Justia Civil Procedure Opinion SummariesArticles Posted in Supreme Court of Pennsylvania
KEM Resources, LP v. Ryvamat, Inc.
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
Allegheny Reprod. Health v. PA DHS
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
Sullivan v. Werner Co.
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
Washington v. PA Dept. of Corrections
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
Tambellini v. Erie Insurance
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
HTR Restaurants v. Erie Insurance
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
Zilka v. Tax Review Bd. City of Phila.
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
DiNardo v. Kohler, et al.
Cosmo DiNardo (“DiNardo”) suffered from bipolar disorder, schizophrenia, and schizoaffective disorder, and, as a result, exhibited psychosis, grandiose speech, suicidal ideation, as well as homicidal ideation and violent behavior. He confessed to killing four individuals, and pleaded guilty to four counts of first-degree murder. He subsequently filed a complaint against his treating psychiatrist and health care providers, claiming that his criminal conduct was the result of his psychiatrist’s grossly negligent treatment, and sought compensatory damages, indemnification for judgments levied against him by his victims’ families, and counsel fees. In an appeal by allowance, the issue presented for the Pennsylvania Supreme Court's consideration was whether the “no felony conviction recovery” rule precluded DiNardo’s cause of action. Because the Court found the rule barred the medical malpractice claims at issue in this appeal, it affirmed the order of the Superior Court. View "DiNardo v. Kohler, et al." on Justia Law
Hangey, et al. v. Husqvarna, et al.
In this case, a Pennsylvania trial court transferred venue based on a determination the corporate defendant did not regularly conduct business in Philadelphia County because only 0.005% of the company’s total national revenue was derived from that county. On appeal, the Superior Court reversed, holding the trial court abused its discretion in transferring venue. The Pennsylvania Supreme Court granted discretionary review to evaluate the Superior Court’s determination, and affirmed: venue was proper in Philadelphia County. View "Hangey, et al. v. Husqvarna, et al." on Justia Law
In Re: Nom. Michael Doyle
The issue this case presented for the Pennsylvania Supreme Court's review was whether the Commonwealth Court abused its discretion in ordering Appellants, Eric Sloss and Sandor Zelekovitz, (“Objectors”) to pay the counsel fees of Appellee Michael Doyle, a candidate for the Republican nomination for Representative of Pennsylvania’s 12th Congressional District (“Candidate”) in the May 17, 2022 Primary Election. These fees were incurred during the litigation of Objectors’ petition to set aside Candidate’s nominating petitions for lack of a sufficient number of legally valid signatures from Republican electors. After review, the Supreme Court concluded the Commonwealth Court abused its discretion in ordering Objectors to pay such fees. The Court therefore reversed its order in that respect. View "In Re: Nom. Michael Doyle" on Justia Law