palpable error (Pennsylvania) · Go Syfert
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palpable error in Pennsylvania

28 Pennsylvania opinions name it 5 courts 1910–2025 3 in the last five years

The cases below were cited by Pennsylvania courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (15)

CaseFollowedCited
United States v. Tsarnaevgreen
scotus · 2022 · cited in 2 Pennsylvania opinions naming this issue, 2025–2025
2 sentences

2025In contrast, the Commonwealth emphasizes that the scope of voir dire rests within the discretion of the trial court and “refusal to permit certain questions … will not be disturbed absent a palpable error.” Commonwealth’s Brief at 10 (citing Holt, 273 A.3d at 547); see also id. at 11 (citing United States v. Tsarnaev, 595 U.S. 302, 314 (2022) (reversing intermediate appellate court’s decision to mandate specific questions on voir dire)).

2025In contrast, the Commonwealth emphasizes that the scope of voir dire rests within the discretion of the trial court and “refusal to permit certain questions … will not be disturbed absent a palpable error.” Commonwealth’s Brief at 10 (citing Holt, 273 A.3d at 547); see also id. at 11 (citing United States v. Tsarnaev, 595 U.S. 302, 314 (2022) (reversing intermediate appellate court’s decision to mandate specific questions on voir dire)).

22
Commonwealth v. Johnsongreen
pa · 1973 · cited in 2 Pennsylvania opinions naming this issue, 2025–2025
2 sentences

2025Throughout, it highlights cases where this Court has “rejected efforts to strip the trial court of discretion to determine the propriety of proposed juror questions.” Id. at 12 (citing inter alia Commonwealth v. Johnson, 305 A.2d 5, 8 (Pa. 1973) (affirming trial court’s exercise of discretion in declining to question jurors regarding whether they were inclined to believe psychologists)).

2025Throughout, it highlights cases where this Court has “rejected efforts to strip the trial court of discretion to determine the propriety of proposed juror questions.” Id. at 12 (citing inter alia Commonwealth v. Johnson, 305 A.2d 5, 8 (Pa. 1973) (affirming trial court’s exercise of discretion in declining to question jurors regarding whether they were inclined to believe psychologists)).

22
Commonwealth v. O'Briengreen
pa · 1933 · cited in 10 Pennsylvania opinions naming this issue, 1934–1974
2 sentences

1974Citing Commonwealth v. O’Brien, 312 Pa. 543, 546 , 168 A. 244, 245 (1933), the court found such a basic and fundamental error, noting that “[a] man is not to be deprived of his liberty and reputation because of the inadvertence of a trial judge or the carelessness of his counsel in failing to call the attention of the trial court to palpable error which offends against the fundamentals of a fair and impartial trial.” 216 Pa. Superior Ct. at 160 n. 1, 264 A. 2d at 181 n. 1.

1974Citing Commonwealth v. O’Brien, 312 Pa. 543, 546 , 168 A. 244, 245 (1933), the court found such a basic and fundamental error, noting that “[a] man is not to be deprived of his liberty and reputation because of the inadvertence of a trial judge or the carelessness of his counsel in failing to call the attention of the trial court to palpable error which offends against the fundamentals of a fair and impartial trial.” 216 Pa. Superior Ct. at 160 n. 1, 264 A. 2d at 181 n. 1.

110
COM., DEPT. OF TRANSP. v. Emerygreen
pacommwct · 1990 · cited in 1 Pennsylvania opinions naming this issue, 2022–2022
1 sentence

2022(Respondent’s Application for Relief ¶ 8.) A single judge of this Court accepted Respondent’s explanation as sufficient, and, as a breakdown in a court’s operation may be a basis for granting nunc pro tunc relief, Department of Transportation, Bureau of Driver Licensing v. Emery, 580 A.2d 909, 912 (Pa. Cmwlth. 1990), we will not say this was palpable error.

11
Commonwealth v. Rovinskigreen
pasuperct · 1997 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
1 sentence

2015Commonwealth v. Rovinski, 704 A.2d 1068, 1073 (Pa. Super. 1997), appeal denied, 723 A.2d 1024 (Pa. 1998) (citations and quotation marks omitted).

11
Commonwealth v. Canalesgreen
pa · 1973 · cited in 1 Pennsylvania opinions naming this issue, 2014–2014
2 sentences

2014“The reason for the prohibition is that the presence in the jury room of the physical embodiment of a portion of the trial testimony in written form may have the effect of increasing the probability that the jury will accept the testimony as credible.” Commonwealth v. Canales, 454 Pa. 422 , 311 A.2d 572, 575 (1973).

2014“The reason for the prohibition is that the presence in the jury room of the physical embodiment of a portion of the trial testimony in written form may have the effect of increasing the probability that the jury will accept the testimony as credible.” Commonwealth v. Canales, 454 Pa. 422 , 311 A.2d 572, 575 (1973).

11
Commonwealth v. Waregreen
· 1890 · cited in 1 Pennsylvania opinions naming this issue, 2014–2014
2 sentences

2014See Commonwealth v. Ware, 137 Pa. 465 , 20 A. 806, 808 (1890) (“The sending out of a part of the testimo ny to the jury room ... would have been a palpable error.”); Pa.R.Crim.P. 646(C)(1).

2014See Commonwealth v. Ware, 137 Pa. 465 , 20 A. 806, 808 (1890) (“The sending out of a part of the testimo ny to the jury room ... would have been a palpable error.”); Pa.R.Crim.P. 646(C)(1).

11
Zane v. Friends Hospitalgreen
pa · 2003 · cited in 1 Pennsylvania opinions naming this issue, 2005–2005
2 sentences

2005This holding has itself been overruled when the prior judge makes a palpable error of law in Zane v. Friends Hospital, 575 Pa. 236, 244, 836 A.2d 25, 30 (2003). .

2005This holding has itself been overruled when the prior judge makes a palpable error of law in Zane v. Friends Hospital, 575 Pa. 236, 244, 836 A.2d 25, 30 (2003). .

11
Commonwealth v. Boringgreen
pasuperct · 1996 · cited in 1 Pennsylvania opinions naming this issue, 1997–1997
2 sentences

1997Id, at 137, 501 A.2d at 236 ; see also Commonwealth v. Boring, 453 Pa.Super. 600, 611-12 , 684 A.2d 561, 566 (1996).

1997Id, at 137, 501 A.2d at 236 ; see also Commonwealth v. Boring, 453 Pa.Super. 600, 611-12 , 684 A.2d 561, 566 (1996).

11
Commonwealth v. Proctorgreen
pa · 1991 · cited in 1 Pennsylvania opinions naming this issue, 1996–1996
2 sentences

1996Commonwealth v. Proctor, 526 Pa. 246, 257-59 , 585 A.2d 454, 460 (1991).

1996Commonwealth v. Proctor, 526 Pa. 246, 257-59 , 585 A.2d 454, 460 (1991).

11
Commonwealth v. Lanegreen
pa · 1989 · cited in 1 Pennsylvania opinions naming this issue, 1992–1992
2 sentences

1992Commonwealth v. Lane, 521 Pa. 390 , 555 A.2d 1246, 1249-50 (1989) (decisions regarding the striking of venire persons rests in the sound discretion of trial judge and will not be overturned absent a palpable error).

1992Commonwealth v. Lane, 521 Pa. 390 , 555 A.2d 1246, 1249-50 (1989) (decisions regarding the striking of venire persons rests in the sound discretion of trial judge and will not be overturned absent a palpable error).

11
Commonwealth v. Smithgreen
pasuperct · 1970 · cited in 1 Pennsylvania opinions naming this issue, 1974–1974
2 sentences

1974See also Commonwealth v. Smith, 217 Pa. Superior Ct. 148 , 269 A. 2d 138 (1970).

1974See also Commonwealth v. Smith, 217 Pa. Superior Ct. 148 , 269 A. 2d 138 (1970).

11
Commonwealth v. Birdgreen
pasuperct · 1943 · cited in 1 Pennsylvania opinions naming this issue, 1951–1951
11
Commonwealth v. Jodlowskygreen
pasuperct · 1948 · cited in 1 Pennsylvania opinions naming this issue, 1951–1951
11
Commonwealth v. Wiandgreen
pasuperct · 1942 · cited in 1 Pennsylvania opinions naming this issue, 1951–1951
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway.

Also cited on this issue (39)

CaseCitedYears
Commonwealth v. Merrick green
pa · 1985
2 sentences

2018Commonwealth v. Merrick , 338 Pa.Super. 495 , 488 A.2d 1 , 3 (1985) (citations omitted).

2018Commonwealth v. Merrick , 338 Pa.Super. 495 , 488 A.2d 1 , 3 (1985) (citations omitted).

12018–2018
Commonwealth v. Berrigan green
pa · 1985
1 sentence

1997Id, at 137, 501 A.2d at 236 ; see also Commonwealth v. Boring, 453 Pa.Super. 600, 611-12 , 684 A.2d 561, 566 (1996).

11997–1997
Boykins v. City of Reading green
pacommwct · 1989
2 sentences

1990The appellant relies on Boykins v. City of Reading, 128 Pa.Cmwlth. 154 , 562 A.2d 1027 (1989) to support its view that the court below based its decision on a palpable error of law.

1990The appellant relies on Boykins v. City of Reading, 128 Pa.Cmwlth. 154 , 562 A.2d 1027 (1989) to support its view that the court below based its decision on a palpable error of law.

11990–1990
Commonwealth v. Richardson neutral
pasuperct · 1983
2 sentences

1985Commonwealth v. Richardson, 315 Pa.Super. 349 , 461 A.2d 1315 (1983); Commonwealth v. Bossick, 305 Pa.Super. 196 , 451 A.2d 489 (1982).

1985Commonwealth v. Richardson, 315 Pa.Super. 349 , 461 A.2d 1315 (1983); Commonwealth v. Bossick, 305 Pa.Super. 196 , 451 A.2d 489 (1982).

11985–1985
Commonwealth v. Bossick green
pasuperct · 1982
2 sentences

1985Commonwealth v. Richardson, 315 Pa.Super. 349 , 461 A.2d 1315 (1983); Commonwealth v. Bossick, 305 Pa.Super. 196 , 451 A.2d 489 (1982).

1985Commonwealth v. Richardson, 315 Pa.Super. 349 , 461 A.2d 1315 (1983); Commonwealth v. Bossick, 305 Pa.Super. 196 , 451 A.2d 489 (1982).

11985–1985
Commonwealth v. Yahnert neutral
pasuperct · 1970
2 sentences

1974Citing Commonwealth v. O'Brien, 312 Pa. 543, 546 , 168 A. 244, 245 (1933), the court found such a basic and fundamental error, noting that "[a] man is not to be deprived of his liberty and reputation because of the inadvertence of a trial judge or the carelessness of his counsel in failing to call the attention of the trial court to palpable error which offends against the fundamentals of a fair and impartial trial." 216 Pa. Superior Ct. at 160 n. 1, 264 A. 2d at 181 n. 1.

1974Citing Commonwealth v. O’Brien, 312 Pa. 543, 546 , 168 A. 244, 245 (1933), the court found such a basic and fundamental error, noting that “[a] man is not to be deprived of his liberty and reputation because of the inadvertence of a trial judge or the carelessness of his counsel in failing to call the attention of the trial court to palpable error which offends against the fundamentals of a fair and impartial trial.” 216 Pa. Superior Ct. at 160 n. 1, 264 A. 2d at 181 n. 1.

11974–1974
Philadelphia Suburban Transportation Co. Application green
pasuperct · 1970
2 sentences

1974Citing Commonwealth v. O'Brien, 312 Pa. 543, 546 , 168 A. 244, 245 (1933), the court found such a basic and fundamental error, noting that "[a] man is not to be deprived of his liberty and reputation because of the inadvertence of a trial judge or the carelessness of his counsel in failing to call the attention of the trial court to palpable error which offends against the fundamentals of a fair and impartial trial." 216 Pa. Superior Ct. at 160 n. 1, 264 A. 2d at 181 n. 1.

1974Citing Commonwealth v. O’Brien, 312 Pa. 543, 546 , 168 A. 244, 245 (1933), the court found such a basic and fundamental error, noting that “[a] man is not to be deprived of his liberty and reputation because of the inadvertence of a trial judge or the carelessness of his counsel in failing to call the attention of the trial court to palpable error which offends against the fundamentals of a fair and impartial trial.” 216 Pa. Superior Ct. at 160 n. 1, 264 A. 2d at 181 n. 1.

11974–1974
Commonwealth v. Williams green
pa · 1968
2 sentences

1970Commonwealth v. Williams, 432 Pa. 557 , 248 A. 2d 301 (1968); Patterson v. Pittsburgh Rys.

1970Commonwealth v. Williams, 432 Pa. 557 , 248 A. 2d 301 (1968); Patterson v. Pittsburgh Rys.

11970–1970
Miller Et Ux. v. Dierken green
pasuperct · 1944
2 sentences

1970In civil cases, moreover, we have considered the plea of res judicata, although not raised below. “[T]he doctrine of res judicata, predicated on the fundamental ground of public policy, may operate as a bar although not specifically raised by the'parties in the court below.” Miller v. Dierken, 157 Pa. Superior Ct. 69, 72 , 41 A. 2d 438 (1945) (Rhodes, J.).

1970In civil cases, moreover, we have considered the plea of res judicata, although not raised below. “[T]he doctrine of res judicata, predicated on the fundamental ground of public policy, may operate as a bar although not specifically raised by the'parties in the court below.” Miller v. Dierken, 157 Pa. Superior Ct. 69, 72 , 41 A. 2d 438 (1945) (Rhodes, J.).

11970–1970
STANDER v. Kelley neutral
pa · 1968
2 sentences

1969An appeal was taken to this Court, which affirmed the dismissal of the preliminary injunction on the ground that the Court below had not committed a clear abuse of discretion or a palpable error of law: Stander v. Kelley, 432 Pa. 1 , 246 A. 2d 649 .

1969An appeal was taken to this Court, which affirmed the dismissal of the preliminary injunction on the ground that the Court below had not committed a clear abuse of discretion or a palpable error of law: Stander v. Kelley, 432 Pa. 1 , 246 A. 2d 649 .

11969–1969
Schmitt v. City of Philadelphia green
pa · 1915
1 sentence

1968However, in a homicide case, [**] where a defendant's life or liberty is at stake, and where defendant may have been deprived of a fair and impartial trial, or suffered manifest injustice, [because of basic and fundamental error] an appellate court will review the case notwithstanding the failure of defendant's counsel to take proper exceptions: Commonwealth v. Scott, 284 Pa. 159, 162 , 130 A. 317 ; Commonwealth v. Corrie, 302 Pa. 431, 436 , 153 A. 743 ." In Commonwealth v. Smith, 374 Pa., supra, the Court expressed the rule at page 225: "It first should be noted that only a general exception

11968–1968
White v. Moore green
· 1927
1 sentence

1968Commonwealth v. Stowers, 363 Pa., supra; Commonwealth v. O'Brien, 312 Pa., supra. In Commonwealth v. Robinson, 317 Pa., supra, the Court said, (page 323): "And, of course, basic and fundamental error, such as here, will be considered even if not pointed out in the court below: [*] White v. Moore, 288 Pa. 411 . `A man is not to be deprived of *565 his liberty and reputation because of the inadvertence of a trial judge or the carelessness of his counsel in failing to call the attention of the trial court to palpable error which offends against the fundamentals of a fair and impartial trial': Com

11968–1968
Marlowe v. Travelers Insurance Co. green
pa · 1933
1 sentence

1968However, in a homicide case, [**] where a defendant's life or liberty is at stake, and where defendant may have been deprived of a fair and impartial trial, or suffered manifest injustice, [because of basic and fundamental error] an appellate court will review the case notwithstanding the failure of defendant's counsel to take proper exceptions: Commonwealth v. Scott, 284 Pa. 159, 162 , 130 A. 317 ; Commonwealth v. Corrie, 302 Pa. 431, 436 , 153 A. 743 ." In Commonwealth v. Smith, 374 Pa., supra, the Court expressed the rule at page 225: "It first should be noted that only a general exception

11968–1968
Commonwealth v. Corrie green
pa · 1930
2 sentences

1968However, in a homicide case, [**] where a defendant's life or liberty is at stake, and where defendant may have been deprived of a fair and impartial trial, or suffered manifest injustice, [because of basic and fundamental error] an appellate court will review the case notwithstanding the failure of defendant's counsel to take proper exceptions: Commonwealth v. Scott, 284 Pa. 159, 162 , 130 A. 317 ; Commonwealth v. Corrie, 302 Pa. 431, 436 , 153 A. 743 ." In Commonwealth v. Smith, 374 Pa., supra, the Court expressed the rule at page 225: "It first should be noted that only a general exception

1968However, in a homicide case, [**] where a defendant's life or liberty is at stake, and where defendant may have been deprived of a fair and impartial trial, or suffered manifest injustice, [because of basic and fundamental error] an appellate court will review the case notwithstanding the failure of defendant's counsel to take proper exceptions: Commonwealth v. Scott, 284 Pa. 159, 162 , 130 A. 317 ; Commonwealth v. Corrie, 302 Pa. 431, 436 , 153 A. 743 ." In Commonwealth v. Smith, 374 Pa., supra, the Court expressed the rule at page 225: "It first should be noted that only a general exception

11968–1968
Commonwealth v. Scott green
pa · 1925
2 sentences

1968However, in a homicide case, [**] where a defendant's life or liberty is at stake, and where defendant may have been deprived of a fair and impartial trial, or suffered manifest injustice, [because of basic and fundamental error] an appellate court will review the case notwithstanding the failure of defendant's counsel to take proper exceptions: Commonwealth v. Scott, 284 Pa. 159, 162 , 130 A. 317 ; Commonwealth v. Corrie, 302 Pa. 431, 436 , 153 A. 743 ." In Commonwealth v. Smith, 374 Pa., supra, the Court expressed the rule at page 225: "It first should be noted that only a general exception

1968However, in a homicide case, [**] where a defendant's life or liberty is at stake, and where defendant may have been deprived of a fair and impartial trial, or suffered manifest injustice, [because of basic and fundamental error] an appellate court will review the case notwithstanding the failure of defendant's counsel to take proper exceptions: Commonwealth v. Scott, 284 Pa. 159, 162 , 130 A. 317 ; Commonwealth v. Corrie, 302 Pa. 431, 436 , 153 A. 743 ." In Commonwealth v. Smith, 374 Pa., supra, the Court expressed the rule at page 225: "It first should be noted that only a general exception

11968–1968
Levy Motor Vehicle Operator License Case green
pasuperct · 1961
1 sentence

1961For the reasons set forth in Levy Motor Vehicle Operator License Case, 191 Pa. Superior Ct. 390 , 169 A. 2d 596 (1960L), the court below must be reversed.

11961–1961
Anundson Construction & Building Supply Co. v. Emporium Area Joint School Authority neutral
pasuperct · 1959
1 sentence

1961For the reasons set forth in Levy Motor Vehicle Operator License Case, 191 Pa. Superior Ct. 390 , 169 A. 2d 596 (1960L), the court below must be reversed.

11961–1961
Commonwealth v. Robinson green
pa · 1934
2 sentences

1951In the ringing words of Mr. Justice (now Chief Justice) Drew in Commonwealth v. O’Brien, 312 Pa. 543, 546 , 168 A. 244 , 245: “A man is not to be deprived of Mg liberty and reputation because of the inadvertence of a trial judge or the carelessness of Ms counsel in failing to call the attention of the trial court to palpable error which offends against the fundamentals of a fair and impartial trial.” The principle-thus stated has since been followed in numerous cases both in our own and the Superior Court: Commonwealth v. Robinson, 317 Pa. 321, 323 , 176 A. 908, 909 ; Commonwealth v. Wiand, 15

1951In the ringing words of Mr. Justice (now Chief Justice) Drew in Commonwealth v. O’Brien, 312 Pa. 543, 546 , 168 A. 244 , 245: “A man is not to be deprived of Mg liberty and reputation because of the inadvertence of a trial judge or the carelessness of Ms counsel in failing to call the attention of the trial court to palpable error which offends against the fundamentals of a fair and impartial trial.” The principle-thus stated has since been followed in numerous cases both in our own and the Superior Court: Commonwealth v. Robinson, 317 Pa. 321, 323 , 176 A. 908, 909 ; Commonwealth v. Wiand, 15

11951–1951
Commonwealth v. Gold Et Ux. green
pasuperct · 1944
11951–1951
Commonwealth v. O'Toole green
pasuperct · 1946
11951–1951
Commonwealth v. Balles green
pasuperct · 1946
11951–1951
Myers & Murray v. Commonwealth neutral
pa · 1875
11936–1936
Commonwealth v. Powell neutral
pasuperct · 1903
11936–1936
Commonwealth v. Major green
pa · 1901
11936–1936
Commonwealth v. Tassone green
pa · 1914
11936–1936
Stevenson v. Mellor green
pa · 1914
11936–1936
Pinney v. Brown green
conn · 1891
11933–1933
Shubert v. State neutral
miss · 1889
11913–1913
State v. Reynolds neutral
moctapp · 1903
11913–1913
Commonwealth v. Brown green
pasuperct · 1903
11913–1913
Clark v. Commonwealth neutral
pa · 1889
11913–1913
Commonwealth v. Crossmire green
pa · 1893
11913–1913
Commonwealth v. Roddy green
pa · 1898
11913–1913
Commonwealth v. Eagan green
pa · 1899
11913–1913
Commonwealth v. Spahr green
pa · 1905
11913–1913
Commonwealth v. Payne green
pa · 1903
11913–1913
State v. . Jones neutral
nc · 1887
11913–1913
Asevado v. Orr green
cal · 1893
11913–1913
Commonwealth v. Gearhardt neutral
pa · 1903
11910–1910

Where else courts name it

KY 496 (1837–2026) MI 125 (1865–2026) PA 28 (1910–2025) MO 23 (1873–2019) AR 14 (1888–2020) NY 12 (1897–2024) CT 11 (1956–2017) IN 10 (1891–1980) CA 8 (1889–2000) LA 8 (1922–2025) AL 8 (1848–2025) KS 6 (1888–2019) VA 6 (1876–2011) IL 5 (1883–1920) CO 5 (1969–2002) WV 5 (1895–1975) UT 4 (1941–2017) MD 3 (1913–1987) NM 3 (1940–1999) OR 3 (1903–1953) FL 3 (1978–2004) MN 3 (1905–1957) NH 2 (2012–2025) MA 2 (1828–1976) NV 2 (1915–1994) OH 2 (1905–2025) HI 2 (2009–2024) WI 2 (1883–1927) TN 2 (1934–1998) SD 2 (1910–1931)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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