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

17 Pennsylvania opinions name it 2 courts 1975–2021 1 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 (5)

CaseFollowedCited
Cagey, J., Aplt. v. PennDOTgreen
pa · 2018 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
1 sentence

2021Id. at 6-7 (quoting Brooks, 243 A.3d at 970 (granting allocatur), and citing Renner v. Court of Common Pleas, 234 A.3d 411 , 417 (Pa. 2020) (reviewing an order sustaining preliminary objections on the basis of sovereign immunity and separation of powers but resolving the case based on separation of powers); Sutton v. Bickell, 220 A.3d 1027 , 1035 (affirming order sustaining preliminary objections on sovereign immunity grounds); Cagey v. Commonwealth, 179 A.3d 458, 468 (Pa. 2018) (reversing order granting motion for judgment on the pleadings on sovereign immunity grounds)).

11
Cristea v. UCBRgreen
pacommwct · 2017 · cited in 1 Pennsylvania opinions naming this issue, 2018–2018
1 sentence

2018See Kull, 81 A.3d at 154 . 5 Appellees cite several recent unreported memorandum decisions of this Court in support of that assertion.2 See DeShields v. Bennet (Pa. Cmwlth., No. 1049 C.D. 2016, filed June 20, 2017) (holding trial court properly granted summary judgement in favor of the Department of Corrections on the basis of sovereign immunity where correctional officers acted within the course and scope of their employment when intentionally destroying confiscated items in amount in excess of that permitted to be possessed by inmate), appeal denied, 172 A.3d 148 (Pa. 2018); Wheeler v. Delba

11
Kull v. Guissegreen
pacommwct · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2018–2018
1 sentence

2018See Kull, 81 A.3d at 154 . 5 Appellees cite several recent unreported memorandum decisions of this Court in support of that assertion.2 See DeShields v. Bennet (Pa. Cmwlth., No. 1049 C.D. 2016, filed June 20, 2017) (holding trial court properly granted summary judgement in favor of the Department of Corrections on the basis of sovereign immunity where correctional officers acted within the course and scope of their employment when intentionally destroying confiscated items in amount in excess of that permitted to be possessed by inmate), appeal denied, 172 A.3d 148 (Pa. 2018); Wheeler v. Delba

11
Feldman v. Hoffmangreen
pacommwct · 2014 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
1 sentence

2015See Feldman, 107 A.3d at 829, 835-36 .

11
Brungard v. HARTMANgreen
pacommwct · 1974 · cited in 1 Pennsylvania opinions naming this issue, 1980–1980
2 sentences

1980See Brungard v. Hartman, 12 Pa.Cmwlth. 477 , 315 A.2d 913 (1974).

1980See Brungard v. Hartman, 12 Pa.Cmwlth. 477 , 315 A.2d 913 (1974).

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 (13)

CaseCitedYears
Mayle v. Pennsylvania Department of Highways green
pa · 1978
2 sentences

1983In Mayle v. Pennsylvania Department of Highways, 479 Pa. 384 , 388 A.2d 709 (1978) the doctrine of sovereign immunity was abrogated.

1983In Mayle v. Pennsylvania Department of Highways, 479 Pa. 384 , 388 A.2d 709 (1978) the doctrine of sovereign immunity was abrogated.

41978–1983
Cowden v. Aetna Casualty & Surety Co. green
pa · 1957
2 sentences

1988In Cowden v. Aetna Casualty and Surety Company, 389 Pa. 459 , 134 A.2d 223 (1957), the Pennsylvania Supreme Court first recognized the cause of action of bad faith refusal to settle.

1988In Cowden v. Aetna Casualty and Surety Company, 389 Pa. 459 , 134 A.2d 223 (1957), the Pennsylvania Supreme Court first recognized the cause of action of bad faith refusal to settle.

21988–1988
Mayle v. Pennsylvania Department of Highways green
pa · 1978
2 sentences

1980This Court on October 6, 1979 granted the parties’ joint petition to vacate the Commonwealth Court’s order and remand the case in light of Mayle v. Pennsylvania Dept. of Highways, 479 Pa. 384 , 388 A.2d 709 (1978), application for reargument denied, 479 Pa. 411 , 390 A.2d 181 (1978) * and Act 152, Act of September 28, 1978, P.L. 788, §§ 1 et seq.

1980This Court on October 6, 1979 granted the parties’ joint petition to vacate the Commonwealth Court’s order and remand the case in light of Mayle v. Pennsylvania Dept. of Highways, 479 Pa. 384 , 388 A.2d 709 (1978), application for reargument denied, 479 Pa. 411 , 390 A.2d 181 (1978) * and Act 152, Act of September 28, 1978, P.L. 788, §§ 1 et seq.

21980–1980
Cohen v. Beneficial Industrial Loan Corp. green
scotus · 1949
1 sentence

2021Id. at 6-7 (quoting Brooks, 243 A.3d at 970 (granting allocatur), and citing Renner v. Court of Common Pleas, 234 A.3d 411 , 417 (Pa. 2020) (reviewing an order sustaining preliminary objections on the basis of sovereign immunity and separation of powers but resolving the case based on separation of powers); Sutton v. Bickell, 220 A.3d 1027 , 1035 (affirming order sustaining preliminary objections on sovereign immunity grounds); Cagey v. Commonwealth, 179 A.3d 458, 468 (Pa. 2018) (reversing order granting motion for judgment on the pleadings on sovereign immunity grounds)).

12021–2021
Commonwealth v. Cabiness neutral
pa · 2018
2 sentences

2019Finally, based on the authorized and “not unexpected” nature of Trooper Lombardo’s actions, the Commonwealth Court held that it was irrelevant to the scope of employment analysis whether Trooper Lombardo’s conduct was [J-106-2018] - 13 “reasonable or not, intentional or not, tortious or not, carried out for an improper motive or not.” Id.8 We granted allowance of appeal to decide whether Trooper Lombardo was “acting within the scope of his employment throughout his entire encounter with the motorist, and thus entitled to JNOV on the basis of sovereign immunity.” Justice v. Lombardo, 187 A.3d 2

2019Finally, based on the authorized and "not unexpected" nature of Trooper Lombardo's actions, the Commonwealth Court held that it was irrelevant to the scope of employment analysis whether Trooper Lombardo's conduct was "reasonable or not, intentional or not, tortious or not, carried out for an improper motive or not." Id. 8 We granted allowance of appeal to decide whether Trooper Lombardo was "acting within the scope of his employment throughout his entire encounter with the motorist, and thus entitled to JNOV on the basis of sovereign immunity." Justice v. Lombardo , --- Pa. ----, 187 A.3d 206

12019–2019
Gallagher v. COM. OF PA., BUR. OF CORR. green
pacommwct · 1988
1 sentence

2018On appeal to this Court, the inmate argued that he “was in the custody and control of the Commonwealth by virtue of his status as a prisoner, thereby making himself the personal property of the Commonwealth.” Gallagher, 545 A.2d at 984 .

12018–2018
Frazier v. Workers' Compensation Appeal Board green
pa · 2012
2 sentences

2017(Bayada Nurses, Inc.), 616 Pa. 592 , 52 A.3d 241 (2012) (holding subro-gation claim against SEPTA under the Workers Compensation Act was barred on the basis of sovereign immunity).

2017(Bayada Nurses, Inc.), 52 A.3d 241 (Pa. 2012) (holding subrogation claim against SEPTA under the Workers Compensation Act was barred on the basis of sovereign immunity).

12017–2017
Barber v. Lynch green
pasuperct · 1980
1 sentence

1990The Superior Court later found that the Supreme Court’s admonitions in Freach were controlling over Greenberg in Barber v. Lynch, 275 Pa.Superior Ct. 333, 418 A.2d 749 (1980).

11990–1990
Garrettson v. Commonwealth green
pacommwct · 1975
2 sentences

1979This Court, per Judge Mencer, sustained the preliminary objections and dismissed the complaint against Defendants Commonwealth and Board. 1 Garrettson v. Pennsylvania Liquor Control Board, 22 Pa. Commonwealth Ct. 331, 348 A.2d 453 (1975).

1979This Court, per Judge Mencer, sustained the preliminary objections and dismissed the complaint against Defendants Commonwealth and Board. 1 Garrettson v. Pennsylvania Liquor Control Board, 22 Pa. Commonwealth Ct. 331, 348 A.2d 453 (1975).

11979–1979
Steinberg v. Commonwealth neutral
pacommwct · 1977
2 sentences

1979Steinberg v. Department of Public Welfare, 33 Pa. Commonwealth Ct. 140 , 380 A.2d 1320 (1977).

1979Steinberg v. Department of Public Welfare, 33 Pa. Commonwealth Ct. 140 , 380 A.2d 1320 (1977).

11979–1979
McCoy v. Liquor Control Board green
pacommwct · 1973
2 sentences

1975In McCoy v. Commonwealth, 9 Pa. Commonwealth Ct. 107 , 305 A.2d 746 (1973), aff’d per curiam, 457 Pa. 513 , 326 A.2d 396 (1974), and Tarantino v. Alletown State Hospital, 16 Pa. Commonwealth Ct. 133 , 329 A.2d 291 (1974), this Court, on the basis of sovereign immunity, sustained preliminary objections to complaints in trespass against state hospitals for the mentally ill.

1975In McCoy v. Commonwealth, 9 Pa. Commonwealth Ct. 107 , 305 A.2d 746 (1973), aff’d per curiam, 457 Pa. 513 , 326 A.2d 396 (1974), and Tarantino v. Alletown State Hospital, 16 Pa. Commonwealth Ct. 133 , 329 A.2d 291 (1974), this Court, on the basis of sovereign immunity, sustained preliminary objections to complaints in trespass against state hospitals for the mentally ill.

11975–1975
Tarantino v. Allentown State Hospital neutral
pacommwct · 1974
2 sentences

1975In McCoy v. Commonwealth, 9 Pa. Commonwealth Ct. 107 , 305 A.2d 746 (1973), aff’d per curiam, 457 Pa. 513 , 326 A.2d 396 (1974), and Tarantino v. Alletown State Hospital, 16 Pa. Commonwealth Ct. 133 , 329 A.2d 291 (1974), this Court, on the basis of sovereign immunity, sustained preliminary objections to complaints in trespass against state hospitals for the mentally ill.

1975In McCoy v. Commonwealth, 9 Pa. Commonwealth Ct. 107 , 305 A.2d 746 (1973), aff’d per curiam, 457 Pa. 513 , 326 A.2d 396 (1974), and Tarantino v. Alletown State Hospital, 16 Pa. Commonwealth Ct. 133 , 329 A.2d 291 (1974), this Court, on the basis of sovereign immunity, sustained preliminary objections to complaints in trespass against state hospitals for the mentally ill.

11975–1975
McCoy v. Commonwealth green
pa · 1974
2 sentences

1975In McCoy v. Commonwealth, 9 Pa. Commonwealth Ct. 107 , 305 A.2d 746 (1973), aff’d per curiam, 457 Pa. 513 , 326 A.2d 396 (1974), and Tarantino v. Alletown State Hospital, 16 Pa. Commonwealth Ct. 133 , 329 A.2d 291 (1974), this Court, on the basis of sovereign immunity, sustained preliminary objections to complaints in trespass against state hospitals for the mentally ill.

1975In McCoy v. Commonwealth, 9 Pa. Commonwealth Ct. 107 , 305 A.2d 746 (1973), aff’d per curiam, 457 Pa. 513 , 326 A.2d 396 (1974), and Tarantino v. Alletown State Hospital, 16 Pa. Commonwealth Ct. 133 , 329 A.2d 291 (1974), this Court, on the basis of sovereign immunity, sustained preliminary objections to complaints in trespass against state hospitals for the mentally ill.

11975–1975

Statutes the citing opinions construe

PA § 42 Pa. Cons. Stat. § 8522 (5) PA § 42 Pa. Cons. Stat. § 8501 (3)

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

GA 49 (1986–2025) NC 30 (2000–2025) TX 25 (1992–2015) PA 17 (1975–2021) CT 12 (1991–2022) AL 11 (1997–2018) OH 10 (1985–2022) KY 6 (1987–2022) FL 6 (1994–2021) MS 5 (1984–1999) HI 5 (1992–2017) TN 5 (2016–2019) SD 4 (1983–2020) MO 3 (2009–2016) AR 3 (2013–2020) DE 3 (1974–2025) NJ 3 (1961–2001) LA 3 (2009–2010) CO 3 (1972–2006) VA 2 (1989–1996) WA 2 (2019–2023) IL 2 (2000–2020) NM 2 (2010–2018) AZ 2 (1975–1985) IA 2 (2023–2023) WY 2 (1979–1980) NY 2 (1996–2000) MI 2 (1971–2019)

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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