judicial resolution challenge in Pennsylvania

2023As this Court explained in William Penn Parking Garage v. City of Pittsburgh, 346 A.2d 269, 280-81 (Pa. 1975) (plurality), the core concept of standing is that a person who is not adversely affected in any way by the matter he seeks to challenge is not aggrieved thereby and has no standing to obtain a judicial resolution of his challenge.

2022In the seminal case William Penn Parking Garage, Inc. v. City of Pittsburgh, 346 A.2d 269 (Pa. 1975), our Supreme Court explained that [t]he core concept, of course, is that a person who is not adversely affected in any way by the matter he seeks to challenge is not “aggrieved” thereby and has no standing to obtain a judicial resolution of his challenge.

2019See, e.g., Hosp [.] & Health System Ass'n of Penn. v. Dep't of Pub [.] Welfare , ... 585 Pa. 106 , 888 A.2d 601 (2005) (explaining that under William Penn 'where a person is not adversely affected in any way by the matter challenged, he is not aggrieved and thus has no standing to obtain a judicial resolution of that challenge.'); Bergdoll v. Kane , ... 557 Pa. 72 , 731 A.2d 1261 , 1269 (1999) ; see also Sparacino v. Phila [.] Zoning Bd. of Adjustment , 728 A.2d 445 , 448 (Pa. Cmwlth. 1999) (explaining that [ Section 752 of the Local Agency Law ,] 2 Pa.C.S. § 752, which provides that 'any pers

2019See, e.g., Hosp [.] & Health System Ass'n of Penn. v. Dep't of Pub [.] Welfare , ... 585 Pa. 106 , 888 A.2d 601 (2005) (explaining that under William Penn 'where a person is not adversely affected in any way by the matter challenged, he is not aggrieved and thus has no standing to obtain a judicial resolution of that challenge.'); Bergdoll v. Kane , ... 557 Pa. 72 , 731 A.2d 1261 , 1269 (1999) ; see also Sparacino v. Phila [.] Zoning Bd. of Adjustment , 728 A.2d 445 , 448 (Pa. Cmwlth. 1999) (explaining that [ Section 752 of the Local Agency Law ,] 2 Pa.C.S. § 752, which provides that 'any pers

2025Assembly, 940 A.2d 1227, 1233 (Pa. 2007). “[T]he core concept of standing is that a person who is not adversely affected in any way by the matter he seeks to challenge is not aggrieved thereby and has no standing to obtain a judicial resolution of his challenge.” Fumo v. City of Phila., 972 A.2d 487, 496 (Pa. 2009).

2024Our Supreme Court has explained that, “[g]enerally, the doctrine of standing is an inquiry into whether the petitioner filing suit has demonstrated aggrievement, by establishing ‘a substantial, direct and immediate interest in the outcome of the litigation.’” Robinson Township, Washington County v. Commonwealth of Pennsylvania, 83 A.3d 901, 917 (Pa. 2013) (quoting Fumo v. City of Philadelphia, 972 A.2d 487, 496 (Pa. 2009)). “[T]he core concept of standing is that a person who is not adversely affected in any way by the matter he seeks to challenge is not aggrieved thereby and has no standing t

2023The “core concept of the doctrine of standing is that a person who is not adversely affected in any way by the matter he seeks to challenge . . . has no right to obtain a judicial resolution of his challenge.” In re T.J., 739 A.2d 478, 481 (Pa. 1999).

2023The “core concept of the doctrine of standing is that a person who is not adversely affected in any way by the matter he seeks to challenge . . . has no right to obtain a judicial resolution of his challenge.” In re T.J., 739 A.2d 478, 481 (Pa. 1999).

2007The crux of our review is that “a person who is not adversely affected in any way by the matter he seeks to challenge is not ‘aggrieved’ and has no right to obtain a judicial resolution of his challenge.” In re T.J., 559 Pa. at 125 , 739 A.2d at 481 , quoting Independent State Store Union v. Pennsylvania Liquor Control Board, 495 Pa. 145, 154 , 432 A.2d 1375, 1379-1380 (1981). ¶ 9 Furthermore, in Commonwealth, Pennsylvania Game Commission v. Commonwealth, Department of Environmental Resources, 521 Pa. 121 , 555 A.2d 812 (1989) the Supreme Court of Pennsylvania specifically addressed the issues

2007The crux of our review is that “a person who is not adversely affected in any way by the matter he seeks to challenge is not ‘aggrieved’ and has no right to obtain a judicial resolution of his challenge.” In re T.J., 559 Pa. at 125 , 739 A.2d at 481 , quoting Independent State Store Union v. Pennsylvania Liquor Control Board, 495 Pa. 145, 154 , 432 A.2d 1375, 1379-1380 (1981). ¶ 9 Furthermore, in Commonwealth, Pennsylvania Game Commission v. Commonwealth, Department of Environmental Resources, 521 Pa. 121 , 555 A.2d 812 (1989) the Supreme Court of Pennsylvania specifically addressed the issues

2011Penn Parking Garage, Inc. v. City of Pittsburgh, 464 Pa. 168 , 346 A.2d 269, 280-281 (1975) (plurality); Pierro v. Pierro, 434 Pa. 131, 132-133 , 252 A.2d 652, 653 (Pa.1969) (determining that where what the court had to say in its opinion regarding the sufficiency of the pleadings was dicta and did not establish the law of the case, the plaintiff was not injured by the court’s order and was not a proper appellant at that stage of the proceedings).

2011Penn Parking Garage, Inc. v. City of Pittsburgh, 464 Pa. 168 , 346 A.2d 269, 280-281 (1975) (plurality); Pierro v. Pierro, 434 Pa. 131, 132-133 , 252 A.2d 652, 653 (Pa.1969) (determining that where what the court had to say in its opinion regarding the sufficiency of the pleadings was dicta and did not establish the law of the case, the plaintiff was not injured by the court’s order and was not a proper appellant at that stage of the proceedings).

2010Before addressing the merits of the constitutional challenges, the majority, in an opinion authored by former-Judge Lally-Green, addressed "the threshold question of whether [Plaintiffs] lack standing to raise a dormant Commerce Clause challenge." Id. at 577 . [6] The Superior Court began its analysis by stating that, generally, "a person who is not adversely affected in any way by the matter he seeks to challenge is not aggrieved thereby and has no standing to obtain a judicial resolution of his challenge," id. (quoting Soc'y Hill Civic Ass'n v. Pa. Gaming Control Bd., 593 Pa. 1 , 928 A.2d 17

2010Before addressing the merits of the constitutional challenges, the majority, in an opinion authored by former-Judge Lally-Green, addressed "the threshold question of whether [Plaintiffs] lack standing to raise a dormant Commerce Clause challenge." Id. at 577 . [6] The Superior Court began its analysis by stating that, generally, "a person who is not adversely affected in any way by the matter he seeks to challenge is not aggrieved thereby and has no standing to obtain a judicial resolution of his challenge," id. (quoting Soc'y Hill Civic Ass'n v. Pa. Gaming Control Bd., 593 Pa. 1 , 928 A.2d 17

2007The crux of our review is that “a person who is not adversely affected in any way by the matter he seeks to challenge is not ‘aggrieved’ and has no right to obtain a judicial resolution of his challenge.” In re T.J., 559 Pa. at 125 , 739 A.2d at 481 , quoting Independent State Store Union v. Pennsylvania Liquor Control Board, 495 Pa. 145, 154 , 432 A.2d 1375, 1379-1380 (1981). ¶ 9 Furthermore, in Commonwealth, Pennsylvania Game Commission v. Commonwealth, Department of Environmental Resources, 521 Pa. 121 , 555 A.2d 812 (1989) the Supreme Court of Pennsylvania specifically addressed the issues

2007The crux of our review is that “a person who is not adversely affected in any way by the matter he seeks to challenge is not ‘aggrieved’ and has no right to obtain a judicial resolution of his challenge.” In re T.J., 559 Pa. at 125 , 739 A.2d at 481 , quoting Independent State Store Union v. Pennsylvania Liquor Control Board, 495 Pa. 145, 154 , 432 A.2d 1375, 1379-1380 (1981). ¶ 9 Furthermore, in Commonwealth, Pennsylvania Game Commission v. Commonwealth, Department of Environmental Resources, 521 Pa. 121 , 555 A.2d 812 (1989) the Supreme Court of Pennsylvania specifically addressed the issues

2026Commonwealth v. Donahue, 98 A.3d 1223, 1229 (Pa. 2014)(quotation marks omitted).

2025Office of Governor v. Donahue, 98 A.3d 1223, 1229 (Pa. 2014) (“Donahue”) (quotation marks omitted).

2025Assembly, 940 A.2d 1227, 1233 (Pa. 2007). “[T]he core concept of standing is that a person who is not adversely affected in any way by the matter he seeks to challenge is not aggrieved thereby and has no standing to obtain a judicial resolution of his challenge.” Fumo v. City of Phila., 972 A.2d 487, 496 (Pa. 2009).

2024Assembly, 940 A.2d 1227, 1233 (Pa. 2007). “[T]he core concept of standing is that a person who is not adversely affected in any way by the matter he seeks to challenge is not aggrieved thereby and has no standing to obtain a judicial resolution of his challenge.” Fumo v. City of Phila., 972 A.2d 487, 496 (Pa. 2009).

2019See, e.g., Hosp [.] & Health System Ass'n of Penn. v. Dep't of Pub [.] Welfare , ... 585 Pa. 106 , 888 A.2d 601 (2005) (explaining that under William Penn 'where a person is not adversely affected in any way by the matter challenged, he is not aggrieved and thus has no standing to obtain a judicial resolution of that challenge.'); Bergdoll v. Kane , ... 557 Pa. 72 , 731 A.2d 1261 , 1269 (1999) ; see also Sparacino v. Phila [.] Zoning Bd. of Adjustment , 728 A.2d 445 , 448 (Pa. Cmwlth. 1999) (explaining that [ Section 752 of the Local Agency Law ,] 2 Pa.C.S. § 752, which provides that 'any pers

2013See, e.g., Hospital & Health System Ass’n of Penn. v. Dep’t of Public Welfare, 585 Pa. 106 , 888 A.2d 601 (Pa.2005) (explaining that under William Penn ‘where a person is not adversely affected in any way by the matter challenged, he is not aggrieved and thus has no standing to obtain a judicial resolution of that challenge.’); Bergdoll v. Kane, 557 Pa. 72 , 731 A.2d 1261, 1269 (1999); see also Sparacino v. Philadelphia Zoning Bd. of Adjustment, 728 A.2d 445, 448 (Pa.Cmwlth.1999) (explaining that 2 Pa.C.S. § 752, which provides that ‘any person aggrieved’ by an adjudication of a local agency,

2019See, e.g., Hosp [.] & Health System Ass'n of Penn. v. Dep't of Pub [.] Welfare , ... 585 Pa. 106 , 888 A.2d 601 (2005) (explaining that under William Penn 'where a person is not adversely affected in any way by the matter challenged, he is not aggrieved and thus has no standing to obtain a judicial resolution of that challenge.'); Bergdoll v. Kane , ... 557 Pa. 72 , 731 A.2d 1261 , 1269 (1999) ; see also Sparacino v. Phila [.] Zoning Bd. of Adjustment , 728 A.2d 445 , 448 (Pa. Cmwlth. 1999) (explaining that [ Section 752 of the Local Agency Law ,] 2 Pa.C.S. § 752, which provides that 'any pers

2019See, e.g., Hosp [.] & Health System Ass'n of Penn. v. Dep't of Pub [.] Welfare , ... 585 Pa. 106 , 888 A.2d 601 (2005) (explaining that under William Penn 'where a person is not adversely affected in any way by the matter challenged, he is not aggrieved and thus has no standing to obtain a judicial resolution of that challenge.'); Bergdoll v. Kane , ... 557 Pa. 72 , 731 A.2d 1261 , 1269 (1999) ; see also Sparacino v. Phila [.] Zoning Bd. of Adjustment , 728 A.2d 445 , 448 (Pa. Cmwlth. 1999) (explaining that [ Section 752 of the Local Agency Law ,] 2 Pa.C.S. § 752, which provides that 'any pers

2018See Johnson v. American Standard, 8 A.3d 318, 329 (Pa. 2010) (explaining that “a person who is not adversely affected in any way by the matter he seeks to challenge is not aggrieved thereby and has no standing to obtain a judicial resolution to his challenge”).

2017The Johnson Court continued that, at its core, the concept of standing is that “a person who is not adversely affected in any way by the matter he seeks to challenge is not aggrieved thereby and has no standing to obtain a judicial resolution of his challenge.” Id. at 326 (quoting Wm.

2025See Rellick-Smith v. Rellick, 147 A.3d 897, 901 (Pa. Super. 2016) (“The core concept of standing is that a person who is not adversely affected in any way by the matter he seeks to challenge is not ‘aggrieved’ thereby and has no standing to obtain a judicial resolution to his challenge.”) (citation and brackets omitted).

2018“Threshold issues of standing are questions of law; thus, our standard - 10 - J-S16029-18 of review is de novo and our scope of review is plenary.” Rellick-Smith v. Rellick, 147 A.3d 897, 901 (Pa. Super. 2016) (internal citation omitted). [T]he core concept of standing is that a person who is not adversely affected in any way by the matter he seeks to challenge is not “aggrieved” thereby and has no standing to obtain a judicial resolution to his challenge.

2025“It is well-established that a person who is not adversely affected in any way by the matter he seeks to challenge is not ‘aggrieved’ thereby and has no standing to obtain a judicial resolution of his challenge.” Tacony Civic Ass’n v. Pa. Liquor Control Bd., 668 A.2d 584, 589 (Pa. Cmwlth. 1995) (citation omitted).

2018Tacony Civic Ass’n v. Pa. Liquor Control Bd., 668 A.2d 584, 589 (Pa. Cmwlth. 1995) (citing Wm.

2018See also Pittsburgh Palisades Par, LLC. v. Commonwealth of Pennsylvania, 888 A.2d 655, 659 (Pa. 2005) (considering preliminary objections challenging standing and noting that, “[p]rior to judicial resolution of a dispute, an individual must as a threshold matter show that he has standing to bring the action”). - 11 - J-S04020-18 permitted Appellants’ to amend their Complaint.

2017Pittsburgh Palisades Park, LLC v. Commonwealth, 585 Pa. 196 , 888 A,2d 655, 659-60 (2006) (internal citations, quotation marks, brackets and paragraph breaks omitted).

1999Kuropatwa v. State Farm Insurance Company, 554 Pa. 456 , 721 A.2d 1067, 1069 (1998) (citations omitted, emphasis added).

1999Kuropatwa v. State Farm Insurance Company, 554 Pa. 456 , 721 A.2d 1067, 1069 (1998) (citations omitted, emphasis added).

1982State Harness Racing Commission, 405 Pa. 1, 7-8 , 173 A.2d 97, 100 (1961).” “The core concept, of course, is that a person who is not adversely affected in any way by the matter he seeks to challenge is not ‘aggrieved’ thereby and has no standing to obtain a judicial resolution of his challenge.

1982State Harness Racing Commission, 405 Pa. 1, 7-8 , 173 A.2d 97, 100 (1961).” “The core concept, of course, is that a person who is not adversely affected in any way by the matter he seeks to challenge is not ‘aggrieved’ thereby and has no standing to obtain a judicial resolution of his challenge.

2023A party who is not aggrieved "has no standing to obtain a judicial resolution of his challenge." In re [Hickson, 821 A.2d 1238, 1243 (Pa. 2003) (citation omitted).

2023A party who is not aggrieved "has no standing to obtain a judicial resolution of his challenge." In re [Hickson, 821 A.2d 1238 , 1243 (Pa. 2003) (citation omitted).

2005"The core concept of standing is that a person who is not adversely affected in any way by the matter he seeks to challenge is not `aggrieved' thereby and has no standing to obtain a judicial resolution of his challenge." Hertzberg v. Zoning Bd. of Adjustment of the City of Pittsburgh, 554 Pa. 249, 256 , 721 A.2d 43 , 46 n. 6 (1998).

2005“The core concept of standing is that a person who is not adversely affected in any way by the matter he seeks to challenge is not ‘aggrieved’ thereby and has no standing to obtain a judicial resolution of his challenge.” Hertzberg v. Zoning Bd. of Adjustment of the City of Pittsburgh, 554 Pa. 249, 256 , 721 A.2d 43 , 46 n. 6 (1998).

2005"The core concept of standing is that a person who is not adversely affected in any way by the matter he seeks to challenge is not `aggrieved' thereby and has no standing to obtain a judicial resolution of his challenge." Hertzberg v. Zoning Bd. of Adjustment of the City of Pittsburgh, 554 Pa. 249, 256 , 721 A.2d 43 , 46 n. 6 (1998).

2005“The core concept of standing is that a person who is not adversely affected in any way by the matter he seeks to challenge is not ‘aggrieved’ thereby and has no standing to obtain a judicial resolution of his challenge.” Hertzberg v. Zoning Bd. of Adjustment of the City of Pittsburgh, 554 Pa. 249, 256 , 721 A.2d 43 , 46 n. 6 (1998).

2019Spahn v. Zoning Bd. of Adjustment , ... 602 Pa. 83 , 977 A.2d 1132 , 1149-50 (2009).

2019Spahn v. Zoning Bd. of Adjustment , ... 602 Pa. 83 , 977 A.2d 1132 , 1149-50 (2009).

2005Id. at 192 , 346 A.2d at 280 (footnote omitted.) A party 'must show' a sufficiently close causal connection between the challenged action and the asserted injury to qualify the interest as 'immediate' rather than ‘remote.’ Id. at 202 , 346 A.2d at 286 .” Maillie, 628 A.2d at 532 .

1994Id.; See also Maillie v. Greater Delaware Valley Health Care, Inc., 156 Pa.Commonwealth Ct. 582, 628 A.2d 528 (1993). ‘A person who is not adversely affected in any way by the matter he seeks to challenge is not “aggrieved” thereby and has no standing to obtain a judicial resolution of this challenge.’ ...

1997As this court has previously explained, “the core concept [of standing] ... is that a person who is not adversely affected in any way by the matter he seeks to challenge is not ‘aggrieved’ thereby and has no standing to obtain a judicial resolution of his challenge.” Franklin Township v. Commonwealth Department of Environmental Resources, 500 Pa. 1, 3-5 , 452 A.2d 718, 719 (1982)(citing William Penn Parking Garage v. City of Pittsburgh, 464 Pa. 168 , 346 A.2d 269 (1975)).

1997As this court has previously explained, “the core concept [of standing] ... is that a person who is not adversely affected in any way by the matter he seeks to challenge is not ‘aggrieved’ thereby and has no standing to obtain a judicial resolution of his challenge.” Franklin Township v. Commonwealth Department of Environmental Resources, 500 Pa. 1, 3-5 , 452 A.2d 718, 719 (1982)(citing William Penn Parking Garage v. City of Pittsburgh, 464 Pa. 168 , 346 A.2d 269 (1975)).

2024Our Supreme Court has explained that, “[g]enerally, the doctrine of standing is an inquiry into whether the petitioner filing suit has demonstrated aggrievement, by establishing ‘a substantial, direct and immediate interest in the outcome of the litigation.’” Robinson Township, Washington County v. Commonwealth of Pennsylvania, 83 A.3d 901, 917 (Pa. 2013) (quoting Fumo v. City of Philadelphia, 972 A.2d 487, 496 (Pa. 2009)). “[T]he core concept of standing is that a person who is not adversely affected in any way by the matter he seeks to challenge is not aggrieved thereby and has no standing t

2023Generally, “[a] prevailing party is not ‘aggrieved’ and therefore, does not have standing to appeal an order that has been entered in his or her favor.” Ratti v. Wheeling Pittsburgh Steel Corp., 758 A.2d 695, 700 (Pa. Super. 2000).