Ortiz rule (Pennsylvania) · Go Syfert
← Pennsylvania issues

Ortiz rule in Pennsylvania

12 Pennsylvania opinions name it 1 courts 1993–2026 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.

Followed or applied (7)

CaseFollowedCited
Mentzer v. Ognibenegreen
pasuperct · 1991 · cited in 2 Pennsylvania opinions naming this issue, 1993–2018
2 sentences

2018Edwards v. Franklin & Marshall College, 663 A.2d 187, 190 (Pa.Super. 1995), quoting Mentzer, 597 A.2d at 610 .

2018Edwards v. Franklin & Marshall College, 663 A.2d 187, 190 (Pa.Super. 1995), quoting Mentzer, 597 A.2d at 610 .

12
Commonwealth v. Mrozikgreen
pasuperct · 2019 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
1 sentence

2024“Sentencing is vested in the discretion of the trial court, and will not be disturbed absent a manifest abuse of that discretion.” Mrozik, 213 A.3d at 276 (citation omitted).

11
Com. v. Ramos, A.green
pasuperct · 2020 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
2 sentences

2024Issues not raised in the trial court are waived and cannot be raised for the first time on appeal See Pa.R.A.P. 302(a); see also Commonwealth v. Ramos, 231 A.3d 955, 957 (Pa. Super. 2020) (stating "[i]t is settled that an appellant’s failure to raise a contemporaneous objection to evidence at trial waives that claim on appeal”) (internal quotation marks and citations omitted).

2024Issues not raised in the trial court are waived and cannot be raised for the first time on appeal See Pa.R.A.P. 302(a); see also Commonwealth v. Ramos, 231 A.3d 955 , 957 (Pa. Super. 2020) (stating "[i]t is settled that an appellant’s failure to raise a contemporaneous objection to evidence at trial waives that claim on appeal”) (internal quotation marks and citations omitted).

11
Com. v. Smith, S.green
pasuperct · 2020 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
1 sentence

2021See Commonwealth v. Smith, 240 A.3d 654, 658 (Pa.Super. 2020).

11
Edwards v. Franklin & Marshall Collegegreen
pasuperct · 1995 · cited in 1 Pennsylvania opinions naming this issue, 2018–2018
2 sentences

2018Edwards v. Franklin & Marshall College, 663 A.2d 187, 190 (Pa.Super. 1995), quoting Mentzer, 597 A.2d at 610 .

2018Edwards v. Franklin & Marshall College, 663 A.2d 187, 190 (Pa.Super. 1995), quoting Mentzer, 597 A.2d at 610 .

11
Commonwealth v. Kempgreen
pasuperct · 2008 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
2 sentences

2016We also noted in Kemp that “the Ortiz position has not been accepted in the federal system.” Id. at 1260 ; see also id. at 1259-60 (discussing three federal circuit court decisions that rejected the Ortiz rule).

2016We also noted in Kemp that “the Ortiz position has not been accepted in the federal system.” Id. at 1260 ; see also id. at 1259-60 (discussing three federal circuit court decisions that rejected the Ortiz rule).

11
Commonwealth v. Eichingergreen
pa · 2007 · cited in 1 Pennsylvania opinions naming this issue, 2014–2014
1 sentence

2014Our standard of review in this context is well-established: ther the evidence admitted at trial, and all reasonable inferences drawn from that evidence, when viewed in the light most favorable to the Commonwealth as verdict[-]winner, was sufficient to enable the fact[-]finder to conclude that the Commonwealth established all Commonwealth v. Eichinger, 915 A.2d 1122, 1130 (Pa. 2007).

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 (9)

CaseCitedYears
Ortiz v. Ra-El Development Corp. green
pa · 1987
2 sentences

1995Even if we were to disagree with this conclusion, it is clear from the record that Edwards cannot satisfy the second prong of the Ortiz test, that is, “the risk is different from the usual and ordinary risk associated with the general type of work done[.]” Id. 53, 528 A.2d at 1358 .

1995Even if we were to disagree with this conclusion, it is clear from the record that Edwards cannot satisfy the second prong of the Ortiz test, that is, “the risk is different from the usual and ordinary risk associated with the general type of work done[.]” Id. 53, 528 A.2d at 1358 .

21993–1995
Commonwealth v. Simmons green
pa · 2014
1 sentence

2026Notably, at the time of Ortiz’s suppression motion and hearing, the warrantless search of the vehicle was subject to our Supreme Court’s plurality ruling in Commonwealth v. Gary, 91 A.3d 102 (Pa. 2014) (plurality opinion announcing judgment of court), which held that the search and seizure provision of Article I, Section 8 of the Pennsylvania Constitution provided no greater protection than did the Fourth Amendment to the United States Constitution with regard to warrantless searches of automobiles.

12026–2026
Miranda v. Arizona green
scotus · 1966
1 sentence

2025Trial Court Opinion, 6/18/2024, at 21-23 (party designation altered; unnecessary capitalization omitted). ____________________________________________ 15 Miranda v. Arizona, 384 U.S. 436 (1966). - 23 - J-S09024-25 In its opinion before this Court, the trial court addressed Ortiz’s claim that the cell phone video evidence was illegally obtained: Ortiz contended in the hearing on June 3, 2022, that his mother was the one who discovered the evidence on Ortiz’s phone and turned it in to the police, but that she lacked authorization to use the phone because it was in Ortiz’s possession and under hi

12025–2025
Commonwealth v. Finley green
pa · 1988
1 sentence

2023This Court, in a divided memorandum, ____________________________________________ 1 See Commonwealth v. Turner, 544 A.2d 927 (Pa. 1988); Commonwealth v. Finley, 550 A.2d 213 (Pa. Super. 1988) (en banc). -2- J-S44001-22 vacated the order and remanded the case to the PCRA court for reconsideration of Ortiz’s challenge to SORNA, pursuant to Commonwealth v. Lacombe, 234 A.3d 602 (Pa. 2020).

12023–2023
Commonwealth v. Turner green
pa · 1988
1 sentence

2023This Court, in a divided memorandum, ____________________________________________ 1 See Commonwealth v. Turner, 544 A.2d 927 (Pa. 1988); Commonwealth v. Finley, 550 A.2d 213 (Pa. Super. 1988) (en banc). -2- J-S44001-22 vacated the order and remanded the case to the PCRA court for reconsideration of Ortiz’s challenge to SORNA, pursuant to Commonwealth v. Lacombe, 234 A.3d 602 (Pa. 2020).

12023–2023
Strickland v. Washington green
scotus · 1984
1 sentence

2022Because Ortiz satisfied a time bar for this claim, we will review the merits of his claim that counsel was ineffective. ____________________________________________ 9 Strickland v. Washington, 466 U.S. 668 (1984). -9- J-S06020-22 We presume counsel was effective and a petitioner bears the burden of proving otherwise.

12022–2022
Gutteridge v. A.P. Green Services, Inc. green
pasuperct · 2002
2 sentences

2018This court determined that “a material issue of fact exists as to whether the risk presented by [defendant’s] saw-tooth roof was ‘different from the ordinary and usual risk associated with [repairing a roof.]’” Beam, No. 514 WDA 2013 at *18, citing Gutteridge, 804 A.2d at 657 .

2018This court determined that “a material issue of fact exists as to whether the risk presented by [defendant’s] saw-tooth roof was ‘different from the ordinary and usual risk associated with [repairing a roof.]’” Beam, No. 514 WDA 2013 at *18, citing Gutteridge, 804 A.2d at 657 .

12018–2018
Commonwealth v. Freeman green
pa · 2000
2 sentences

2016Additionally, we stressed in Kemp that the Ortiz rule was not supported by our Supreme Court’s reasoning in Commonwealth v. Freeman, 757 A.2d 903 (Pa. 2000), the case on which Ortiz relied.

2016Additionally, we stressed in Kemp that the Ortiz rule was not supported by our Supreme Court’s reasoning in Commonwealth v. Freeman, 757 A.2d 903 (Pa. 2000), the case on which Ortiz relied.

12016–2016
Peffer v. Penn 21 Associates green
pasuperct · 1991
2 sentences

1993Applying the second prong of the Ortiz test, we held that “construction work on a ladder while tightening bolts of a steel structure is not a peculiar risk for an individual employed by a steel erector company.” Id. at 466, 594 A.2d at 714 .

1993Applying the second prong of the Ortiz test, we held that “construction work on a ladder while tightening bolts of a steel structure is not a peculiar risk for an individual employed by a steel erector company.” Id. at 466, 594 A.2d at 714 .

11993–1993

Where else courts name it

KS 57 (1991–2026) CA 21 (1982–2025) TX 19 (1980–2025) PA 12 (1993–2026) FL 5 (1991–2026) AZ 3 (2006–2024) MA 3 (2013–2025) NY 3 (1998–2009) DE 2 (2015–2025) IN 2 (2017–2020) ID 2 (2025–2025) OH 2 (2017–2017) IA 2 (2010–2016)

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.

← Caselaw search · G Cite Topics · Brief Check