waiver of sovereign immunity (Pennsylvania) · Go Syfert
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waiver of sovereign immunity in Pennsylvania

20 Pennsylvania opinions name it 6 courts 1946–2024 7 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 (8)

CaseFollowedCited
Mascaro v. Youth Study Centergreen
pa · 1987 · cited in 3 Pennsylvania opinions naming this issue, 1988–2021
2 sentences

1988The court in Rippy held that a deer on the highway was not a dangerous condition upon which to predicate commonwealth liability, primarily due to the fact that this type of condition was not conceivably correctable, citing Mistecka, supra. 1 Important to note is that the Commonwealth Court, in a footnote to the Rippy case, questioned the validity of its own holding in Mistecka after the Pennsylvania Supreme Court decision in Mascaro v. Youth Study Center, 514 Pa. 351 , 523 A.2d 1118 (1987) 2 Falling along the continuum between the easy question of dangerous conditions actually on the highways

1988The court in Rippy held that a deer on the highway was not a dangerous condition upon which to predicate commonwealth liability, primarily due to the fact that this type of condition was not conceivably correctable, citing Mistecka, supra. 1 Important to note is that the Commonwealth Court, in a footnote to the Rippy case, questioned the validity of its own holding in Mistecka after the Pennsylvania Supreme Court decision in Mascaro v. Youth Study Center, 514 Pa. 351 , 523 A.2d 1118 (1987) 2 Falling along the continuum between the easy question of dangerous conditions actually on the highways

23
Hall v. ACME MARKETS, INC.green
pacommwct · 1987 · cited in 2 Pennsylvania opinions naming this issue, 2016–2020
2 sentences

2020Finally, with respect to Inmate’s claims against the Commonwealth, as this Court has explained: The waiver of sovereign immunity in Section 8522 of the Judicial Code applies only to claims against Commonwealth agencies and employees, and does not waive the immunity of the Commonwealth itself. 42 Pa. C.S. §§8501,[14] 8522; Tork-Hiss [v. Commonwealth, 735 A.2d 1256, 1258 (Pa. 1999)]; Russo [v. Allegheny County, 125 A.3d 113, 118 (Pa. Cmwlth. 2015)]; Hall v. Acme Markets, Inc., 532 A.2d 894, 897 (Pa. Cmwlth. 1987).

2016The waiver of sovereign immunity in Section 8522 of the Judicial Code applies only to claims against Commonwealth agencies and employees, and does not waive the immunity of the Commonwealth itself. 42 Pa. C.S. §§ 8501, 8522; Tork-Hiis, 735 7 A.2d at 1258; Russo, 125 A.3d at 118 ; Hall v. Acme Markets, Inc., 532 A.2d 894, 897 (Pa. Cmwlth. 1987).

22
A.J. Russo v. Allegheny County, and the Court of Common Pleas of Allegheny County, PA, Criminal Divisiongreen
pacommwct · 2015 · cited in 2 Pennsylvania opinions naming this issue, 2016–2020
2 sentences

2020Finally, with respect to Inmate’s claims against the Commonwealth, as this Court has explained: The waiver of sovereign immunity in Section 8522 of the Judicial Code applies only to claims against Commonwealth agencies and employees, and does not waive the immunity of the Commonwealth itself. 42 Pa. C.S. §§8501,[14] 8522; Tork-Hiss [v. Commonwealth, 735 A.2d 1256, 1258 (Pa. 1999)]; Russo [v. Allegheny County, 125 A.3d 113, 118 (Pa. Cmwlth. 2015)]; Hall v. Acme Markets, Inc., 532 A.2d 894, 897 (Pa. Cmwlth. 1987).

2016The waiver of sovereign immunity in Section 8522 of the Judicial Code applies only to claims against Commonwealth agencies and employees, and does not waive the immunity of the Commonwealth itself. 42 Pa. C.S. §§ 8501, 8522; Tork-Hiis, 735 7 A.2d at 1258; Russo, 125 A.3d at 118 ; Hall v. Acme Markets, Inc., 532 A.2d 894, 897 (Pa. Cmwlth. 1987).

12
Finn v. Rendellgreen
pacommwct · 2010 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
1 sentence

2024Finn v. Rendell, 990 A.2d 100, 105 (Pa. Cmwlth. 2010).

11
Talarico v. Bonhamgreen
pacommwct · 1994 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
1 sentence

2021(Appellees’ Brief at 10-11.) 7 elements: “(1) [Appellees’] duty or obligation recognized by law; (2) a breach of that duty; (3) a causal connection between [Appellees’] conduct and the resulting injury; and (4) actual damages.” Id. (citing Talarico v. Bonham, 650 A.2d 1192, 1195-96 (Pa. Cmwlth. 1994)).

11
Snyder v. Harmongreen
pa · 1989 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
2 sentences

2021The Court also opined that the unambiguous language of the exception, specifically the “critical word …‘of,’” 8 Accordingly, we do not address the issue, or any associated arguments raised by the parties, regarding whether Wise has met the first requirement for a waiver of sovereign immunity, i.e., that the injury is recoverable under common law or statute against a party not having the defense of sovereign immunity available. [J-67-2020] - 11 indicated that the “dangerous condition must derive, originate from or have as its source the Commonwealth realty.” Id. at 311 & n.5.

2021We further held that immunity will be waived under the real estate exception “where it is alleged that the artificial condition or defect of the land itself causes an injury to occur.” Id. at 312 (relying upon Mascaro v. Youth Study Center, 523 A.2d 1118, 1124 (Pa. 1984) (interpreting the real estate exception to local agency immunity under the PSTCA, 42 Pa.C.S. § 8542(b)(3), to apply “only to those cases where it is alleged that the artificial condition or defect of the land itself causes injury, not merely when it facilitates injury by acts of others, whose acts are outside [the PSTCA’s] sco

11
Tork-Hiis v. Commonwealthgreen
pa · 1999 · cited in 1 Pennsylvania opinions naming this issue, 2020–2020
1 sentence

2020Finally, with respect to Inmate’s claims against the Commonwealth, as this Court has explained: The waiver of sovereign immunity in Section 8522 of the Judicial Code applies only to claims against Commonwealth agencies and employees, and does not waive the immunity of the Commonwealth itself. 42 Pa. C.S. §§8501,[14] 8522; Tork-Hiss [v. Commonwealth, 735 A.2d 1256, 1258 (Pa. 1999)]; Russo [v. Allegheny County, 125 A.3d 113, 118 (Pa. Cmwlth. 2015)]; Hall v. Acme Markets, Inc., 532 A.2d 894, 897 (Pa. Cmwlth. 1987).

11
Philadelphia Life Insurance v. Commonwealthgreen
pa · 1963 · cited in 1 Pennsylvania opinions naming this issue, 1979–1979
2 sentences

1979Plaintiff has cited the case of Philadelphia Life Insurance Co. v. Com., 410 Pa. 571, 576 , 190 A. 2d 111, 114 (1963), however, as authority to take this case out of the sovereign immunity area.

1979Plaintiff has cited the case of Philadelphia Life Insurance Co. v. Com., 410 Pa. 571, 576 , 190 A. 2d 111, 114 (1963), however, as authority to take this case out of the sovereign immunity area.

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 (14)

CaseCitedYears
Meyer v. Community College of Beaver County green
pa · 2010
2 sentences

2024PLCB’s argument is analogous to the rationale we rejected in Meyer v. Community College of Beaver County, 2 A.3d 499 (Pa. 2010) (“Meyer I”), with regard to the Political Subdivision Tort Claims Act (“Tort Claims Act”) (recodified as 42 Pa.C.S. §§ 8541-8542).

2024PLCB’s argument is analogous to the rationale we rejected in Meyer v. Community College of Beaver County, 2 A.3d 499 (Pa. 2010) (“Meyer I”), with regard to the Political Subdivision Tort Claims Act (“Tort Claims Act”) (recodified as 42 Pa.C.S. §§ 8541-8542).

22024–2024
Armenti v. Pennsylvania State System of Higher Education green
pacommwct · 2014
1 sentence

2023Armenti, 100 A.3d at 777 .

12023–2023
Commonwealth v. Robertson green
pa · 2013
1 sentence

2022The Department argues that in Scientific Games, 66 A.3d 740 , the Supreme Court held that the waiver of sovereign immunity is limited by the language of the Procurement Code.

12022–2022
Page v. City of Philadelphia neutral
pa · 2012
1 sentence

2021(Appellees’ Brief at 10-11.) 7 elements: “(1) [Appellees’] duty or obligation recognized by law; (2) a breach of that duty; (3) a causal connection between [Appellees’] conduct and the resulting injury; and (4) actual damages.” Id. (citing Talarico v. Bonham, 650 A.2d 1192, 1195-96 (Pa. Cmwlth. 1994)).

12021–2021
Federal Aviation Administration v. Cooper green
scotus · 2012
2 sentences

2018PTC insists the waiver of sovereign immunity must be " 'unequivocally expressed' " and " '[a]ny ambiguities in the statutory language are to be construed in favor of immunity[.]' " Id. at 28, quoting F.A.A. v. Cooper , 566 U.S. 284 , 290, 132 S.Ct. 1441 , 182 L.Ed.2d 497 (2012).

2018PTC insists the waiver of sovereign immunity must be " 'unequivocally expressed' " and " '[a]ny ambiguities in the statutory language are to be construed in favor of immunity[.]' " Id. at 28, quoting F.A.A. v. Cooper , 566 U.S. 284 , 290, 132 S.Ct. 1441 , 182 L.Ed.2d 497 (2012).

12018–2018
Dean v. Com., Dept. of Transp. green
pa · 2000
2 sentences

2018Cageys’ Brief at 5 (citing Dean, 751 A.2d at 1133 ).

2018Cageys' Brief at 5 (citing Dean , 751 A.2d at 1133 ).

12018–2018
Mason & Dixon Lines, Inc. v. Mognet green
pacommwct · 1994
2 sentences

2014This Court’s decision in Mason & Dixon Lines, Inc. v. Mognet, 166 Pa.Cmwlth. 1 , 645 A.2d 1370 (1994), is instructive on the application of the exception in this case.

2014This Court’s decision in Mason & Dixon Lines, Inc. v. Mognet, 166 Pa.Cmwlth. 1 , 645 A.2d 1370 (1994), is instructive on the application of the exception in this case.

12014–2014
United States v. Alabama green
scotus · 1941
2 sentences

2009United States v. Alabama, 313 U.S. 274 , 61 S.Ct. 1011 , 85 L.Ed. 1327 (1941); United States v. Dansby, 509 F.Supp. 188 (N.D.Ohio 1981). *1275 Carney concedes that 38 U.S.C. § 3720 (a)(6) constitutes a waiver of sovereign immunity from state and local taxation on property owned by the V.A.

2009United States v. Alabama, 313 U.S. 274 , 61 S.Ct. 1011 , 85 L.Ed. 1327 (1941); United States v. Dansby, 509 F.Supp. 188 (N.D.Ohio 1981). *1275 Carney concedes that 38 U.S.C. § 3720 (a)(6) constitutes a waiver of sovereign immunity from state and local taxation on property owned by the V.A.

12009–2009
United States v. Dansby green
ohnd · 1981
1 sentence

2009United States v. Alabama, 313 U.S. 274 , 61 S.Ct. 1011 , 85 L.Ed. 1327 (1941); United States v. Dansby, 509 F.Supp. 188 (N.D.Ohio 1981). *1275 Carney concedes that 38 U.S.C. § 3720 (a)(6) constitutes a waiver of sovereign immunity from state and local taxation on property owned by the V.A.

12009–2009
Mayle v. Pennsylvania Department of Highways green
pa · 1978
2 sentences

1979This legislation, which was a response to our Supreme Court’s opinion in Mayle v. Pennsylvania Department of Highways, 479 Pa. 384 , 388 A.2d 709 (1978), expressly provided that a waiver of sovereign immunity would operate in eight enumerated categories.

1979This legislation, which was a response to our Supreme Court’s opinion in Mayle v. Pennsylvania Department of Highways, 479 Pa. 384 , 388 A.2d 709 (1978), expressly provided that a waiver of sovereign immunity would operate in eight enumerated categories.

11979–1979
Freach v. Commonwealth green
pa · 1977
1 sentence

1977The Court in Freach, supra, held: *340 [Legislative authorization of suits against the Commonwealth is not to be inferred from language which less than clearly expresses an intent to subject the Commonwealth to suit.

11977–1977
BROWN v. Commonwealth green
pa · 1973
2 sentences

1973Brown v. Commonwealth, 453 Pa. 566 , 305 A. 2d 868 (1973), confirmed the Commonwealth’s immunity from vicarious liability in actions ex delicto, again holding that the immunity is founded in the Constitution and that the immunity does not violate the due process and equal protection clauses of the fourteenth amendment to the United States Constitution and concludes: “Whether the doctrine of sovereign immunity should be modified in this Commonwealth is a legislative question.” Accordingly, URA’s demurrer to the complaint must be sustained and the complaint, as to URA, must be dismissed.

1973Brown v. Commonwealth, 453 Pa. 566 , 305 A. 2d 868 (1973), confirmed the Commonwealth’s immunity from vicarious liability in actions ex delicto, again holding that the immunity is founded in the Constitution and that the immunity does not violate the due process and equal protection clauses of the fourteenth amendment to the United States Constitution and concludes: “Whether the doctrine of sovereign immunity should be modified in this Commonwealth is a legislative question.” Accordingly, URA’s demurrer to the complaint must be sustained and the complaint, as to URA, must be dismissed.

11973–1973
Rader v. Pennsylvania Turnpike Commission green
pa · 1962
1 sentence

1973But Rader v. Pennsylvania Turnpike Commission, 407 Pa. 609 (1962), holds that the cited language “powers ... to sue and be sued” does not constitute a waiver of sovereign immunity from vicarious liability in ex delicto actions but “applies only to those actions necessary to carry out the ordinary business and functions of the Commission or Agency.” Page 615.

11973–1973
United States v. Norwegian Barque Thekla green
scotus · 1924
2 sentences

1946Against the background of complete immunity we find no congressional action modifying the immunity rule in favor of cross-actions beyond the amount necessary as a set-off.” The court then proceeded to distinguish the ease of United States v. The Thekla, 266 U. S. 328 , 69 L.

1946Against the background of complete immunity we find no congressional action modifying the immunity rule in favor of cross-actions beyond the amount necessary as a set-off.” The court then proceeded to distinguish the ease of United States v. The Thekla, 266 U. S. 328 , 69 L.

11946–1946

Statutes the citing opinions construe

PA § 42 Pa. Cons. Stat. § 8522 (12) PA § 42 Pa. Cons. Stat. § 8521 (6) PA § 42 Pa. Cons. Stat. § 8501 (5) PA § 42 Pa. Cons. Stat. § 8541 (4) PA § 62 Pa. Cons. Stat. § 1702 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 468 (1977–2026) GA 238 (1975–2026) FL 104 (1975–2026) MO 68 (1981–2025) NE 40 (1985–2024) CT 34 (1981–2024) NC 33 (1979–2026) NY 31 (1952–2025) MD 26 (1976–2026) NJ 26 (1961–2026) VA 24 (2001–2026) KY 24 (1989–2025) HI 24 (1964–2025) PA 20 (1946–2024) CA 19 (1981–2020) OK 19 (1979–2020) MA 17 (1981–2025) CO 16 (1992–2025) WA 16 (1979–2025) NM 16 (1994–2022) MS 15 (1993–2016) TN 14 (1998–2026) IL 14 (1992–2025) LA 13 (1990–2023) IA 13 (1986–2024) AK 10 (1972–2009) DE 10 (1972–2025) VT 10 (1987–2025) RI 9 (1992–2017) MT 9 (1979–2023) MN 9 (1994–2024) AR 9 (1997–2017) NH 8 (1977–2025) WI 8 (1985–2021) OH 7 (1974–2015) SC 7 (1959–2021) ID 6 (1992–2019) ME 6 (2005–2017) IN 5 (2006–2020) DC 4 (1986–2010) NV 3 (1950–1988) AZ 3 (1985–2020) SD 3 (1990–1998) KS 2 (1975–1994) AL 2 (2014–2017) UT 2 (2005–2014) VI 2 (2004–2013)

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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