conflict preemption doctrine (Pennsylvania) · Go Syfert
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conflict preemption doctrine in Pennsylvania

11 Pennsylvania opinions name it 2 courts 2006–2022 2 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 (8)

CaseFollowedCited
Fross v. County of Alleghenygreen
pa · 2011 · cited in 3 Pennsylvania opinions naming this issue, 2011–2022
2 sentences

2022See Fross, 20 A.3d at 1194-95 . 9 The Supreme Court disagreed with the County, concluding that the ordinance interfered with the intent of the General Assembly in adopting Megan’s Law and the Sentencing and Parole Codes and was, therefore, invalid under the conflict preemption doctrine.

2022Id. at 1195 .

23
Orson, Inc. T/a Roxy Screening Rooms v. Miramax Film Corp.green
ca3 · 1999 · cited in 2 Pennsylvania opinions naming this issue, 2006–2006
2 sentences

2006Orson, 189 F.3d at 381-82 (citations omitted) (emphasis added).

2006Orson, 189 F.3d at 381-82 (citations omitted) (emphasis added).

22
Hoffman Mining Co. v. Zoning Hearing Boardgreen
pa · 2011 · cited in 3 Pennsylvania opinions naming this issue, 2018–2022
2 sentences

2022Relevant here, the conflict preemption doctrine is applicable where “simultaneous compliance with both [a] local ordinance and [a] state statute is impossible” or where the local enactment “stands as an obstacle to the execution of the full purposes of the statute.” Hoffman Mining Co., Inc. v. Zoning Hearing Bd. of Adams Twp., Cambria Cnty., 32 A.3d 587, 594 (Pa. 2011).

2019As previously noted, the NMA does not preempt the entire field of nutrient management, see Majority Opinion at 14-15; thus, a conflict preemption analysis is warranted. “[C]onflict preemption require[s] an analysis of whether preemption is implied in or implicit from the text of the whole statute, which may or may not include an express preemption clause.” Hoffman Mining, 32 A.3d at 594 , citing Cellucci v. Gen.

13
UGI Utilities, Inc. v. City of Reading and PA PUCgreen
pacommwct · 2017 · cited in 1 Pennsylvania opinions naming this issue, 2022–2022
1 sentence

2022See UGI Utils., Inc. v. City of Reading, 179 A.3d 624, 629 (Pa. Cmwlth. 2017) (“Preemption is not limited to state statutes; both state statutes and state regulations may preempt local ordinances.”).

11
Cellucci v. General Motors Corp.green
pa · 1998 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
1 sentence

2019Motors Corp., 706 A.2d 806, 809 (Pa. 1998).

11
Department of Licenses & Inspections v. Webergreen
pa · 1959 · cited in 1 Pennsylvania opinions naming this issue, 2011–2011
2 sentences

2011See Nutter v. Dougherty, 595 Pa. 340 , 938 A.2d 401 (2007); Mars EMS, 740 A.2d 193 ; Marcincin, 515 A.2d 1320 , Dep't of Licenses & Inspections v. Weber, 394 Pa. 466 , 147 A.2d 326 (1959) ( "Weber" ). *919 Among relevant types of ordinances that this Court has found valid against a conflict preemption challenge are enactments that added locally-tailored conditions to broad state pronouncements on a given course of conduct, and ordinances that defined prerequisites for operating a business in the municipality which exceeded the licensing requirements imposed by the state statute.

2011See Nutter v. Dougherty, 595 Pa. 340 , 938 A.2d 401 (2007); Mars EMS, 740 A.2d 193 ; Marcincin, 515 A.2d 1320 , Dep't of Licenses & Inspections v. Weber, 394 Pa. 466 , 147 A.2d 326 (1959) ( "Weber" ). *919 Among relevant types of ordinances that this Court has found valid against a conflict preemption challenge are enactments that added locally-tailored conditions to broad state pronouncements on a given course of conduct, and ordinances that defined prerequisites for operating a business in the municipality which exceeded the licensing requirements imposed by the state statute.

11
Nutter v. Doughertygreen
pa · 2007 · cited in 1 Pennsylvania opinions naming this issue, 2011–2011
2 sentences

2011See Nutter v. Dougherty, 595 Pa. 340 , 938 A.2d 401 (2007); Mars EMS, 740 A.2d 193 ; Marcincin, 515 A.2d 1320 , Dep't of Licenses & Inspections v. Weber, 394 Pa. 466 , 147 A.2d 326 (1959) ( "Weber" ). *919 Among relevant types of ordinances that this Court has found valid against a conflict preemption challenge are enactments that added locally-tailored conditions to broad state pronouncements on a given course of conduct, and ordinances that defined prerequisites for operating a business in the municipality which exceeded the licensing requirements imposed by the state statute.

2011See Nutter v. Dougherty, 595 Pa. 340 , 938 A.2d 401 (2007); Mars EMS, 740 A.2d 193 ; Marcincin, 515 A.2d 1320 , Dep't of Licenses & Inspections v. Weber, 394 Pa. 466 , 147 A.2d 326 (1959) ( "Weber" ). *919 Among relevant types of ordinances that this Court has found valid against a conflict preemption challenge are enactments that added locally-tailored conditions to broad state pronouncements on a given course of conduct, and ordinances that defined prerequisites for operating a business in the municipality which exceeded the licensing requirements imposed by the state statute.

11
Mars Emergency Medical Services, Inc. v. Township of Adamsgreen
pa · 1999 · cited in 1 Pennsylvania opinions naming this issue, 2011–2011
2 sentences

2011Id.; Mars Emergency Medical Services, Inc. v. Township of Adams, 559 Pa. 309 , 740 A.2d 193, 195 (1999) (citing Western Pennsylvania Restaurant Association v. City of Pittsburgh, 366 Pa. 374 , 77 A.2d 616 , 620 (1951)).

2011See Nutter v. Dougherty, 595 Pa. 340 , 938 A.2d 401 (2007); Mars EMS, 740 A.2d 193 ; Marcincin, 515 A.2d 1320 , Dep't of Licenses & Inspections v. Weber, 394 Pa. 466 , 147 A.2d 326 (1959) ( "Weber" ). *919 Among relevant types of ordinances that this Court has found valid against a conflict preemption challenge are enactments that added locally-tailored conditions to broad state pronouncements on a given course of conduct, and ordinances that defined prerequisites for operating a business in the municipality which exceeded the licensing requirements imposed by the state statute.

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 (5)

CaseCitedYears
Haas v. HOSGOOD green
pa · 2010
2 sentences

2011Conflict Preemption Finally, I note that I agree with the Majority’s conflict preemption analysis, because it squares with my dissenting expression in Holt’s Cigar Co. v. City of Philadelphia, 608 Pa. 146 , 10 A.3d 902 (2011) (“Holt’s ”).

2011Conflict Preemption Finally, I note that I agree with the Majority's conflict preemption analysis, because it squares with my dissenting expression in Holt's Cigar Co. v. City of Philadelphia, 608 Pa. 146 , 10 A.3d 902 (2011) ( "Holt's" ).

22011–2012
Holt's Cigar Co. v. City of Philadelphia green
pa · 2011
2 sentences

2011Conflict Preemption Finally, I note that I agree with the Majority’s conflict preemption analysis, because it squares with my dissenting expression in Holt’s Cigar Co. v. City of Philadelphia, 608 Pa. 146 , 10 A.3d 902 (2011) (“Holt’s ”).

2011Conflict Preemption Finally, I note that I agree with the Majority's conflict preemption analysis, because it squares with my dissenting expression in Holt's Cigar Co. v. City of Philadelphia, 608 Pa. 146 , 10 A.3d 902 (2011) ( "Holt's" ).

12011–2011
Western Pennsylvania Restaurant Ass'n v. Pittsburgh green
pa · 1951
2 sentences

2011Id.; Mars Emergency Medical Services, Inc. v. Township of Adams, 559 Pa. 309 , 740 A.2d 193, 195 (1999) (citing Western Pennsylvania Restaurant Association v. City of Pittsburgh, 366 Pa. 374 , 77 A.2d 616 , 620 (1951)).

2011Id.; Mars Emergency Medical Services, Inc. v. Township of Adams, 559 Pa. 309 , 740 A.2d 193, 195 (1999) (citing Western Pennsylvania Restaurant Association v. City of Pittsburgh, 366 Pa. 374 , 77 A.2d 616 , 620 (1951)).

12011–2011
Fross v. County of Allegheny green
pawd · 2009
1 sentence

2011Fross, 612 F.Supp.2d at 660 .

12011–2011
CITY COUN. OF BETHLEHEM v. Marcincin green
pa · 1986
1 sentence

2011See Nutter v. Dougherty, 595 Pa. 340 , 938 A.2d 401 (2007); Mars EMS, 740 A.2d 193 ; Marcincin, 515 A.2d 1320 , Dep't of Licenses & Inspections v. Weber, 394 Pa. 466 , 147 A.2d 326 (1959) ( "Weber" ). *919 Among relevant types of ordinances that this Court has found valid against a conflict preemption challenge are enactments that added locally-tailored conditions to broad state pronouncements on a given course of conduct, and ordinances that defined prerequisites for operating a business in the municipality which exceeded the licensing requirements imposed by the state statute.

12011–2011

Statutes the citing opinions construe

PA § 42 Pa. Cons. Stat. § 9721 (3) PA § 42 Pa. Cons. Stat. § 9791 (3) PA § 61 Pa. Cons. Stat. § 6102 (3) PA § 61 Pa. Cons. Stat. § 6137 (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

NY 12 (2008–2026) PA 11 (2006–2022) CA 6 (1997–2018) IA 4 (2014–2023) MA 4 (2009–2023) CO 3 (2010–2017) NJ 3 (2000–2021) TX 2 (2009–2018) DC 2 (2009–2020) KS 2 (2017–2026) VT 2 (2013–2025) MN 2 (2003–2019) MD 2 (2004–2017)

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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