thirty-day rule (Pennsylvania) · Go Syfert
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thirty-day rule in Pennsylvania

21 Pennsylvania opinions name it 4 courts 1965–2026 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 (10)

CaseFollowedCited
McGuigen Estategreen
pa · 1957 · cited in 3 Pennsylvania opinions naming this issue, 1965–1974
2 sentences

1974See McGuigen Estate, 388 Pa. 475 , 131 A.2d 124 (1957); Comments of the Joint State Government Commission, Comment to § 7(1), 20 P.S.

1974See McGuigen Estate, 388 Pa. 475 , 131 A.2d 124 (1957); Comments of the Joint State Government Commission, Comment to § 7(1), 20 P.S.

33
Commonwealth v. Wrightgreen
pasuperct · 2004 · cited in 2 Pennsylvania opinions naming this issue, 2020–2024
2 sentences

2024Id. at 735 (internal footnote omitted).

2024Id. at 735 (internal footnote omitted).

22
Commonwealth v. Heilmangreen
pasuperct · 1981 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
1 sentence

2026The purpose of the thirty-day rule with respect to extradition proceedings is to prevent a person from languishing in jail without judicial supervision.” Commonwealth v. Heilman, 433 A.2d 83, 85 (Pa. Super. 1981).

11
Commonwealth v. Valentinegreen
pasuperct · 2007 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023See also Commonwealth v. Valentine, 928 A.2d 346, 349 (Pa. Super. 2007) (applying the thirty-day rule).

11
Stockton v. Stocktongreen
pasuperct · 1997 · cited in 1 Pennsylvania opinions naming this issue, 2013–2013
1 sentence

2013Even if considered as a motion subject to the thirty day rule, as this court noted in Fulton v. Bedford County Tax Claim Bureau, 942 A.2d 240 (Pa.Cmwlth.2008): After expiration of the 30-day period, ... the court may only open or vacate an order upon a showing of extrinsic fraud, lack of subject matter jurisdiction, a fatal defect on the face of the record or some other evidence of “extraordinary cause justifying intervention by the court.” Stockton v. Stockton, 698 A.2d 1334, 1337 (Pa.Super.1997).

11
Bellis v. Board of Pensions & Retirementgreen
pacommwct · 1993 · cited in 1 Pennsylvania opinions naming this issue, 2012–2012
1 sentence

2012In that case, “[E]mployer knew that Claimant considered the thirty-day clause to be a crucial term and condition of employment ...”, and “[t]he proposed contract ... stated that [Claimant] was to perform the more difficult job of graphic satellite coordinator for less pay....” Id., 634 A.2d at 821.

11
Klugman v. Gimbel Bros.green
pasuperct · 1962 · cited in 1 Pennsylvania opinions naming this issue, 1988–1988
1 sentence

1988Generally, judgments regularly entered in adverse proceedings cannot be opened or vacated after they have become final, unless there has been fraud or some other circumstance “so grave or compelling as to constitute ‘extraordinary cause’ justifying intervention of the court. ” Id., 350 Pa.Superior Ct. at 245, 504 A.2d at 337 (emphasis supplied) (quoting Klugman v. Gimbel Brothers, Inc., 198 Pa.Superior Ct. 268, 272, 182 A.2d 223, 225 (1962)).

11
Simpson v. Allstate Insurancegreen
pa · 1986 · cited in 1 Pennsylvania opinions naming this issue, 1988–1988
1 sentence

1988Generally, judgments regularly entered in adverse proceedings cannot be opened or vacated after they have become final, unless there has been fraud or some other circumstance “so grave or compelling as to constitute ‘extraordinary cause’ justifying intervention of the court. ” Id., 350 Pa.Superior Ct. at 245, 504 A.2d at 337 (emphasis supplied) (quoting Klugman v. Gimbel Brothers, Inc., 198 Pa.Superior Ct. 268, 272, 182 A.2d 223, 225 (1962)).

11
Commonwealth v. Rowegreen
pasuperct · 1979 · cited in 1 Pennsylvania opinions naming this issue, 1980–1980
2 sentences

1980See Commonwealth v. Rowe, 264 Pa.Super. 67 , 398 A.2d 1060 (1979).

1980See Commonwealth v. Rowe, 264 Pa.Super. 67 , 398 A.2d 1060 (1979).

11
Baum Estategreen
pa · 1965 · cited in 1 Pennsylvania opinions naming this issue, 1969–1969
2 sentences

1969Since the section which we are considering is remedial in nature, we have held that it must be liberally construed in order to effectuate its purpose." Baum Estate, 418 Pa. 404, 410-11 , 211 A. 2d 521, 524 (1965) (emphasis added).

1969Since the section which we are considering is remedial in nature, we have held that it must be liberally construed in order to effectuate its purpose." Baum Estate, 418 Pa. 404, 410-11 , 211 A. 2d 521, 524 (1965) (emphasis added).

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 (9)

CaseCitedYears
Moore Nomination Petition green
pa · 1972
2 sentences

1978Our Supreme Court considered *486 an analogous argument in the case of In re Moore, 447 Pa. 526 , 291 A.2d 531 (1972).

1978Our Supreme Court considered *486 an analogous argument in the case of In re Moore, 447 Pa. 526 , 291 A.2d 531 (1972).

21977–1978
Estate of Easterday Appeal of: Easterday green
pasuperct · 2017
1 sentence

2019Id.

12019–2019
Commonwealth v. Holmes green
pa · 2007
1 sentence

2015Equal protection of the laws requires that the Appellant receive relief pursuant to 42 Pa.C.S.A. § 5505; Commonwealth v. Holmes, 933 A.2d 57 (2007).

12015–2015
Fulton v. Bedford County Tax Claim Bureau green
pacommwct · 2008
1 sentence

2013Even if considered as a motion subject to the thirty day rule, as this court noted in Fulton v. Bedford County Tax Claim Bureau, 942 A.2d 240 (Pa.Cmwlth.2008): After expiration of the 30-day period, ... the court may only open or vacate an order upon a showing of extrinsic fraud, lack of subject matter jurisdiction, a fatal defect on the face of the record or some other evidence of “extraordinary cause justifying intervention by the court.” Stockton v. Stockton, 698 A.2d 1334, 1337 (Pa.Super.1997).

12013–2013
Accu-Weather, Inc. v. Unemployment Compensation Board of Review green
pacommwct · 1993
2 sentences

2012In that case, "[E]mployer knew that Claimant considered the thirty-day clause to be a crucial term and condition of employment ...", and "[t]he proposed contract... stated that [Claimant] was to perform the more difficult job of graphic satellite coordinator for less pay...." Id., 634 A.2d at 821 .

2012In that case, "[E]mployer knew that Claimant considered the thirty-day clause to be a crucial term and condition of employment ...", and "[t]he proposed contract... stated that [Claimant] was to perform the more difficult job of graphic satellite coordinator for less pay...." Id., 634 A.2d at 821 .

12012–2012
J.B. Steven, Inc. v. Department of Transportation green
pacommwct · 1993
2 sentences

1995Steven, Inc. v. Department of Transportation, 156 Pa.Cmwlth. 360 , 627 A.2d 278 (1993). 2 In J.B.

1995Steven, Inc. v. Department of Transportation, 156 Pa.Cmwlth. 360 , 627 A.2d 278 (1993). 2 In J.B.

11995–1995
International Ass'n of Firefighters, Local 463 v. City of Johnstown green
pa · 1976
2 sentences

1994Consistent with [International Association of Firefighters v. City of Johnstown, 468 Pa. 96 , 360 A.2d 197 (1976) ], a party whose representative has acquiesced in the extension of proceedings beyond the thirty days specified in section 4(b) may not be permitted to nullify an award rendered by the binding arbitration procedures mandated by Act 111.

1994Consistent with [International Association of Firefighters v. City of Johnstown, 468 Pa. 96 , 360 A.2d 197 (1976) ], a party whose representative has acquiesced in the extension of proceedings beyond the thirty days specified in section 4(b) may not be permitted to nullify an award rendered by the binding arbitration procedures mandated by Act 111.

11994–1994
Commonwealth v. Murphy green
pasuperct · 1975
2 sentences

1981Commonwealth v. Murphy, 236 Pa.Super. 37 , 344 A.2d 662 (1975).

1981Commonwealth v. Murphy, 236 Pa.Super. 37 , 344 A.2d 662 (1975).

11981–1981
Commonwealth v. Ehret neutral
pacommwct · 1979
2 sentences

1980Department of Transportation v. Ehret, 46 Pa. Commonwealth Ct. 131 , 405 A.2d 1355 (1979).

1980Department of Transportation v. Ehret, 46 Pa. Commonwealth Ct. 131 , 405 A.2d 1355 (1979).

11980–1980

Where else courts name it

TN 66 (1993–2026) TX 22 (1913–2024) PA 21 (1965–2026) MS 18 (1996–2025) OH 17 (1985–2020) MO 17 (1988–2020) FL 16 (1983–2025) NJ 12 (1997–2026) IA 10 (1985–2024) WI 9 (1979–2018) CT 9 (1922–2020) IN 9 (1991–2020) MD 6 (1951–2024) NY 6 (1884–2025) MA 5 (1975–2012) AR 5 (1994–2009) NC 5 (2005–2025) IL 4 (1970–2014) VI 4 (2011–2013) LA 4 (1958–2017) AZ 4 (1997–2019) GA 3 (1983–2016) NM 3 (2003–2021) KS 3 (1976–2008) DC 3 (1995–2017) VA 3 (1999–2001) ID 2 (1997–2001) WV 2 (2018–2018) UT 2 (1983–2000) KY 2 (2020–2020) AK 2 (1993–1996) CO 2 (1992–2003)

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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