Commonwealth v. Miller, 121 A.3d 942 (Pa. 2015). · Go Syfert
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Commonwealth v. Miller, 121 A.3d 942 (Pa. 2015). Cases Citing This Book View Copy Cite
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cited 3× by 3 distinct cases, 2021–2024 · 2 courts · …is absolute, meaning that, where it attaches, the declarant's intent is immaterial even if the statement is false and made with malice. at p. 947 ⚠ not in text
138 citation events (138 in the last 25 years) across 9 distinct courts.
Strongest positive: Michael Weinik v. Temple University of the Commo (ca3, 2021-12-13)
Treatment trajectory · 2015 → 2026 · click a year to view as-of
2015 2020 2026
Top citers, strongest first. 35 distinct citers. How cited ↗
examined Cited as authority (verbatim quote) Michael Weinik v. Temple University of the Commo (4×) also: Cited as authority (rule), Cited "see"
3rd Cir. · 2021 · quote attribution · 1 verbatim quote · confidence high
it can hardly be the law that a plaintiff is prohibited from challenging a defense raised by the defendant because there are costs to litigating its merits.
examined Cited as authority (verbatim quote) RALSTON v. POULOS
E.D. Pa. · 2020 · quote attribution · 1 verbatim quote · confidence high
we hold that the judicial privilege does not apply to an allegation made by an adult before commencement of any quasi-judicial proceeding and without an intent that it lead to a quasi-judicial proceeding.
examined Cited as authority (verbatim quote) Greenberg, M. v. McGraw, N. (2×) also: Cited as authority (rule)
Pa. Super. Ct. · 2017 · signal: see · quote attribution · 1 verbatim quote · confidence high
the judicial privilege operates by incentivizing individuals to speak freely within a judicial (or quasi-judicial) context-or more to the point here, to speak freely in seeking to initiate judicial or quasi-judicial proceedings.
discussed Cited as authority (rule) STRADER v. HOME DEPOT
W.D. Pa. · 2025 · confidence medium
“A witness is absolutely privileged to publish defamatory matter concerning another in communications preliminary to a proposed judicial proceeding ... if it has some relation to the proceeding.” Schanne v. Addis, 121 A.3d 942, 948 (Pa. 2015) (quoting Restatement (Second) of Torts § 588 (1977)).
discussed Cited as authority (rule) GADDY v. WOOD BROTHERS BAR, INC. (2×) also: Cited "see"
E.D. Pa. · 2025 · confidence medium
Schanne v. Addis, 121 A.3d 942, 946-49 (Pa. 2015) (discussing contours of absolute judicial and quasi-judicial privilege).
cited Cited as authority (rule) K.G. Sheehan Vello v. D. DeMarco
Pa. Commw. Ct. · 2025 · confidence medium
In addition, the doctrine is absolute, meaning “the declarant’s intent is immaterial even if the statement is false and made with malice.” Schanne v. Addis, 121 A.3d 942, 947 (Pa. 2015).
discussed Cited as authority (rule) Shen-Sampas v. Klein (2×)
E.D. Pa. · 2025 · confidence medium
Ct. 2014)). 17 Bochetto, 860 A.2d at 73 . 18 In Schanne v. Addis, 615 F. App’x 759 (3d Cir. 2015), our Court of Appeals certified a question to the Pennsylvania Supreme Court: “Does the absolute privilege apply to an allegation of sexual misconduct against a teacher by a former student, which allegation was made prior to the commencement of any quasi-judicial proceeding and without an intent that the allegation lead to a quasi-judicial proceeding?” The Pennsylvania Supreme Court answered the question in the negative, holding “the judicial privilege does not apply to an allegation made …
discussed Cited as authority (rule) LLOYD v. MANBEL DEVCO I LP
E.D. Pa. · 2025 · confidence medium
“This privilege sweeps broadly to protect [a]ll communications pertinent to any stage of a judicial proceeding, including not only . . . communications made in open court, but also . . . pleadings and even less formal communications such as preliminary conferences and correspondence between counsel in furtherance of the client’s interest.” Schwartz v. OneWest Bank, FSB, 614 F. App’x 80, 82-83 (3d Cir. 2015) (internal quotations and citations omitted). “[T]he privilege is absolute, meaning that, where it attaches, the declarant’s intent is immaterial even if the statement is false a…
discussed Cited as authority (rule) BELFI v. WAGNER
E.D. Pa. · 2024 · confidence medium
It “covers statements by a party, a witness, an attorney, or a judge,” and “is absolute, meaning that, where it attaches, the declarant’s intent is immaterial even if the statement is false and made with malice.” Schanne v. Addis, 121 A.3d 942, 947 (Pa. 2015).
discussed Cited as authority (rule) PRATICO v. GIANNOPOULOS (2×)
E.D. Pa. · 2024 · confidence medium
Schanne v. Addis, 121 A.3d 942, 951 (Pa. 2015) (other citations omitted) (citing Pa. R.
examined Cited as authority (rule) Vivian, J. v. St. Luke's Hospital (3×) also: Cited "see, e.g."
Pa. Super. Ct. · 2024 · confidence medium
Answer and New Matter, ¶167; see Pa.R.Civ.P. 1030(a) (providing that “privilege” shall be raised as a defense in a new matter); Schanne v. Addis, 121 A.3d 942, 951 (Pa. 2015) (noting that judicial privilege is a defense that must be raised by a defendant). - 17 - J-A28039-23 lost where republished outside the scope of the proceedings.
discussed Cited as authority (rule) MANCO v. St. Joseph's University
E.D. Pa. · 2024 · confidence medium
“These two factors apply equally to communications made prior to the initiation of judicial proceedings.” Schatzberg, 877 F. Supp. 2d at 247 (citations omitted). “[T]he privilege is absolute, meaning that, where it attaches, the declarant’s intent is immaterial even if the statement is false and made with malice.” Schanne v. Addis, 121 A.3d 942, 947 (Pa. 2015).
cited Cited as authority (rule) WENK v. STATE FARM FIRE AND CASUALTY COMPANY
W.D. Pa. · 2023 · confidence medium
Schanne v. Addis, 121 A.3d 942, 947 (Pa. 2015).
examined Cited as authority (rule) WENK v. STATE FARM FIRE AND CASUALTY COMPANY (3×) also: Cited "see, e.g."
W.D. Pa. · 2022 · confidence medium
Pa. Apr. 21, 2016) (citing Schanne v. Addis, 121 A.3d 942, 947 (Pa. 2015) as recognizing “ a judicial [litigation] privilege providing immunity for communications which are made in the regular course of judicial proceedings and are material to the relief sought.”); Lin v. Rohm & Hass Co., No. 2:11-cv-3158-WY, 2014 U.S. Dist.
cited Cited as authority (rule) PERSICHINI v. NATIONWIDE GENERAL INSURANCE COMPANY
W.D. Pa. · 2022 · confidence medium
Schanne v. Addis, 121 A.3d 942, 946-47 (Pa. 2015) (citations and footnotes omitted).
examined Cited as authority (rule) RALSTON v. POULOS (12×) also: Cited "see", Cited "see, e.g."
E.D. Pa. · 2021 · confidence medium
Ct. 2009). 88 See Bochetto v. Gibson, 860 A.2d 67, 71 (Pa. 2004). 89 Id. (emphases removed) (quoting Post v. Mendel, 507 A.2d 351, 355 (Pa. 1986)). 90 Schanne v. Addis, 121 A.3d 942, 947 (Pa. 2015). 91 Id. (quoting Pawlowski v. Smorto, 588 A.2d 36, 41 (Pa. Super.
cited Cited as authority (rule) HOLFORD v. DIFABIO
E.D. Pa. · 2021 · confidence medium
Pa. 2015) (quoting Schanne v. Addis, 121 A.3d 942, 947 (Pa. 2015), aff'd, 708 F. App’x 64 (3d Cir. 2017).
discussed Cited as authority (rule) Vinco Ventures, Inc. v. Milam Knecht and Warner, LLP (2×) also: Cited "see"
C.D. Cal. · 2021 · confidence medium
Pa. 2015) (quoting Schanne v. Addis, 121 A.3d 942, 947 (Pa. 2015)); Brown, 94 Cal. App. 4th at 44 .
discussed Cited as authority (rule) VINCO VENTURES, INC. v. MILAM KNECHT & WARNER, LLP (2×) also: Cited "see"
E.D. Pa. · 2021 · confidence medium
Pa. 2015) (quoting Schanne v. Addis, 121 A.3d 942, 947 (Pa. 2015)); Brown, 94 Cal. App. 4th at 44 .
discussed Cited as authority (rule) SIMMONS v. GILMORE
W.D. Pa. · 2021 · confidence medium
“Pennsylvania, like many other jurisdictions, recognizes a judicial [litigation] privilege providing immunity for communications which ate made in the regular coutse of judicial ptoceedings and are material to the relief sought.” Schanne v. Addis, 121 A.3d 942, 947 (Pa. 2015).
discussed Cited as authority (rule) FLINT DILLE v. GEER
E.D. Pa. · 2020 · confidence medium
Judicial privilege provides “immunity for communications which are made in the regular course of judicial proceedings and are material to the relief sought,” whether made by “a party, a witness, an attorney, or a judge.” Schanne v. Addis, 121 A.3d 942, 947 (Pa. 2015) (citation omitted). “[W]here [the privilege] attaches, the declarant’s intent is immaterial even if the statement is false and made with malice.” Id.
cited Cited as authority (rule) Hammond, A. v. United States Liability Insurance
Pa. Super. Ct. · 2020 · confidence medium
Judicial privi1ege provides immunity for all communications made during the course of judicial proceedings and are material to the relief sought. schanne v. Addis, 121 A.3d 942, 947 (Pa, �015).
cited Cited as authority (rule) Forbes, C. v. King Shooters Supply
Pa. Super. Ct. · 2020 · confidence medium
Schanne v. Addis, 632 Pa. 545 , 121 A.3d 942, 946-47 (2015) (citations and footnotes omitted).
cited Cited as authority (rule) Forbes, C. v. King Shooters Supply
Pa. Super. Ct. · 2020 · confidence medium
Schanne v. Addis, 632 Pa. 545 , 121 A.3d 942, 946-47 (2015) (citations and footnotes omitted).
discussed Cited as authority (rule) RALSTON v. POULOS (2×)
E.D. Pa. · 2019 · confidence medium
“The judicial privilege is a defense raised by the defendant.” Schanne v. Addis, 121 A.3d 942, 951 (Pa. 2015).
examined Cited as authority (rule) Commonwealth v. McClure (3×) also: Cited "see, e.g."
Pa. Super. Ct. · 2017 · confidence medium
But, the Court explained, while the scope of this privilege has been extended to a “variety of scenarios connected with the sound administration of justice as that term is broadly understood,” , “it has also been made subject to limitations where the administration of justice is not likely to be substantially affected.” Id. at 948-49.
discussed Cited as authority (rule) Church Mutual Insurance Co. v. Alliance Adjustment Group
3rd Cir. · 2017 · confidence medium
“The privilege covers statements by a party, a witness, an attorney, or a judge” and “where [the privilege] attaches, the declarant’s intent is immaterial even if the statement is false and made with malice.” Schanne v. Addis, 632 Pa. 545 , 121 A.3d 942, 947 (2015).
discussed Cited as authority (rule) Stacy Miller v. County of Centre
3rd Cir. · 2017 · confidence medium
The judicial privilege doctrine extends to “statements made to law enforcement officials for the purpose of persuading those officials to initiate criminal proceedings.” Schanne v. Addis, 632 Pa. 545 , 121 A.3d 942, 947-48 (2015).
cited Cited "see" Weiser Law Firm P.C. v. Michael Hartleib
3rd Cir. · 2024 · signal: see · confidence high
See Parks Miller, 702 F. App’x at 73. 64 See Schanne, 121 A.3d at 947–48; Richmond v. McHale, 35 A.3d 779 , 784–85 (Pa. Super.
discussed Cited "see" Mathu Rajan v. Alastair Crawford (2×) also: Cited "see, e.g."
3rd Cir. · 2022 · signal: see · confidence high
See id. at 23–24.
discussed Cited "see" JACOVETTI LAW P.C. v. SHELTON (2×)
E.D. Pa. · 2020 · signal: see · confidence high
See Schanne v. Addis, 121 A.3d 942, 947 (Pa. 2015).
cited Cited "see" Bush, M. v. Lawrence, T.
Pa. Super. Ct. · 2019 · signal: see · confidence high
See generally, Schanne v. Addis, 121 A.3d 942, 945 (Pa. 2015).
cited Cited "see" Robert Schanne v. Jenna Addis
3rd Cir. · 2015 · signal: see · confidence high
See Schanne v. Addis, No. 106 MAP 2014, 121 A.3d 942, 949-53 , 2015 WL 4920770 , at *7-9 (Pa. Aug. 17, 2015).
cited Cited "see, e.g." United States v. Harris, M., Aplt.
Pa. · 2023 · signal: see, e.g. · confidence medium
See, e.g., Shanne v. Addis, 121 A.3d 942, 943-44 (Pa. 2015).
discussed Cited "see, e.g." AGM Investors, LLC v. Business Law Group, P.A. (2×)
Fla. Dist. Ct. App. · 2017 · signal: see, e.g. · confidence low
See, e.g., Schanne v. Addis, 632 Pa. 545 , 121 A.3d 942, 949-51 (2015) *926 (holding that absolute privilege does not extend to statements before commencement of a quasi-judicial proceeding without intent that it lead to one); Mansfield v. Bernabei, 284 Va. 116 , 727 S.E.2d 69, 75 (2012) (adopting rule requiring that absolute privilege extends to communications preliminary to litigation that is contemplated in good faith and under serious consideration); Smith v. Suburban Rests., Inc., 374 Mass. 528 , 378 N.E.2d 215 , 218 (1978) (holding that denial of summary judgment on privilege grounds was…
Retrieving the full opinion text from the archive…
COMMONWEALTH of Pennsylvania
v.
Mark William MILLER
No. 83 MM 2015.
Supreme Court of Pennsylvania.
Jul 8, 2015.
121 A.3d 942
Published

ORDER

PER CURIAM.

AND NOW, this 8th day of July, 2015, the Application for Leave to File Original Process is GRANTED, and the Petition for Writ of Habeas Corpus is DENIED.