Thomas G. Saylor

This case is a capital murder appeal in which defendant Albert Reid challenged his convictions for killing his wife and daughter and the resulting death sentence on grounds of ineffective assistance of counsel. Justice Saylor concurs in the result upholding the guilt phase and supports a remand for further proceedings but dissents as to the penalty phase. He would grant a new sentencing hearing because trial counsel, who lacked any prior capital case experience, elicited extensive bad-character evidence from defense witnesses, failed to present available mitigating evidence of brain damage and mental illness, and otherwise delivered a deficient penalty-phase presentation that left the jury without key information relevant to sentencing.

criminal law

The case involved a challenge to a vehicle search based on the odor of burnt marijuana, in light of Pennsylvania's medical marijuana laws allowing legal consumption. The suppression court credited expert testimony that the smell of burnt marijuana from illegal smoking could not be distinguished from legally vaporized medical marijuana. Justice Saylor's concurrence noted that the ruling hinged on this credibility determination, rendering it potentially case-specific rather than supporting broader legal pronouncements by the majority. He reasoned that if the odor more likely resulted from combustion, it would indicate the probable commission of illegal marijuana smoking inside the vehicle.

criminal lawprocedure

This case involves a dispute over whether a school district's delay in deciding a charter school's renewal application beyond the end of the existing charter term automatically grants a new five-year charter. The Pennsylvania Supreme Court held that no such automatic renewal occurs under the Charter School Law. The majority and concurring/dissenting opinions agreed that the statute's language at 24 P.S. §17-1729-A does not impose automatic consequences for late decisions and that courts cannot create an extension where the legislature did not. The opinions focused on statutory interpretation of timing requirements and noted potential operational uncertainties for schools but concluded that any remedies for delays must come from legislative amendments rather than judicial action.

business & regulatoryprocedure

This case involved landowners in Tioga County suing UGI Storage Company for inverse condemnation damages, alleging that UGI's operation of a natural gas storage field and designation of a surrounding buffer zone effectively took their properties without compensation. The lower courts had dismissed the claims, ruling that UGI could not be liable because it lacked eminent domain authority specifically tied to the properties at issue. The Pennsylvania Supreme Court vacated the Commonwealth Court's decision and remanded the case, holding that under the Eminent Domain Code, a public or quasi-public entity need only possess the general capacity to receive condemnation powers, not property-specific authority, to face inverse condemnation liability. The Court based this on a plain-meaning reading of the statute that aligns with constitutional requirements for just compensation in de facto takings. The matter returns to address an alternative waiver issue raised in the trial court.

property

In these consolidated cases, Pennsylvania landowners sued UGI Storage Company for inverse condemnation damages, alleging that the company's federally approved natural gas storage operations and proposed buffer zone in Tioga County substantially interfered with their properties. The trial court dismissed the petitions, and the Commonwealth Court affirmed, ruling that UGI could not be liable because it lacked eminent domain authority specific to the properties at issue. The Pennsylvania Supreme Court vacated that decision, holding that under the Eminent Domain Code an entity need only possess general condemnation powers as a public or quasi-public entity to face potential inverse condemnation liability, without requiring property-specific authority. The court based this on a plain-meaning interpretation of the statute that aligns with constitutional requirements and remanded for further proceedings on other issues.

propertyprocedurefederal power

This case involved a defamation lawsuit filed by Joy M. Fox against multiple defendants over statements published online, with appeals challenging the selected venue in Philadelphia County. The Pennsylvania Supreme Court affirmed the Superior Court's ruling that venue was proper there. The court held that under Pennsylvania Rules of Civil Procedure 1006 and 2179, a defamation cause of action arises where defamatory statements are published, meaning where they are read and understood as such by third parties. It applied the same standards used in prior newspaper libel cases, noting that internet publications can create venue in multiple counties, and plaintiffs may select one where injury occurred without needing to show substantiality.

proceduretorts & liability

This case involved a school district's decision to expel a student for sending private memes from home that the district characterized as cyberbullying and terroristic threats under its policies. The concurrence agrees with the outcome affirming relief for the student but on alternative grounds, emphasizing that the district's policies were expressly limited to conduct in a school setting or under school supervision pursuant to the Public School Code, rendering them inapplicable to the off-campus activity. The opinion further concludes that the board's written adjudication was inadequate because it failed to analyze the specific elements of the policies, including intent requirements, and lacked sufficient evidentiary support for the findings. As a result, the discipline could not stand based on the policies as written and applied.

free speechcivil rights

The case concerned whether a casino's provision of concert tickets to patrons counted as taxable 'services' under statutory definitions of gross terminal revenue and gross table game revenue for Pennsylvania gaming taxes. The court decided that the concert experiences did not qualify as services. The reasoning centered on substantial ambiguity in whether artistic performances constitute services as commonly understood, with such ambiguities in taxing statutes resolved in the taxpayer's favor. The concurrence emphasized that tax law focuses on economic realities rather than the tangible form of tickets or vouchers.

taxesbusiness & regulatory

This case addressed whether venue rules developed for defamation claims based on newspaper publications apply equally to claims arising from internet publications. The Pennsylvania Supreme Court held that under the Rules of Civil Procedure, venue is proper in any county where a cause of action arises, including counties where defamatory statements are published and understood by third parties as defamatory. The Court applied its prior decision in Gaetano v. Sharon Herald Co. and the Uniform Single Publication Act, concluding that a plaintiff may choose a single venue among multiple possible locations where publication and injury occurred. It affirmed the Superior Court order upholding venue in Philadelphia County based on the plaintiff's alleged injury there.

proceduretorts & liability

This case involved a defamation lawsuit filed in Philadelphia County by Joy M. Fox against various defendants over statements published on the internet regarding a local election in Chester Heights. The central issue was whether venue could properly lie in a county where the plaintiff allegedly suffered harm from online publications, consistent with rules for traditional newspaper libel. The Pennsylvania Supreme Court affirmed the lower courts' rulings that venue was proper there. The court reasoned that under Pa.R.Civ.P. Nos. 1006 and 2179 and precedent from Gaetano v. Sharon Herald Co., a defamation cause of action arises where defamatory statements are published and understood by third parties, allowing a plaintiff to select any such venue even for widely accessible internet content.

proceduretorts & liability

This case involved a defamation lawsuit filed by Joy M. Fox against multiple defendants over statements published on the internet, with the central dispute being whether venue was proper in Philadelphia County under Pennsylvania procedural rules. The Supreme Court of Pennsylvania affirmed the Superior Court's order, holding that venue may be laid in any county where the cause of action arose, which for defamation includes locations where defamatory statements are published and understood as such by third-party readers. The Court reasoned that the same standards applied in prior newspaper libel cases, such as Gaetano v. Sharon Herald Co., extend to internet publications because publication occurs wherever the statements are accessed and apprehended, consistent with Pa.R.Civ.P. 1006 and 2179 as well as 42 Pa.C.S. §8343. The decision declined to alter these venue rules retroactively or through prospective rulemaking at this time.

proceduretorts & liability

The case concerned whether the City of Pittsburgh had authority under Pennsylvania's home-rule laws to enact an ordinance requiring local employers to provide paid sick days, framed as a disease-prevention measure. The court upheld the ordinance, concluding that a provision in the Disease Prevention and Control Law of 1955 supplied the necessary express statutory permission for home-rule municipalities to regulate in this area. The core reasoning involved construing the statute to overcome the general business-regulation exclusion in the Home Rule Charter and Optional Plans Law, even though the provision did not facially apply to Pittsburgh. The concurrence agrees with the result but observes that the case is close under that approach and suggests a more direct reading that requires the exception to be express rather than implied.

business & regulatorylabor & employmenthealthcare

The case involved a dispute over the administration of a testamentary trust established by Augustus T. Ashton, under which appellant Elizabeth Reed, a grandniece, receives a fixed annual annuity of $2,400 from trust income. Reed challenged the trustee PNC Bank's petition to divide the trust into separate beneficiary and charitable portions and to increase its fees, including a large retroactive commission. The Pennsylvania Supreme Court held that Reed has standing to object to these matters because her interest could be affected by changes in trust income or structure, even with a fixed benefit and sufficient corpus. The court reasoned that standing turns on whether the beneficiary can show a potential impact from the proposed actions, reversing the Superior Court's contrary determination on standing while remanding for further proceedings on the merits.

propertyprocedure

This case involved a dispute over whether Pennsylvania courts could intervene when the Bucks County Republican Committee sought to discipline or remove an elected committeeperson for alleged violations of the party's internal code of ethics, including campaigning against endorsed candidates and sending critical mailers. The plaintiff, Daniel Mohn, filed suit in the court of common pleas seeking declaratory and injunctive relief to block any removal proceedings after complaints were filed and an ethics hearing was scheduled. The Supreme Court of Pennsylvania affirmed the Commonwealth Court's order, ruling that courts lack jurisdiction to interfere in the internal affairs of political parties. The court's core reasoning was that, under the First Amendment's protection of freedom of association, parties may interpret and enforce their own governing rules and select leaders without judicial oversight unless there is a direct and substantial nexus to state action, such as the nomination of candidates for judgeships.

electionscivil rights

This case concerned the applicable statute of limitations for petitions filed under Pennsylvania's Protection of Victims of Sexual Violence or Intimidation Act and whether a petitioner's asserted ongoing fear must meet an objective reasonableness standard. The Pennsylvania Supreme Court held that the six-year catch-all limitations period governs such petitions rather than the two-year period for tort or personal injury actions, and that the Act imposes no requirement of objective reasonableness for claims of intimidation or fear. The core reasoning was that petitions under the Act rest on alleged criminal conduct as defined in the Crimes Code, not on tortious conduct, rendering the shorter tort-based limitations periods inapplicable, while the statutory language itself contains no objective-harm or objective-fear element.

criminal lawprocedure

This case is a post-conviction appeal by Robert Anthony Flor from the denial of relief in his capital murder case, where he raised multiple claims including ineffective assistance of counsel for failing to argue that he was intellectually disabled and thus ineligible for execution under Atkins v. Virginia. The concurring opinion notes that the PCRA court failed to address all issues in its opinion as required by procedural rules and expresses a preference for remand, but joins the majority's review of the claims and concurs in the result denying relief. On the Atkins claim specifically, the opinion agrees with the dissent that the issue is not waived because it implicates an illegal sentence but concurs in the majority's alternative merits analysis rejecting it. The opinion also joins the dissent regarding the prosecutor's statements to the sentencing jury under Caldwell v. Mississippi.

criminal lawprocedure

This case involved a mother convicted of child endangerment for failing to secure her child in a car seat while using a ride-sharing service. The lead opinion vacated the conviction, concluding that the conduct was not covered by the endangerment statute under a community-standards analysis. In this concurring opinion, Justice Saylor agrees with the result of vacating the conviction and sentence but reaches that conclusion by applying the rule of lenity. He notes the absence of clear statutory guidance on parents' duties regarding car seats in ride-sharing contexts and emphasizes that penal statutes must be strictly construed in favor of the defendant. The concurrence stresses that this approach avoids reliance on community standards while still respecting the lack of express criminalization of the conduct.

criminal law

This case involves James Henry Cobbs's appeal from the denial of his Post Conviction Relief Act (PCRA) petition, in which he challenged the validity of his conviction and sentence under the U.S. Supreme Court's rulings in Miller v. Alabama and Montgomery v. Louisiana concerning juvenile life sentences. The majority of the Pennsylvania Supreme Court concluded that the claim satisfied the PCRA eligibility criterion under 42 Pa.C.S. §9543(a)(2)(i), as the asserted constitutional violation undermined the truth-determining process. In this concurring opinion, Justice Saylor joins the result but disagrees with that characterization, arguing instead that eligibility is better supported by viewing the issue as a retroactively imposed legal impediment under the rationale of Commonwealth v. Lantzy.

criminal law

The case involved Jordan Adonis Rawls, who was charged with criminal homicide and related offenses for a home-invasion robbery resulting in two deaths. During a police interrogation after his arrest, Rawls received Miranda warnings but was not specifically informed that formal charges had already been filed against him. He waived his rights and made incriminating statements, which he later sought to suppress on Sixth Amendment grounds, arguing that the lack of notice about the charges invalidated his waiver of the right to counsel. The Pennsylvania Supreme Court held that the Miranda warnings were sufficient to make the waiver knowing and intelligent under the Sixth Amendment, affirming the lower courts' denial of suppression. The court reasoned that, per U.S. Supreme Court precedent, such warnings adequately convey the risks of self-representation during post-indictment questioning, and there is no per se requirement to disclose that charges have been filed.

criminal law

In this medical negligence lawsuit, plaintiffs alleged that a hospital and several doctors were liable for permanent brain damage suffered by a patient following spinal surgery, including claims of corporate negligence based on the hospital's allegedly inadequate credentialing of the operating surgeon. The core dispute involved whether portions of the hospital's credentialing file, particularly responses to queries of the National Practitioner Data Bank, were subject to discovery or shielded by Pennsylvania's Peer Review Protection Act and the federal Health Care Quality Improvement Act. The Supreme Court of Pennsylvania ruled that a hospital credentials committee qualifies as a review committee under the PRPA to the extent it engages in peer review activities, and that the HCQIA and its regulations create a privilege protecting NPDB responses from disclosure that overrides contrary state law. The court therefore reversed the Superior Court's order requiring production of the NPDB materials while vacating and remanding on the remaining issues for proceedings consistent with its opinion.

healthcareproceduretorts & liability