvania Supreme Court decided that the orders were the functional equivalent of search warrants and therefore constitutional under United States v. Carpenter. The court reasoned that the state statute required a showing of probable cause to believe the information would be relevant to an ongoing criminal investigation, along with specific details about the offense and targeted individuals, which satisfied warrant standards, unlike the lower federal threshold for historical CSLI. The Superior Court's affirmance of the defendant's judgment of sentence was upheld.

criminal lawprocedure

This case concerns a challenge by Firearm Owners Against Crime and individual plaintiffs to four City of Harrisburg ordinances regulating firearms, including restrictions on discharge, possession in parks, possession by unaccompanied minors, and reporting of lost or stolen guns. The dissenting opinion concludes that the plaintiffs lack standing to seek declaratory and injunctive relief. The core reasoning is that the complaint fails to allege facts showing a substantial, direct, and immediate interest, such as any charges under the ordinances, immediate intent to engage in prohibited conduct, or specific applicability to the plaintiffs' circumstances, making any potential harm remote and speculative under established standing requirements.

gunsprocedure

The case concerned whether the coordinate jurisdiction rule barred a second trial judge from granting defendants' motion to amend their pleadings to add a statute of limitations defense after an earlier judge had found the defense waived when denying judgment on the pleadings. The dissenting opinion concluded that the rule did not preclude the amendment because the two rulings addressed distinct legal questions. It reasoned that the first judge had determined only whether the existing pleadings entitled defendants to judgment, while the second judge properly exercised discretion to assess whether amendment should be allowed in light of potential prejudice to the plaintiff. The dissent would therefore affirm the Superior Court's judgment upholding the amendment and the resulting dismissal of the complaint.

procedure

This case concerns the application of the Pennsylvania Steel Products Procurement Act to blower systems supplied for a public water and sewer project, specifically whether the systems qualified as United States steel products under the Act's requirement that at least 75% of costs be from domestic sources. The majority refused to allow a 10% deduction for domestic overhead costs on foreign steel components and calculated the cost percentage using amounts paid by the subcontractor to its foreign and domestic suppliers. In this concurring and dissenting opinion, the justice agrees that the overhead deduction is not permitted under the Act but disagrees with the majority's choice of denominator in the cost fraction, instead advocating for the amount paid by the general contractor to the subcontractor as better reflecting the cost of the finished product supplied under the contract. The opinion emphasizes that the Act focuses on costs of articles, materials, and supplies in the product as supplied to the public agency.

business & regulatoryprocedure

The case involved a defendant convicted of murder after a shooting, where the central issue on appeal was the trial court's decision to permit a child witness with autism to testify with the assistance of a trained comfort dog. The Pennsylvania Supreme Court ruled that trial courts have discretion to allow such accommodations by weighing how the support aids the witness in providing truthful testimony against any risk of prejudice to the defendant's right to a fair trial, while using measures to minimize bias such as keeping the dog out of the jury's view and issuing limiting instructions. The court affirmed the lower courts' rulings, finding that the trial judge appropriately balanced these factors and mitigated potential prejudice in this instance. The opinion focused on the procedural standards for witness accommodations rather than the underlying facts of the shooting.

criminal lawprocedure

This case concerned a challenge to an administrative order issued by the president judge of the Erie County Court of Common Pleas, which disqualified Judge Stephanie Domitrovich from handling petitions under 22 Pa.C.S. § 501 for the appointment of private police officers filed by her son on behalf of LECOM. The Supreme Court of Pennsylvania held that the administrative order was not appealable. The Court declined to exercise King's Bench jurisdiction over the matter, finding it was a purely administrative dispute without issues of immense public concern requiring immediate resolution. Instead, the Court invoked its general supervisory and administrative authority under Article V, Section 10(a) of the Pennsylvania Constitution to address the controversy internally.

procedure