first two factors (Pennsylvania) · Go Syfert
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first two factors in Pennsylvania

26 Pennsylvania opinions name it 4 courts 1973–2025 8 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 (12)

CaseFollowedCited
Strawn v. Commonwealthgreen
pa · 2009 · cited in 11 Pennsylvania opinions naming this issue, 2014–2025
2 sentences

2024In applying these factors to appeals where a trial court has dismissed an action for non-compliance with a discovery order, appellate courts “have consistently placed greater emphasis on the first two factors: (1) the prejudice to the non-offending party and the ability to cure that prejudice; and (2) the willfulness of the offending party’s conduct.” Id. at 1271 .

2024In applying these factors to appeals where a trial court has dismissed an action for non-compliance with a discovery order, appellate courts “have consistently placed greater emphasis on the first two factors: (1) the prejudice to the non-offending party and the ability to cure that prejudice; and (2) the willfulness of the offending party’s conduct.” Id. at 1271 .

211
Commonwealth v. Hillgreen
pasuperct · 2012 · cited in 2 Pennsylvania opinions naming this issue, 2014–2015
2 sentences

2015See Hill, 42 A.3d at 1095 n.9; see also Hill, 104 A.3d at 1248 n.3 (Eakin, J., Concurring). - 16 - J-S53015-15 Applying the remaining two factors announced in León–Delfis to the case at bar, our review of the record reveals that it bears no resemblance to that case.

2014The panel then concluded, apparently as a matter of law based on its application of the Leon-Delfis factors, that appellee did not waive his right to counsel for purposes of the post-polygraph interview. 42 A.3d at 1095-97 .

12
Commonwealth v. Wexlergreen
pa · 1981 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
1 sentence

2025See, e.g., Adams, 317 A.3d at 645-46 (reviewing the Wexler factors and concluding that trial court abused its discretion in denying expungement because the ____________________________________________ 2 In Wexler, the court determined that the first two factors—the strength of the case against the petitioner and the reasons given for maintaining the record—weighed in favor of granting expungement and, thus, only considered those two factors in determining that the lower court abused its discretion in denying expungement. 431 A.2d at 880-81 . -4- J-A01009-25 Commonwealth had provided only polic

11
Com. v. Adams, J.green
pasuperct · 2024 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
1 sentence

2025See, e.g., Adams, 317 A.3d at 645-46 (reviewing the Wexler factors and concluding that trial court abused its discretion in denying expungement because the ____________________________________________ 2 In Wexler, the court determined that the first two factors—the strength of the case against the petitioner and the reasons given for maintaining the record—weighed in favor of granting expungement and, thus, only considered those two factors in determining that the lower court abused its discretion in denying expungement. 431 A.2d at 880-81 . -4- J-A01009-25 Commonwealth had provided only polic

11
Commonwealth v. Motogreen
pa · 2011 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
1 sentence

2025When the Commonwealth admits that it will be unable to bear its burden of proof beyond a reasonable doubt at trial, the Commonwealth “bear[s] the burden of justifying why the arrest record should not be expunged.” Commonwealth v. Moto, 23 A.3d 989, 994 (Pa. 2011) (citation omitted).

11
Commonwealth v. Legeregreen
pacommwct · 2012 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
1 sentence

2024If there were any doubt as to the first two factors, the Requests make it clear that Requester has adequately specified the records Requester seeks—in other words, the three factors, considered together, evince a sufficiently specific request because the Requests seek “a clearly-defined universe of documents.” Dep’t of Env’t Prot. v. Legere, 50 A.3d 260, 265 (Pa. Cmwlth. 2012).

11
Wilson, A. v. Parker, C.green
pasuperct · 2020 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
1 sentence

2021See id.

11
Stewart v. Rossigreen
pasuperct · 1996 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
2 sentences

2016See, e.g., Stewart v. Rossi, 452 Pa.Super. 120 , 681 A.2d 214, 217 (1996), appeal denied, 689 A.2d 235 (Pa. 1997) (holding that because “dismissal is the most severe sanction, it should be imposed only in extreme circumstances, and a trial court is required to balance the equities carefully and dismiss only when the violation of the discovery rules is willful and the opposing party has been prejudiced.”).

2016See, e.g., Stewart v. Rossi, 452 Pa.Super. 120 , 681 A.2d 214, 217 (1996), appeal denied, 689 A.2d 235 (Pa. 1997) (holding that because “dismissal is the most severe sanction, it should be imposed only in extreme circumstances, and a trial court is required to balance the equities carefully and dismiss only when the violation of the discovery rules is willful and the opposing party has been prejudiced.”).

11
Commonwealth v. Tinsleygreen
pa · 2012 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
1 sentence

2015When reviewing sufficiency of the evidence claims, “we must determine whether the evidence admitted at trial, as well as all reasonable inferences drawn therefrom, when viewed in the light most favorable to the verdict winner, are sufficient to support all elements of the offense.” Commonwealth v. Cox, 72 A.3d 719, 721 (Pa. Super. 2013) (quoting Commonwealth v. Koch, 39 A.3d 996, 1001 (Pa. Super. 2011)).

11
Commonwealth v. Coxgreen
pasuperct · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
1 sentence

2015When reviewing sufficiency of the evidence claims, “we must determine whether the evidence admitted at trial, as well as all reasonable inferences drawn therefrom, when viewed in the light most favorable to the verdict winner, are sufficient to support all elements of the offense.” Commonwealth v. Cox, 72 A.3d 719, 721 (Pa. Super. 2013) (quoting Commonwealth v. Koch, 39 A.3d 996, 1001 (Pa. Super. 2011)).

11
Commonwealth, Aplt v. Hill, E.green
pa · 2014 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
1 sentence

2015See Hill, 42 A.3d at 1095 n.9; see also Hill, 104 A.3d at 1248 n.3 (Eakin, J., Concurring). - 16 - J-S53015-15 Applying the remaining two factors announced in León–Delfis to the case at bar, our review of the record reveals that it bears no resemblance to that case.

11
Commonwealth v. Hermangreen
pasuperct · 1981 · cited in 1 Pennsylvania opinions naming this issue, 1982–1982
1 sentence

1982Commonwealth v. Herman, 288 Pa.Superior Ct. 219, 230, 431 A.2d 1016, 1022 (1981).

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 (10)

CaseCitedYears
Com. v. AMR green
pasuperct · 2005
2 sentences

2009We do not comment on the court’s finding that the Commonwealth’s case was strong, 2 but we do note that the court in A.M.R. recognized that “[t]he ‘future case’ argument is similarly unpersuasive: the Supreme Court in Wexler expressly rejected the argument that a general interest in maintaining an arrest record overrides the individual’s interest in expungement.” A.M.R., 887 A.2d at 1270 .

2009We do not comment on the court's finding that the Commonwealth's case was strong, [2] but we do note that the court in A.M.R. recognized that "[t]he `future case' argument is similarly unpersuasive: the Supreme Court in Wexler expressly rejected the argument that a general interest in maintaining an arrest record overrides the individual's interest in expungement." A.M.R., 887 A.2d at 1270 .

22009–2009
Hoss Land Co. v. Thorson, R. green
pasuperct · 2024
1 sentence

2024City of Philadelphia, 985 A.2d at 1271 ; Hoss Land Co. v. Thorson, ___ A.3d ___, 2024 PA Super 198 , *7 (Pa. Super., filed Sept. 5, 2024).

12024–2024
Elkins v. United States green
scotus · 1960
1 sentence

2020Id.

12020–2020
In Re Estate of Janosky green
pasuperct · 2003
2 sentences

2017Appellants only dispute that Sister proved the third factor, ie., that “when .the testator died, the will remained undestroyed or revoked.” Janosky, supra, 827 A.2d at 520 , citing Burns v. Kabboul, supra. See Appellants’ Brief at 10.

2017Appellants only dispute that Sister proved the third factor, ie., that “when .the testator died, the will remained undestroyed or revoked.” Janosky, supra, 827 A.2d at 520 , citing Burns v. Kabboul, supra. See Appellants’ Brief at 10.

12017–2017
Montejo v. Louisiana green
scotus · 2009
2 sentences

2014The panel noted, however, that because of subsequent U.S. Supreme Court precedent, “the significance of the first two factors listed in Leon-Delfis , has essentially been negated.” Id. at 1095 n. 9 (citing Montejo v. Louisiana, 556 U.S. 778 , 129 S.Ct. 2079 , 173 L.Ed.2d 955 (2009)).

2014The panel noted, however, that because of subsequent U.S. Supreme Court precedent, “the significance of the first two factors listed in Leon-Delfis , has essentially been negated.” Id. at 1095 n. 9 (citing Montejo v. Louisiana, 556 U.S. 778 , 129 S.Ct. 2079 , 173 L.Ed.2d 955 (2009)).

12014–2014
United States v. Leon-Delfis green
ca1 · 2000
2 sentences

2014The panel noted, however, that because of subsequent U.S. Supreme Court precedent, “the significance of the first two factors listed in Leon-Delfis , has essentially been negated.” Id. at 1095 n. 9 (citing Montejo v. Louisiana, 556 U.S. 778 , 129 S.Ct. 2079 , 173 L.Ed.2d 955 (2009)).

2014The panel noted, however, that because of subsequent U.S. Supreme Court precedent, “the significance of the first two factors listed in Leon- Delfis, has essentially been negated.” Id. at 1095 n.9 (citing Montejo v. Louisiana, 556 U.S. 778 (2009)).

12014–2014
Commonwealth v. Turza green
pa · 1940
1 sentence

2010“The corpus delicti of a crime consists of the first two factors or elements.” Id. (internal citations omitted).

12010–2010
Commonwealth v. May green
pa · 1973
2 sentences

1981In establishing a criminal case, it is incumbent upon the Commonwealth to show: “(1) that a loss has occurred; *231 (2) that the loss occurred through a criminal agency, and (3) that the accused was, in fact, the perpetrator of the deed.” Commonwealth v. May, 451 Pa. 31 , 301 A.2d 368 (1973); Commonwealth v. Burns, supra. The corpus delicti of a crime consists of the first two factors or elements.

1981In establishing a criminal case, it is incumbent upon the Commonwealth to show: “(1) that a loss has occurred; *231 (2) that the loss occurred through a criminal agency, and (3) that the accused was, in fact, the perpetrator of the deed.” Commonwealth v. May, 451 Pa. 31 , 301 A.2d 368 (1973); Commonwealth v. Burns, supra. The corpus delicti of a crime consists of the first two factors or elements.

11981–1981
Commonwealth v. Rhoads green
pasuperct · 1973
2 sentences

1981Commonwealth v. May, supra; Commonwealth v. Rhoads, 225 Pa.Super. 208 , 310 A.2d 406 (1973).

1981Commonwealth v. May, supra; Commonwealth v. Rhoads, 225 Pa.Super. 208 , 310 A.2d 406 (1973).

11981–1981
Commonwealth v. Dial green
pasuperct · 1971
2 sentences

1973In Commonwealth v. Dial, 218 Pa. Superior Ct. 248 , 276 A.2d 314 (1971), we held that the mere detailing of an accused’s previous arrests for narcotics violations plus the occurrence of numerous meetings between an accused and known narcotics dealers and users was an insufficient basis from which a magistrate could conclude that the accused was in possession of narcotics.

1973In Commonwealth v. Dial, 218 Pa. Superior Ct. 248 , 276 A.2d 314 (1971), we held that the mere detailing of an accused’s previous arrests for narcotics violations plus the occurrence of numerous meetings between an accused and known narcotics dealers and users was an insufficient basis from which a magistrate could conclude that the accused was in possession of narcotics.

11973–1973

Where else courts name it

KS 113 (2004–2025) IL 82 (1981–2026) TX 77 (1972–2025) CA 65 (1980–2026) NM 40 (1988–2025) WA 38 (1973–2026) NY 26 (1979–2025) PA 26 (1973–2025) MI 20 (1987–2025) OH 19 (1981–2025) OR 18 (1981–2025) WI 16 (1975–2025) NJ 15 (1986–2025) UT 14 (1993–2022) GA 14 (2002–2026) FL 12 (1936–2015) MS 12 (1991–2022) MN 11 (1986–2016) IA 11 (1996–2024) NV 10 (2017–2022) MD 9 (1979–2025) IN 9 (1992–2019) MA 8 (2001–2026) MO 8 (1989–2023) AZ 8 (2006–2025) AL 6 (2005–2015) MT 6 (1999–2026) NC 6 (1998–2024) CT 6 (1995–2012) LA 6 (1996–2026) WY 5 (1992–2025) HI 5 (2009–2026) ND 5 (2004–2019) TN 5 (1999–2016) NH 5 (2006–2022) WV 4 (2005–2020) VT 4 (2009–2025) VA 4 (2005–2022) CO 3 (1997–2021) SD 3 (1999–2025) DE 3 (2018–2023) NE 3 (1998–2021) SC 2 (2025–2025) DC 2 (1997–2009) ID 2 (2020–2025)

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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