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17 Pennsylvania opinions name it 3 courts 1988–2026 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.
| Case | Followed | Cited |
|---|---|---|
Commonwealth v. Messersmithgreen2 sentences2026We begin our consideration of the proper standard of prejudice by examining the analogous situation involving an ____________________________________________ 3 See Commonwealth v. Messersmith, 860 A.2d 1078, 1085 (Pa. Super. 2004) (“[u]nder the exception to the no impeachment rule [contained in Pennsylvania Rule of Evidence 606(b)], a juror may testify only as to the existence of the outside influence, but not as to the effect this outside influence may have had on deliberations. 2023Rule 606(b)(2) then provides two exceptions to the general rule, declaring that jurors are competent to testify about whether: 1) “prejudicial information not of record and beyond common knowledge and experience was improperly brought to the jury's attention” and 2) “an outside influence was improperly brought to bear on any juror.” Pa.R.E. 606(b)(2); see also Commonwealth v. Messersmith, 860 A.2d 1078 , 1085 (Pa. Super. 2004) (“[u]nder the exception[s] to the no impeachment rule, a juror may testify only as to the existence of the [extraneous information or] outside influence, but not as to t | 3 | 4 |
Commonwealth v. Szakalgreen2 sentences2020Pa.R.E. 606(b)(1); Szakal, 50 A.3d at 223 . 2018Under no circumstances may jurors testify about their subjective reasoning processes.” Commonwealth ____________________________________________ 6 This rule is codified in Pa.R.E. 606, which provides that “[a] juror is incompetent to testify as to what occurred during deliberations.” Commonwealth v. Szakal, 50 A.3d 210, 223 (Pa. Super. 2012). -9- J-A08036-18 v. Messersmith, 860 A.2d 1078, 1085 (Pa. Super. 2004) (internal citation and quotation marks omitted). | 1 | 2 |
Commonwealth v. Piercegreen2 sentences1999However, we believe the impeachment rule does in fact apply, in light of a subsequent Supreme Court case: Commonwealth v. Pierce, 453 Pa. 319 , 309 A.2d 371 (1973). 1999However, we believe the impeachment rule does in fact apply, in light of a subsequent Supreme Court case: Commonwealth v. Pierce, 453 Pa. 319 , 309 A.2d 371 (1973). | 1 | 2 |
Commonwealth v. Serogreen2 sentences2005Accord Commonwealth v. Sero, 478 Pa. 440, 448 , 387 A.2d 63, 67 (1978) (“Information, if prejudicial, that reaches a juror through a third party is precisely the evil our exception to the no impeachment rule is intended to obviate.”); Eades v. State, 75 Md.App. 411 , 541 A.2d 1001, 1006 (1988) (“A private communication between a third party and a deliberating juror raises a serious concern that the juror may reach a verdict on the basis of the matters communicated, rather than the trial evidence.”). 2005Accord Commonwealth v. Sero, 478 Pa. 440, 448 , 387 A.2d 63, 67 (1978) (“Information, if prejudicial, that reaches a juror through a third party is precisely the evil our exception to the no impeachment rule is intended to obviate.”); Eades v. State, 75 Md.App. 411 , 541 A.2d 1001, 1006 (1988) (“A private communication between a third party and a deliberating juror raises a serious concern that the juror may reach a verdict on the basis of the matters communicated, rather than the trial evidence.”). | 1 | 2 |
Pena-Rodriguez v. Coloradogreen2 sentences2020Id. ____________________________________________ 4 In Pena-Rodriguez, the United States Supreme Court abrogated the Pennsylvania Supreme Court’s decision of Commonwealth v. Steele, 961 A.2d 786 (Pa. 2008), in which our Supreme Court held that the no impeachment rule barred consideration of a juror’s declaration that several other jurors expressed racial bias towards the defendant and appeared to vote to convict based upon the defendant’s race. 2020Id. at 807-08 ; see also Pena- Rodriguez, 137 S.Ct. at 865 (citing Steele and noting that Pennsylvania was one of only two states that had declined to find an exception to the no impeachment rule for racial bias). -5- J-A12010-20 In the letter, which was dated the same day as the date of the verdict, Juror Number 5 wrote to the trial court that “there is a lot that troubles me about the deliberation portion of this trial.” Supplemental Certified Record, Docket Number 5. | 1 | 1 |
Eades v. Stategreen2 sentences2005Accord Commonwealth v. Sero, 478 Pa. 440, 448 , 387 A.2d 63, 67 (1978) (“Information, if prejudicial, that reaches a juror through a third party is precisely the evil our exception to the no impeachment rule is intended to obviate.”); Eades v. State, 75 Md.App. 411 , 541 A.2d 1001, 1006 (1988) (“A private communication between a third party and a deliberating juror raises a serious concern that the juror may reach a verdict on the basis of the matters communicated, rather than the trial evidence.”). 2005Accord Commonwealth v. Sero, 478 Pa. 440, 448 , 387 A.2d 63, 67 (1978) (“Information, if prejudicial, that reaches a juror through a third party is precisely the evil our exception to the no impeachment rule is intended to obviate.”); Eades v. State, 75 Md.App. 411 , 541 A.2d 1001, 1006 (1988) (“A private communication between a third party and a deliberating juror raises a serious concern that the juror may reach a verdict on the basis of the matters communicated, rather than the trial evidence.”). | 1 | 1 |
Boring v. LaMarcagreen2 sentences1999An extraneous influence consists of “information . . . not provided in open court or vocalized by the trial court via instructions.” Boring v. LaMarca, 435 Pa. Super. 487, 493 , 646 A.2d 1199, 1202 (1994) (citing Carter and Pittsburgh National Bank (concurrence), supra). 1999An extraneous influence consists of “information . . . not provided in open court or vocalized by the trial court via instructions.” Boring v. LaMarca, 435 Pa. Super. 487, 493 , 646 A.2d 1199, 1202 (1994) (citing Carter and Pittsburgh National Bank (concurrence), supra). | 1 | 1 |
Commonwealth v. Williamsgreen2 sentences1990Commonwealth v. Williams, 371 Pa.Super. 509, 515 , 538 A.2d 557, 560 (1988). 1990Commonwealth v. Williams, 371 Pa.Super. 509, 515 , 538 A.2d 557, 560 (1988). | 1 | 1 |
Commonwealth v. Storygreen2 sentences1988In Commonwealth v. Story, 476 Pa. 391, 409 , 383 A.2d 155, 164 (1978), the Court ruled: We adopt the standard that an error cannot be held harmless unless the appellate court determines that the error could not have contributed to the verdict. 1988In Commonwealth v. Story, 476 Pa. 391, 409 , 383 A.2d 155, 164 (1978), the Court ruled: We adopt the standard that an error cannot be held harmless unless the appellate court determines that the error could not have contributed to the verdict. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Larsen v. Senate of Pennsylvania
green
2 sentences2024The court also noted that the specific remedy which the DA sought – declaratory relief under Section 7541(a) of the Declaratory Judgments Act – was compatible with its prior holding in Larsen v. Senate of Pennsylvania, 646 A.2d 694 (Pa. Cmwlth. 1994) (holding that courts could not halt an impeachment proceeding through the issuance of an injunction), as the DA did not seek to bar the Senate from conducting an impeachment hearing, but, instead, trusted that, if a declaratory judgment was entered indicating that the impeachment was unconstitutional, the Senate would refrain from carrying out the 2024The court also noted that the specific remedy which the DA sought – declaratory relief under Section 7541(a) of the Declaratory Judgments Act – was compatible with its prior holding in Larsen v. Senate of Pennsylvania, 646 A.2d 694 (Pa. Cmwlth. 1994) (holding that courts could not halt an impeachment proceeding through the issuance of an injunction), as the DA did not seek to bar the Senate from conducting an impeachment hearing, but, instead, trusted that, if a declaratory judgment was entered indicating that the impeachment was unconstitutional, the Senate would refrain from carrying out the | 3 | 2024–2024 |
Carter v. United States Steel Corp.
green
2 sentences2004This rule often is referred to as the "no impeachment rule." Carter, 529 Pa. at 415 , 604 A.2d at 1013 . ¶ 16 As the trial court recognized, however, there exists a narrow exception to the no impeachment rule. 2004This rule often is referred to as the "no impeachment rule." Carter, 529 Pa. at 415 , 604 A.2d at 1013 . ¶ 16 As the trial court recognized, however, there exists a narrow exception to the no impeachment rule. | 2 | 2004–2004 |
Commonwealth, Aplt. v. Molina, M.
green
1 sentence2023Id. | 1 | 2023–2023 |
Commonwealth v. Steele
green
2 sentences2020Id. ____________________________________________ 4 In Pena-Rodriguez, the United States Supreme Court abrogated the Pennsylvania Supreme Court’s decision of Commonwealth v. Steele, 961 A.2d 786 (Pa. 2008), in which our Supreme Court held that the no impeachment rule barred consideration of a juror’s declaration that several other jurors expressed racial bias towards the defendant and appeared to vote to convict based upon the defendant’s race. 2020Id. at 807-08 ; see also Pena- Rodriguez, 137 S.Ct. at 865 (citing Steele and noting that Pennsylvania was one of only two states that had declined to find an exception to the no impeachment rule for racial bias). -5- J-A12010-20 In the letter, which was dated the same day as the date of the verdict, Juror Number 5 wrote to the trial court that “there is a lot that troubles me about the deliberation portion of this trial.” Supplemental Certified Record, Docket Number 5. | 1 | 2020–2020 |
Commonwealth v. Girard Trust Co.
green
1 sentence2007Finally, we reiterate that our approach is consistent with the line of cases beginning with Weiss v. Ziegler, 327 Pa. 100 , 193 A. 642 (1937). [1] In a parallel development, some delegates urged caution in the removal of elected officials, preferring to require impeachment instead of solely the "address of two-thirds of the Senate." That suggestion was defeated as well, with one delegate who opposed the impeachment requirement explaining: Take for instance your office of State Treasurer, who will be elected by the people. | 1 | 2007–2007 |
Weiss v. Ziegler
green
1 sentence2007Finally, we reiterate that our approach is consistent with the line of cases beginning with Weiss v. Ziegler, 327 Pa. 100 , 193 A. 642 (1937). [1] In a parallel development, some delegates urged caution in the removal of elected officials, preferring to require impeachment instead of solely the "address of two-thirds of the Senate." That suggestion was defeated as well, with one delegate who opposed the impeachment requirement explaining: Take for instance your office of State Treasurer, who will be elected by the people. | 1 | 2007–2007 |
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.
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.