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106 Pennsylvania opinions name it 6 courts 1931–2026 29 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. Mentzergreen2 sentences2025Relevant factors for Rule 564 prejudice include: (1) whether the amendment changes the factual scenario supporting the charges; (2) whether the amendment adds new facts previously unknown to the defendant; (3) whether the entire factual scenario was developed during a preliminary hearing; (4) whether the description of the charges changed with the amendment; (5) whether a change in defense strategy was necessitated by the amendment; and (6) whether the timing of the Commonwealth’s request for amendment allowed for ample notice and preparation. - 11 - J-S27025-25 Commonwealth v. Mentzer, 18 A.3 2024In determining whether a defendant would suffer prejudice, the following factors are taken into consideration: (1) whether the amendment changes the factual scenario supporting the charges; (2) whether the amendment adds new facts previously unknown to the defendant; (3) whether the entire factual scenario was developed during a preliminary hearing; (4) whether the description of the charges changed with the amendment; (5) whether a change in defense strategy was necessitated by the amendment; and (6) whether the timing of the Commonwealth’s request for amendment allowed for ample notice and p | 16 | 21 |
Commonwealth v. Sinclairgreen2 sentences2025Sinclair, 897 A.2d at 1223 (citation omitted). -8- J-S15005-25 In determining whether a defendant suffered prejudice, we consider the following factors: (1) whether the amendment changes the factual scenario supporting the charges; (2) whether the amendment adds new facts previously unknown to the defendant; (3) whether the entire factual scenario was developed during a preliminary hearing; (4) whether the description of the charges changed with the amendment; (5) whether a change in defense strategy was necessitated by the amendment; and (6) whether the timing of the Commonwealth's request fo 2018If so, then the defendant is deemed to have been placed on notice regarding his alleged criminal conduct." Id. (quoting Commonwealth v. Davalos, 779 A.2d 1190, 1194 (Pa.Super. 2001)). 5 The Superior Court has set out some of the factors to be considered when determining whether the defendant will be prejudiced by the amendment: "( 1) whether the amendment changes the factual scenario supporting the charges; (2) whether the amendment adds new facts previously unknown to the defendant; (3) whether the entire factual scenario was developed during a preliminary hearing; (4) whether the de- scripti | 15 | 34 |
Commonwealth v. Grekisgreen2 sentences2021Sinclair, supra (citing Commonwealth v. Grekis, 601 A.2d 1284, 1292 (Pa. Super. 1992)). 2021Sinclair, supra (citing Commonwealth v. Grekis, 601 A.2d 1284, 1292 (Pa. Super. 1992)). | 5 | 7 |
Commonwealth v. Witmayergreen2 sentences2018Upon amendment, the court may grant such postponement of trial or other relief as is necessary in the interests of justice. 5 The rule at issue in Brown was Rule 229, which was subsequently renumbered as Rule 564 in 2000. 6 Again, those considerations include "(1) whether the amendment changes the factual scenario supporting the charges; (2) whether the amendment adds new facts previously unknown to the defendant; (3) whether the entire factual scenario was developed during a preliminary hearing; (4) whether the description of the charges changed with the amendment; (5) whether a change in def 2018If so, then the defendant is deemed to have been placed on notice regarding his alleged criminal conduct." Id. (quoting Commonwealth v. Davalos, 779 A.2d 1190, 1194 (Pa.Super. 2001)). 5 The Superior Court has set out some of the factors to be considered when determining whether the defendant will be prejudiced by the amendment: "( 1) whether the amendment changes the factual scenario supporting the charges; (2) whether the amendment adds new facts previously unknown to the defendant; (3) whether the entire factual scenario was developed during a preliminary hearing; (4) whether the de- scripti | 5 | 6 |
Commonwealth v. Rosergreen2 sentences2025Relevant factors for Rule 564 prejudice include: (1) whether the amendment changes the factual scenario supporting the charges; (2) whether the amendment adds new facts previously unknown to the defendant; (3) whether the entire factual scenario was developed during a preliminary hearing; (4) whether the description of the charges changed with the amendment; (5) whether a change in defense strategy was necessitated by the amendment; and (6) whether the timing of the Commonwealth’s request for amendment allowed for ample notice and preparation. - 11 - J-S27025-25 Commonwealth v. Mentzer, 18 A.3 2024In determining whether an amendment prejudiced a defendant, the court considers, inter alia, whether “a change in defense strategy was necessitated[.]” Commonwealth v. Roser, 914 A.2d 447, 454 (Pa. Super. 2006) (citation omitted). | 4 | 9 |
Commonwealth v. Beckgreen2 sentences2023See 18 Pa.C.S.A. § 306(c). - 21 - J-A08003-23 We turn to the fifth factor, “whether a change in defense strategy was necessitated by the amendment.” Beck, 78 A.3d at 660 . 2023See 18 Pa.C.S.A. § 306(c). - 21 - J-A08003-23 We turn to the fifth factor, “whether a change in defense strategy was necessitated by the amendment.” Beck, 78 A.3d at 660 . | 4 | 6 |
Commonwealth v. Veongreen2 sentences2019Commonwealth v. Witmayer, 144 A.3d 949 (Pa. Super. 2016); Commonwealth v. Veon, 109 A.3d 754 (Pa. Super.2015). 2017Id. | 3 | 8 |
Commonwealth v. Williamsgreen2 sentences2022Commonwealth v. Jackson, 2019 PA Super 221 , 215 A.3d 972 , 979--80 (2019) (internal citations omitted). 30 Appellant relied on Commonwealth v. Mentzer, 18 A.3d 1200, 1203 (Pa. Super., 2011) and Commonwealth v. Williams, 2017 PA Super 204 , 166 A.3d 460, 462 (2017) t0 support his position, neither of which are particularly helpful to said position. 2022Commonwealth v. Jackson, 2019 PA Super 221 , 215 A.3d 972 , 979--80 (2019) (internal citations omitted). 30 Appellant relied on Commonwealth v. Mentzer, 18 A.3d 1200, 1203 (Pa. Super., 2011) and Commonwealth v. Williams, 2017 PA Super 204 , 166 A.3d 460, 462 (2017) t0 support his position, neither of which are particularly helpful to said position. | 2 | 2 |
Commonwealth v. Browngreen2 sentences2018See Brown, 727 A.2d at 543 (concluding prejudice results if new charges render defenses to original charges ineffective). 2017(Citing Commonwealth v. Brown, 556 Pa. 131, 135 , 727 A.2d 541, 543 (1999)). 49 Id. | 2 | 2 |
Commonwealth v. Davalosgreen2 sentences2018If so, then the defendant is deemed to have been placed on notice regarding his alleged criminal conduct." Id. (quoting Commonwealth v. Davalos, 779 A.2d 1190, 1194 (Pa.Super. 2001)). 5 The Superior Court has set out some of the factors to be considered when determining whether the defendant will be prejudiced by the amendment: "( 1) whether the amendment changes the factual scenario supporting the charges; (2) whether the amendment adds new facts previously unknown to the defendant; (3) whether the entire factual scenario was developed during a preliminary hearing; (4) whether the de- scripti 2018If so, then the defendant is deemed to have been placed on notice regarding his alleged criminal conduct." Id. (quoting Commonwealth v. Davalos, 779 A.2d 1190, 1194 (Pa.Super. 2001)). 5 The Superior Court has set out some of the factors to be considered when determining whether the defendant will be prejudiced by the amendment: "( 1) whether the amendment changes the factual scenario supporting the charges; (2) whether the amendment adds new facts previously unknown to the defendant; (3) whether the entire factual scenario was developed during a preliminary hearing; (4) whether the de- scripti | 2 | 2 |
Commonwealth v. Pagegreen2 sentences2017In Page, we stated that the factors to be considered when determining whether a defendant was prejudiced by the Commonwealth's amendment include: “whether the amendment changes the factual scenario; whether new facts, previously unknown to appellant, were added; whether the description of the charges changed; whether the amendment -4- J-S21009-17 necessitated a change in defense strategy; and whether the timing of the request for the amendment allowed for ample notice and preparation by [defendant].” Id. 2015Factors to be considered when determining whether Appellant was prejudiced by the Commonwealth's 7 Circulated 10/13/2015 11:03 AM amendment include "whether the amendment changes the factual scenario; whether new facts, previously unknown to appellant, were added; whether the description of the charges changed; whether the amendment necessitated a change in defense strategy; and whether the timing of the request for the amendment allowed for ample notice and preparation by appellant." Id. | 1 | 4 |
Commonwealth v. Quinonesgreen2 sentences2023As a result, a change in defense strategy was necessitated in order to defend against the new charges, which were unrelated to the original charges and painted a different picture of the events[.] - 18 - J-A08003-23 Quinones, 200 A.3d at 1012-13 . 2023As a result, a change in defense strategy was necessitated in order to defend against the new charges, which were unrelated to the original charges and painted a different picture of the events[.] - 18 - J-A08003-23 Quinones, 200 A.3d at 1012-13 . | 1 | 2 |
Commonwealth v. Hoffmangreen1 sentence2023Commonwealth v. Hoffman, 198 A.3d 1112, 1122 (Pa.Super. 2018) (quoting Commonwealth v. Mentzer, 18 A.3d 1200, 1203 (Pa.Super. 2011)). | 1 | 1 |
Com. v. Sandoval, J.green1 sentence2022Id. (citations omitted). “[T]he test is whether the crimes specified in the original indictment or information involve the same basic elements and evolved out of the same factual situation as the crimes specified in the amended indictment or information.” Sandoval, 266 A.3d at 1102 (citation and internal quotation marks omitted). | 1 | 1 |
Commonwealth v. Picchiantigreen2 sentences2018Id. (citation omitted) .... 'The mere possibility amendment of information may result in a more severe penalty ... is not, of itself, prejudice.' Commonwealth v. Picchianti, 410 Pa.Super. 563 , 600 A.2d 597, 599 (1991 ), appeal denied, 530 Pa. 660 , 609 A.2d 168 (1992). 2018Id. (citation omitted) .... 'The mere possibility amendment of information may result in a more severe penalty ... is not, of itself, prejudice.' Commonwealth v. Picchianti, 410 Pa.Super. 563 , 600 A.2d 597, 599 (1991 ), appeal denied, 530 Pa. 660 , 609 A.2d 168 (1992). | 1 | 1 |
Commonwealth v. Brickergreen1 sentence2018Commonwealth v. Bricker, 882 A.2d 1008, 1019 (Pa. Super. 2005). | 1 | 1 |
McCarthy v. Unemployment Compensation Board of Reviewgreen2 sentences2005“The question of whether a unilateral change in terms of employment constitutes ‘cause of a necessitous and compelling nature’ is subject to a substantial change analysis.” McCarthy v. Unemployment Compensation Board of Review, 829 A.2d 1266, 1270 (Pa.Cmwlth.2003) (quoting Kaolin Mushroom Farms v. Unemployment Compensation Board of Review, 669 A.2d 438 , 442 n. 3 (Pa.Cmwlth.1995)). 2005McCarthy, 829 A.2d. at 1271 . 3 The Board did not engage in a substantial change analysis, and its factual findings are lacking on that issue. | 1 | 1 |
| Commonwealth v. Chilcotegreen | 1 | 1 |
| Commonwealth v. Ernstgreen | 1 | 1 |
| Opperman's Estate (No. 1)green | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Com. v. POSTLEY
green
2 sentences2021Commonwealth v. Jackson, 215 A.3d 972 , 979-80 (Pa. Super. 2019), appeal denied, 927 A.2d 624 (2007); Sinclair, 897 A.2d at 1223 . 2014Commonwealth v. Roser, 914 A.2d 447, 454 (Pa. Super. 2006), appeal denied 592 Pa. 788 , 927 A.2d 624 (Pa. 2007); Sinclair, 897 A.2d at 1223 . - 13 - J-S72012-14 Factors to be considered when determining whether [an a]ppellant was prejudiced by the Commonwealth's amendment include whether the amendment changes the factual scenario; whether new facts, previously unknown to [the] appellant, were added; whether the description of the charges changed; whether the amendment necessitated a change in defense strategy; and whether the timing of the request for the amendment allowed for ample notice and | 2 | 2014–2021 |
Kaolin Mushroom Farms, Inc. v. Unemployment Compensation Board of Review
neutral
2 sentences2005"The question of whether a unilateral change in terms of employment constitutes `cause of a necessitous and compelling nature' is subject to a substantial change analysis." McCarthy v. Unemployment Compensation Board of Review, 829 A.2d 1266, 1270 (Pa.Cmwlth.2003) (quoting Kaolin Mushroom Farms v. Unemployment Compensation Board of Review, 669 A.2d 438 , 442 n. 3 (Pa.Cmwlth.1995)). 2005“The question of whether a unilateral change in terms of employment constitutes ‘cause of a necessitous and compelling nature’ is subject to a substantial change analysis.” McCarthy v. Unemployment Compensation Board of Review, 829 A.2d 1266, 1270 (Pa.Cmwlth.2003) (quoting Kaolin Mushroom Farms v. Unemployment Compensation Board of Review, 669 A.2d 438 , 442 n. 3 (Pa.Cmwlth.1995)). | 2 | 2003–2005 |
Steinberg Vision v. Unemp. Comp. Bd.
green
2 sentences2003“The question of whether a unilateral change in terms of employment constitutes ‘cause of a necessitous and compelling nature’ is subject to a substantial change analysis.” Kaolin Mushroom Farms v. Unemployment Compensation Board of Review, 669 A.2d 438 , 442 n. 3 (Pa.Cmwlth.1995) (quoting Steinberg Vision Associates v. Unemployment Compensation Board of Review, 154 Pa.Cmwlth. 486 , 624 A.2d 237 (1993)). 2003“The question of whether a unilateral change in terms of employment constitutes ‘cause of a necessitous and compelling nature’ is subject to a substantial change analysis.” Kaolin Mushroom Farms v. Unemployment Compensation Board of Review, 669 A.2d 438 , 442 n. 3 (Pa.Cmwlth.1995) (quoting Steinberg Vision Associates v. Unemployment Compensation Board of Review, 154 Pa.Cmwlth. 486 , 624 A.2d 237 (1993)). | 2 | 1995–2003 |
Com. v. Belgrave, J.
green
1 sentence2024There are six factors that the court must consider in determining whether an amendment is prejudicial to the defendant: (1) Whether the amendment changes the factual scenario supporting the charges; (2) whether the amendment adds new facts previously unknown to the defendant; (3) whether the entire factual scenario was developed during a preliminary hearing; (4) whether the description of the charges changed with the amendment; (5) whether a change in defense strategy was necessitated by the amendment; and (6) whether the timing of the Commonwealth’s request for amendment allowed for ample not | 1 | 2024–2024 |
Alabama Insurance Guaranty Ass'n v. Reliance Insurance Co. in Liquidation
green
1 sentence2016Commonwealth v. Veon, 109 A.3d 754, 768 (Pa.Super. 2015), appeal granted in part, 121 A.3d 954 (Pa. 2015) (citation omitted). | 1 | 2016–2016 |
Com. v. Morgan
green
1 sentence2014Commonwealth v. Roser, 914 A.2d 447, 454 (Pa. Super. 2006), appeal denied 592 Pa. 788 , 927 A.2d 624 (Pa. 2007); Sinclair, 897 A.2d at 1223 . - 13 - J-S72012-14 Factors to be considered when determining whether [an a]ppellant was prejudiced by the Commonwealth's amendment include whether the amendment changes the factual scenario; whether new facts, previously unknown to [the] appellant, were added; whether the description of the charges changed; whether the amendment necessitated a change in defense strategy; and whether the timing of the request for the amendment allowed for ample notice and | 1 | 2014–2014 |
D'Antona v. Hampton Grinding Wheel Co.
green
2 sentences2005Eck v. Powermatic Houdaille, 364 Pa. Super. 178 , 527 A.2d 1012 (1987); Thompson v. Motch & Merryweather Machinery, 358 Pa. Super. 149 , 516 A.2d 1226 (1986); D’Antona v. Hampton Grinding Wheel Company, 225 Pa. Super. 120 , 310 A.2d 307 (1973). 2005Eck v. Powermatic Houdaille, 364 Pa. Super. 178 , 527 A.2d 1012 (1987); Thompson v. Motch & Merryweather Machinery, 358 Pa. Super. 149 , 516 A.2d 1226 (1986); D’Antona v. Hampton Grinding Wheel Company, 225 Pa. Super. 120 , 310 A.2d 307 (1973). | 1 | 2005–2005 |
Eck v. Powermatic Houdaille
green
2 sentences2005Eck v. Powermatic Houdaille, 364 Pa. Super. 178 , 527 A.2d 1012 (1987); Thompson v. Motch & Merryweather Machinery, 358 Pa. Super. 149 , 516 A.2d 1226 (1986); D’Antona v. Hampton Grinding Wheel Company, 225 Pa. Super. 120 , 310 A.2d 307 (1973). 2005Eck v. Powermatic Houdaille, 364 Pa. Super. 178 , 527 A.2d 1012 (1987); Thompson v. Motch & Merryweather Machinery, 358 Pa. Super. 149 , 516 A.2d 1226 (1986); D’Antona v. Hampton Grinding Wheel Company, 225 Pa. Super. 120 , 310 A.2d 307 (1973). | 1 | 2005–2005 |
Thompson v. Motch & Merryweather MacHinery Co.
green
2 sentences2005Eck v. Powermatic Houdaille, 364 Pa. Super. 178 , 527 A.2d 1012 (1987); Thompson v. Motch & Merryweather Machinery, 358 Pa. Super. 149 , 516 A.2d 1226 (1986); D’Antona v. Hampton Grinding Wheel Company, 225 Pa. Super. 120 , 310 A.2d 307 (1973). 2005Eck v. Powermatic Houdaille, 364 Pa. Super. 178 , 527 A.2d 1012 (1987); Thompson v. Motch & Merryweather Machinery, 358 Pa. Super. 149 , 516 A.2d 1226 (1986); D’Antona v. Hampton Grinding Wheel Company, 225 Pa. Super. 120 , 310 A.2d 307 (1973). | 1 | 2005–2005 |
Office of Disciplinary Counsel v. Zdrok
green
1 sentence2000Thus, there is simply no retroactive application of a law. 645 A.2d at 834 . | 1 | 2000–2000 |
Pacewicz v. Young
green
1 sentence1999Although the substantial change analysis is generally more favorable to employers than the strike/ lock-out analysis under Vrotney Unemployment Compensation Case, 400 Pa. 440 , 163 A.2d 91 (1960), the referee determined that Employer unilaterally imposed a substantial change and concluded that Petitioners were eligible for benefits. | 1 | 1999–1999 |
Erie Forge & Steel Corp. v. Unemployment Compensation Board of Review
green
1 sentence1999Although the substantial change analysis is generally more favorable to employers than the strike/ lock-out analysis under Vrotney Unemployment Compensation Case, 400 Pa. 440 , 163 A.2d 91 (1960), the referee determined that Employer unilaterally imposed a substantial change and concluded that Petitioners were eligible for benefits. | 1 | 1999–1999 |
Farber v. Perkiomen Mutual Insurance
green
1 sentence1997The plain language of Farber invites the insurance companies to change the terms of their policies if they dislike the result in that case. "[I]f the [companies] wish to bring about a different result ... they will have to change the terms of their policies in order to achieve that end.” Farber, 88 A.2d at 780 . | 1 | 1997–1997 |
| Commonwealth v. DeSumma green | 1 | 1991–1991 |
| United States v. Johnson red | 1 | 1982–1982 |
| Chesapeake & Ohio Railway Co. v. Kelly green | 1 | 1980–1980 |
| Steele v. Sheppard green | 1 | 1975–1975 |
| Land Title Bank & Trust Co. v. Cheltenham National Bank green | 1 | 1975–1975 |
| Thompson Maple Products, Inc. v. Citizens National Bank green | 1 | 1973–1973 |
| Loraine v. Pittsburg, Johnstown, Ebensburg & Eastern Railroad green | 1 | 1968–1968 |
| Joseph Aguilar Gaitan and Dolores Marie Gaitan v. United States green | 1 | 1963–1963 |
| United States v. Gilberto Santana green | 1 | 1963–1963 |
| Cooper v. Pate green | 1 | 1963–1963 |
| Crawford Estate green | 1 | 1962–1962 |
| Shaffer v. Hoke neutral | 1 | 1940–1940 |
| Forrest v. Safety Banking & Trust Co. neutral | 1 | 1940–1940 |
| G. B. Hurt, Inc. v. Fuller Canneries Co. green | 1 | 1936–1936 |
| Mindlin v. Saxony Spinning Co. green | 1 | 1931–1931 |
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.