parens patriae doctrine (Pennsylvania) · Go Syfert
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parens patriae doctrine in Pennsylvania

16 Pennsylvania opinions name it 3 courts 1964–2021 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 (7)

CaseFollowedCited
In Re William L.green
pa · 1978 · cited in 3 Pennsylvania opinions naming this issue, 1980–2016
2 sentences

2016"The-source of the state’s authority to intervene in family matters to protect minor children has been said to be the doctrine of parens patriae, the concept that the sovereign is the father of his country.” In re Williams L., 383 A.2d at 1235-36 .

2016See id. (“fundamental right of parents to the care and custody of their children when that care and custody serves the best interests of the children” (emphasis provided)). 3 “The source of the state’s authority to intervene in family matters to protect minor children has been said to be the doctrine of parens patriae, the concept that the sovereign is the father of his country.” In re Williams L., 383 A.2d at 1235-36 .

23
Pruner Estategreen
pa · 1957 · cited in 2 Pennsylvania opinions naming this issue, 2005–2012
2 sentences

2012The doctrine of “parens patriae ” refers to the “ancient powers of guardianship over persons under disability and of protectorship of the public interest which were originally held by the Crown of England as ‘father of the country,’ and which as part of the common law devolved upon the states and federal government.” In re Milton Hershey School Trust, 807 A.2d 324 , 326 n. 1 (Pa.Cmwlth.2002) (quoting In re Pruner’s Estate, 390 Pa. 529, 532 , 136 A.2d 107, 109 (1957)) (citations omitted).

2012The doctrine of “parens patriae ” refers to the “ancient powers of guardianship over persons under disability and of protectorship of the public interest which were originally held by the Crown of England as ‘father of the country,’ and which as part of the common law devolved upon the states and federal government.” In re Milton Hershey School Trust, 807 A.2d 324 , 326 n. 1 (Pa.Cmwlth.2002) (quoting In re Pruner’s Estate, 390 Pa. 529, 532 , 136 A.2d 107, 109 (1957)) (citations omitted).

22
Kraisinger v. Kraisingergreen
pasuperct · 2007 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
1 sentence

2016This authority would not apply to a typical custody arrangement, but it supports the strong public policy of Pennsylvania to promote custody arrangements that are in a child’s best interests. -5- J-E03001-15 Cf. Kraisinger v. Kraisinger, 928 A.2d 333, 345 (Pa.Super.2007) (contract provision invalid where it “penalizes mother for, and therefore would act to discourage her from, seeking a court’s review of the parties’ agreement as to child support”); see also Ferguson v. McKiernan, 940 A.2d 1236 , 1245 n.16 (Pa.2007) (a contract is against public policy where the policy “is so obviously for or

11
Ferguson v. McKiernangreen
pa · 2007 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
1 sentence

2016This authority would not apply to a typical custody arrangement, but it supports the strong public policy of Pennsylvania to promote custody arrangements that are in a child’s best interests. -5- J-E03001-15 Cf. Kraisinger v. Kraisinger, 928 A.2d 333, 345 (Pa.Super.2007) (contract provision invalid where it “penalizes mother for, and therefore would act to discourage her from, seeking a court’s review of the parties’ agreement as to child support”); see also Ferguson v. McKiernan, 940 A.2d 1236 , 1245 n.16 (Pa.2007) (a contract is against public policy where the policy “is so obviously for or

11
In re S.H.green
pasuperct · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
1 sentence

2016See id. (“fundamental right of parents to the care and custody of their children when that care and custody serves the best interests of the children” (emphasis provided)). 3 “The source of the state’s authority to intervene in family matters to protect minor children has been said to be the doctrine of parens patriae, the concept that the sovereign is the father of his country.” In re Williams L., 383 A.2d at 1235-36 .

11
State Ex Rel. J. R. v. MacQueengreen
wva · 1979 · cited in 1 Pennsylvania opinions naming this issue, 1988–1988
2 sentences

1988The command of these cases is that the constitutional rights of the juvenile can no longer be ignored but that he must be afforded constitutional due process and fair treatment. 259 S.E.2d at 422 (holding that juveniles in parole revocation hearings are entitled to the same protections afforded adults by Morrissey).

1988The command of these cases is that the constitutional rights of the juvenile can no longer be ignored but that he must be afforded constitutional due process and fair treatment. 259 S.E.2d at 422 (holding that juveniles in parole revocation hearings are entitled to the same protections afforded adults by Morrissey ).

11
In Re Adoption of R. I.green
pa · 1976 · cited in 1 Pennsylvania opinions naming this issue, 1978–1978
2 sentences

1978See, e.g., Adoption of R.I., 468 Pa. at 294 , 361 A.2d at 297 .

1978See, e.g., Adoption of R.I., 468 Pa. at 294 , 361 A.2d at 297 .

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 (10)

CaseCitedYears
In Re GAULT green
scotus · 1967
2 sentences

1981Even criticism of the doctrine in In re Gault, 387 U.S. 1 , 87 S.Ct. 1428 , 18 L.Ed.2d 527 (1967) 2 did not anticipate a state would attribute finality to a present mental condition and use that “judicial prognosis” as the ground for involuntary termination of parental rights.

1981Even criticism of the doctrine in In re Gault, 387 U.S. 1 , 87 S.Ct. 1428 , 18 L.Ed.2d 527 (1967) 2 did not anticipate a state would attribute finality to a present mental condition and use that “judicial prognosis” as the ground for involuntary termination of parental rights.

31969–1981
In Re Milton Hershey School Trust green
pacommwct · 2002
2 sentences

2012The doctrine of “parens patriae ” refers to the “ancient powers of guardianship over persons under disability and of protectorship of the public interest which were originally held by the Crown of England as ‘father of the country,’ and which as part of the common law devolved upon the states and federal government.” In re Milton Hershey School Trust, 807 A.2d 324 , 326 n. 1 (Pa.Cmwlth.2002) (quoting In re Pruner’s Estate, 390 Pa. 529, 532 , 136 A.2d 107, 109 (1957)) (citations omitted).

2005The doctrine of “parens patriae” refers to the “ancient powers of guardianship over persons under disability and of protectorship of the public interest which were originally held by the Crown of England as ‘father of the country,’ and which as part of the common law devolved upon the states and federal government.” In re Milton Hershey School Trust, 807 A.2d 324 , 326 n. 1 (Pa.Cmwlth.2002) (quoting In re Primer’s Estate, 390 Pa. 529, 532 , 136 A.2d 107, 109 (1957)) (citations omitted).

22005–2012
Alfred L. Snapp & Son, Inc. v. Puerto Rico Ex Rel. Barez green
scotus · 1982
2 sentences

2010In considering the respondents’ preliminary objections in TAP II, this Court relied upon the parens patriae analysis of Snapp v. Puerto Rico, 458 U.S. 592 , 102 S.Ct. 3260 , 73 L.Ed.2d 995 (1982), the leading case on the scope of a state’s parens patriae authority.

2010In considering the respondents’ preliminary objections in TAP II, this Court relied upon the parens patriae analysis of Snapp v. Puerto Rico, 458 U.S. 592 , 102 S.Ct. 3260 , 73 L.Ed.2d 995 (1982), the leading case on the scope of a state’s parens patriae authority.

22010–2011
Holmes' Appeal green
pa · 1954
2 sentences

1980In re William L., 477 Pa. 322, 338 , 383 A.2d 1228, 1236 (1978); Holmes Appeal, 379 Pa. 599, 603 , 109 A.2d 523 (1954); Janet D. v. Carros, supra, 240 Pa.Super. at 316 , 362 A.2d at 1072 . 6 We conclude that, pursuant to the doctrine of parens patriae, the juvenile court in this case stood in loco parentis to the mentally ill deprived child, Jerry G.

1980In re William L., 477 Pa. 322, 338 , 383 A.2d 1228, 1236 (1978); Holmes Appeal, 379 Pa. 599, 603 , 109 A.2d 523 (1954); Janet D. v. Carros, supra, 240 Pa.Super. at 316 , 362 A.2d at 1072 . 6 We conclude that, pursuant to the doctrine of parens patriae, the juvenile court in this case stood in loco parentis to the mentally ill deprived child, Jerry G.

21969–1980
State of New Mexico v. General Electric green
ca10 · 2006
1 sentence

2021Co., 467 F.3d 1223 , 1243 n.30 (10th Cir. 2006) (noting that the parens patriae doctrine provides “a state with standing to sue for damages to a broader range of natural resources because it does not require state ownership of such resources”).

12021–2021
Commonwealth v. Nixon green
pa · 2000
2 sentences

2018The trial *916 court then discussed Commonwealth v. Nixon , 563 Pa. 425 , 761 A.2d 1151 (2000), and stated that where parents cannot or will not fulfill their duties, it is the obligation of the Commonwealth to take on that role under the doctrine of parens patriae . 10 Id. at 6.

2018The trial *916 court then discussed Commonwealth v. Nixon , 563 Pa. 425 , 761 A.2d 1151 (2000), and stated that where parents cannot or will not fulfill their duties, it is the obligation of the Commonwealth to take on that role under the doctrine of parens patriae . 10 Id. at 6.

12018–2018
Pennsylvania Department of Banking v. NCAS of Delaware, LLC green
pacommwct · 2010
1 sentence

2011This does not mean that the Commonwealth has undertaken "trade or commerce" in the creation of its state park system. [7] See also Pennsylvania Department of Banking v. NCAS of Delaware LLC, 995 A.2d 422 (Pa.Cmwlth.2010) (Leavitt, J., concurring). [8] The origin of the parens patriae doctrine can be traced to medieval England.

12011–2011
Exparte Crouse green
· 1839
2 sentences

2006This Court propounded the parens patriae doctrine as the rationale by which the Commonwealth could accomplish child behavioral “reformation, by training [children] to industry; by imbuing their minds with principles of morality and religion; by furnishing them with means to earn a living; and, above all, by separating them from the corrupting influence of improper associates.” Crouse, 4 Whart. 9 , 1839 WL 3700 at *2.

2006This Court propounded the parens patriae doctrine as the rationale by which the Commonwealth could accomplish child behavioral "reformation, by training [children] to industry; by imbuing their minds with principles of morality and religion; by furnishing them with means to earn a living; and, above all, by separating them from the corrupting influence of improper associates." Crouse, 4 Whart. 9 , 1839 WL 3700 at *2.

12006–2006
Janet D. v. Carros green
pasuperct · 1976
2 sentences

1980In re William L., 477 Pa. 322, 338 , 383 A.2d 1228, 1236 (1978); Holmes Appeal, 379 Pa. 599, 603 , 109 A.2d 523 (1954); Janet D. v. Carros, supra, 240 Pa.Super. at 316 , 362 A.2d at 1072 . 6 We conclude that, pursuant to the doctrine of parens patriae, the juvenile court in this case stood in loco parentis to the mentally ill deprived child, Jerry G.

1980In re William L., 477 Pa. 322, 338 , 383 A.2d 1228, 1236 (1978); Holmes Appeal, 379 Pa. 599, 603 , 109 A.2d 523 (1954); Janet D. v. Carros, supra, 240 Pa.Super. at 316 , 362 A.2d at 1072 . 6 We conclude that, pursuant to the doctrine of parens patriae, the juvenile court in this case stood in loco parentis to the mentally ill deprived child, Jerry G.

11980–1980
Ciammaichella Appeal green
pa · 1952
2 sentences

1964Perhaps we are motivated by the doctrine of parens patriae but “The Commonwealth is vitally concerned with infants within its boundaries and an interested party in all matters affecting them.” Ciammaichella Appeal, 369 Pa. 278, 287 , 85 A. 2d 406 (1952).

1964Perhaps we are motivated by the doctrine of parens patriae but “The Commonwealth is vitally concerned with infants within its boundaries and an interested party in all matters affecting them.” Ciammaichella Appeal, 369 Pa. 278, 287 , 85 A. 2d 406 (1952).

11964–1964

Statutes the citing opinions construe

PA § 42 Pa. Cons. Stat. § 6301 (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

NJ 34 (1953–2025) IL 26 (1978–2024) CA 23 (1964–2025) NY 16 (1968–2025) PA 16 (1964–2021) OH 13 (1988–2026) MD 13 (1984–2021) IN 10 (1979–2023) TX 9 (1946–2024) FL 8 (1977–2015) CO 8 (1970–2025) MT 7 (1962–2012) MN 7 (1987–2018) KS 7 (1977–2004) OK 7 (1963–2012) WV 6 (1963–2024) VT 6 (1983–2024) NE 6 (1968–2020) AK 5 (1976–2024) IA 4 (1985–2020) AZ 4 (1965–2022) MA 4 (1979–2014) WA 4 (2014–2015) SC 3 (1989–2017) LA 3 (1971–2008) TN 3 (1998–2014) CT 2 (1992–2000) GA 2 (1982–1995) MO 2 (1950–1988) VA 2 (1995–2003) NM 2 (1954–1990) DC 2 (1985–2018) WI 2 (1980–2006) AL 2 (1937–2008) MS 2 (1969–1982) NC 2 (1985–2000) VI 2 (1977–2014) MI 2 (1993–2008)

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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