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15 Pennsylvania opinions name it 5 courts 1981–2025 4 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 |
|---|---|---|
Action Coalition of Elders v. Allegheny County Institution Districtgreen2 sentences1996The indispensable party rule requires that “a court should not adjudicate a case if an absentee was so closely related to the matters in dispute that further litigation would probably be required to define the position of the absentee or to protect the defendant.” Action Coalition v. Allegheny County Institution District, 493 Pa. 302, 311 , 426 A.2d 560, 564 (plurality) (1981). 1996The indispensable party rule requires that “a court should not adjudicate a case if an absentee was so closely related to the matters in dispute that further litigation would probably be required to define the position of the absentee or to protect the defendant.” Action Coalition v. Allegheny County Institution District, 493 Pa. 302, 311 , 426 A.2d 560, 564 (plurality) (1981). | 2 | 5 |
In Re: Est. of D.A.A., Appeal of: Anderson, R.green2 sentences2025See In re Estate of Anderson, 317 A.3d 997, 1005 (Pa. Super. 2024). 2025While it is true that Appellants challenged neither the legality of the transfer of the liquor license nor the failure to join the PLCB as a party in the court below, “the failure to join an indispensable party is a challenge to the court’s subject matter jurisdiction that cannot be waived.” In re Estate of Anderson, 317 A.3d 997, 1004 (Pa. Super. 2024). | 2 | 2 |
Mechanicsburg Area School District v. Klinegreen2 sentences2019The Defendant cited to Mechanicsburg Area S.cho0l District v. Kline, 494 Pa. 476 , 431 A.2d 953 (1981) for the proposition that "the indispensable party rule requires that a court should not adjudicate a case if an absentee was so closely related to the matters in dispute that further litigation would probably be required to protect the defendant." (Id., Paragraphs 10-12). 2019The Defendant cited to Mechanicsburg Area S.cho0l District v. Kline, 494 Pa. 476 , 431 A.2d 953 (1981) for the proposition that "the indispensable party rule requires that a court should not adjudicate a case if an absentee was so closely related to the matters in dispute that further litigation would probably be required to protect the defendant." (Id., Paragraphs 10-12). | 1 | 4 |
Turner, J. v. The Estate of Baird, D.green1 sentence2025“The want of jurisdiction over the subject matter may be questioned at any time . . . in the trial court, before or after judgment, or for the first time in an appellate court . . ..” Turner v. Estate of Baird, 270 A.3d 556, 560 (Pa. Super. 2022) (internal citations and quotation marks omitted). - 11 - J-A04036-25 To the extent we must address the Patronos’ indispensable party claim,9 the threshold question in that analysis is whether justice can be done in the absence of a third party. | 1 | 1 |
Lobos Management v. Powell, B.green1 sentence2025See id. | 1 | 1 |
Yorty v. PJM Interconnection, L.L.C.green1 sentence2025See Yorty, 79 A.3d at 660 . | 1 | 1 |
In Re:Petition of Navarra, S. Appeal of:Navarra,Cgreen2 sentences2024See In re Navarra, 185 A.3d 342 , 349 (Pa. Super. 2018). 2024See In re Navarra, 185 A.3d 342, 349 (Pa. Super. 2018). | 1 | 1 |
Cry, Inc. v. Mill Service, Inc.green1 sentence2019See CRY, Inc. v. Mill Serv., Inc., 640 A.2d 372, 377-78 (Pa. 1994). | 1 | 1 |
Oswald v. WB Public Square Associates, LLCgreen1 sentence2018See Oswald, 80 A.3d at 796 ; Mother’s Restaurant Inc. v. Krystkiewicz, 861 A.2d at 338 ; Erie Ins. | 1 | 1 |
Lsk v. Hangreen1 sentence2007Id. at 878. ¶ 25 Accordingly, we affirm the award of custody, vacate the award of support, and remand to the trial court with directions that Appellee Frampton be joined as an indispensable party for a hearing at which the support obligation of each litigant is to be recalculated. ¶26 Custody order affirmed. | 1 | 1 |
Keitt v. Rossgreen2 sentences1981My disagreement is that the instant problem is not to be solved by refining the indispensable party test, but rather by a reevaluation of the reasoning of Keitt v. Ross, 17 Pa.Cmwlth. 183 , 331 A.2d 582 (1975). 1981My disagreement is that the instant problem is not to be solved by refining the indispensable party test, but rather by a reevaluation of the reasoning of Keitt v. Ross, 17 Pa.Cmwlth. 183 , 331 A.2d 582 (1975). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Mother's Restaurant, Inc. v. Krystkiewicz
green
1 sentence2018See Oswald, 80 A.3d at 796 ; Mother’s Restaurant Inc. v. Krystkiewicz, 861 A.2d at 338 ; Erie Ins. | 1 | 2018–2018 |
Pennsylvania Dental Ass'n v. Commonwealth
green
2 sentences1993Pennsylvania Dental Association v. Insurance Department, 126 Pa. Commonwealth Ct. 628 , 560 A.2d 870 (1989); Pennsylvania State Education Association v. Department of Education, 101 Pa.Commonwealth Ct. 497, 516 A.2d 1308 (1986). 1993Pennsylvania Dental Association v. Insurance Department, 126 Pa. Commonwealth Ct. 628 , 560 A.2d 870 (1989); Pennsylvania State Education Association v. Department of Education, 101 Pa.Commonwealth Ct. 497, 516 A.2d 1308 (1986). | 1 | 1993–1993 |
Pa. St. Ed. Asso. v. Dept. of Ed.
green
1 sentence1993Pennsylvania Dental Association v. Insurance Department, 126 Pa. Commonwealth Ct. 628 , 560 A.2d 870 (1989); Pennsylvania State Education Association v. Department of Education, 101 Pa.Commonwealth Ct. 497, 516 A.2d 1308 (1986). | 1 | 1993–1993 |
Duquesne Light Co. v. Monroeville Borough
green
2 sentences1983Duquesne Light Co. v. Monroeville Borough, 449 Pa. 573 , 298 A.2d 252 (1972) (location of facilities) ; Chester County v. Philadelphia Electric Co., 420 Pa. 422 , 218 A.2d 331 (1966) (location of facilities) ; Landsdale Borough v. Philadelphia Electric Co., 403 Pa. 647 , 170 A.2d 565 (1961) (location of facilities) ; Duquesne Light Co. v. Upper St. 1983Duquesne Light Co. v. Monroeville Borough, 449 Pa. 573 , 298 A.2d 252 (1972) (location of facilities) ; Chester County v. Philadelphia Electric Co., 420 Pa. 422 , 218 A.2d 331 (1966) (location of facilities) ; Landsdale Borough v. Philadelphia Electric Co., 403 Pa. 647 , 170 A.2d 565 (1961) (location of facilities) ; Duquesne Light Co. v. Upper St. | 1 | 1983–1983 |
Chester County v. Philadelphia Electric Co.
green
2 sentences1983Duquesne Light Co. v. Monroeville Borough, 449 Pa. 573 , 298 A.2d 252 (1972) (location of facilities) ; Chester County v. Philadelphia Electric Co., 420 Pa. 422 , 218 A.2d 331 (1966) (location of facilities) ; Landsdale Borough v. Philadelphia Electric Co., 403 Pa. 647 , 170 A.2d 565 (1961) (location of facilities) ; Duquesne Light Co. v. Upper St. 1983Duquesne Light Co. v. Monroeville Borough, 449 Pa. 573 , 298 A.2d 252 (1972) (location of facilities) ; Chester County v. Philadelphia Electric Co., 420 Pa. 422 , 218 A.2d 331 (1966) (location of facilities) ; Landsdale Borough v. Philadelphia Electric Co., 403 Pa. 647 , 170 A.2d 565 (1961) (location of facilities) ; Duquesne Light Co. v. Upper St. | 1 | 1983–1983 |
Lansdale Borough v. Philadelphia Electric Co.
green
1 sentence1983Duquesne Light Co. v. Monroeville Borough, 449 Pa. 573 , 298 A.2d 252 (1972) (location of facilities) ; Chester County v. Philadelphia Electric Co., 420 Pa. 422 , 218 A.2d 331 (1966) (location of facilities) ; Landsdale Borough v. Philadelphia Electric Co., 403 Pa. 647 , 170 A.2d 565 (1961) (location of facilities) ; Duquesne Light Co. v. Upper St. | 1 | 1983–1983 |
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.