exceptional doctrine (Pennsylvania) · Go Syfert
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exceptional doctrine in Pennsylvania

11 Pennsylvania opinions name it 3 courts 1898–2026 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 (3)

CaseFollowedCited
Commonwealth v. Rosado, F., Apltgreen
pa · 2016 · cited in 4 Pennsylvania opinions naming this issue, 2019–2026
2 sentences

2026Our Supreme Court has distinguished between “errors causing waiver of all claims and those failing to preserve particular claims,” which “prevent[s] the exceptional doctrine of ineffective assistance of counsel per se from engulfing the general rule that an accused must demonstrate that counsel’s errors caused him prejudice.” Commonwealth v. Rosado, 150 A.3d 425 , 433–35 (Pa. 2016) (emphasis in original); see Halley, 870 A.2d at 801 (“The -7- J-S44004-25 difference in degree between failures that completely foreclose appellate review, and those which may result in narrowing its ambit, justifie

2020Importantly, the Supreme Court explained “that maintaining the distinction between errors causing waiver of all claims and those failing to preserve particular claims appropriately prevented the exceptional doctrine of ineffective assistance of counsel per se from engulfing the general rule that an accused must demonstrate that counsel’s errors caused him prejudice.” Id. at 431-32 .

14
Commonwealth v. Hernandezgreen
pasuperct · 2000 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
1 sentence

2026Our Supreme Court has distinguished between “errors causing waiver of all claims and those failing to preserve particular claims,” which “prevent[s] the exceptional doctrine of ineffective assistance of counsel per se from engulfing the general rule that an accused must demonstrate that counsel’s errors caused him prejudice.” Commonwealth v. Rosado, 150 A.3d 425 , 433–35 (Pa. 2016) (emphasis in original); see Halley, 870 A.2d at 801 (“The -7- J-S44004-25 difference in degree between failures that completely foreclose appellate review, and those which may result in narrowing its ambit, justifie

11
Roofner's Appealgreen
pasuperct · 1923 · cited in 1 Pennsylvania opinions naming this issue, 1981–1981
2 sentences

1981As our Superior Court long ago observed, "to permit such use of public funds is but to encourage a disregard of duty and to put a premium upon neglect or *65 refusal of public officials to perform the duties imposed upon them by law." Roofner's Appeal, 81 Pa.Super. 482, 485 (1923).

1981As our Superior Court long ago observed, “to permit such use of public funds is but to encourage a disregard of duty and to put a premium upon neglect or refusal of public officials to perform the duties imposed upon them by law.” Roofner’s Appeal, 81 Pa. Super. 482, 485 (1923).

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
Commonwealth v. Halley green
pa · 2005
2 sentences

2016Id. (“[T]he limiting principle arising from the recognition of such difference in degree addresses the . . . concern that the presumption should not extend to every circumstance in which a defendant may claim no effective appeal.” (citations omitted)). [J-79-2016] - 11 Our subsequent decisions have maintained Halley’s distinction between errors which completely foreclose merits review and those which merely “narrow its ambit.” Thus, in Reaves, we held an attorney’s failure to file a post-sentence motion preserving a particular sentencing claim “did not operate to entirely foreclose appellate r

2016Id. (“[T]he limiting principle arising from the recognition of such difference in degree addresses the ... concern that the presumption should not extend to every circumstance in which a defendant may claim no effective appeal.” (citations omitted)).

22016–2016
Appletree Land Development v. Zoning Hearing Board of York Township green
pacommwct · 2003
1 sentence

2019We have held that an applicant’s failure to determine the zoning requirements, whether mistakenly or intentionally, “bars [an applicant’s] ability to invoke the exceptional standard for a de minimis variance.” Id.

12019–2019
Commonwealth v. Reaves green
pa · 2007
1 sentence

2016Id. (“[T]he limiting principle arising from the recognition of such difference in degree addresses the . . . concern that the presumption should not extend to every circumstance in which a defendant may claim no effective appeal.” (citations omitted)). [J-79-2016] - 11 Our subsequent decisions have maintained Halley’s distinction between errors which completely foreclose merits review and those which merely “narrow its ambit.” Thus, in Reaves, we held an attorney’s failure to file a post-sentence motion preserving a particular sentencing claim “did not operate to entirely foreclose appellate r

12016–2016
Skeen Et Vir v. Stanley Co. of America green
pa · 1949
2 sentences

1953In support of what they denote as “this exceptional doctrine” they cite Durning v. Hyman, 286 Pa. 376 , 133 A. 568 , and Skeen v. Stanley Co. of America, 362 Pa. 174 , 66 A. 2d 774 , and conclude from the fact of recovery by plaintiff in each of these cases that as a general proposition of law the proprietor of a public place of amusement warrants the physical *31 safety of bis paid patrons.

1953In support of what they denote as “this exceptional doctrine” they cite Durning v. Hyman, 286 Pa. 376 , 133 A. 568 , and Skeen v. Stanley Co. of America, 362 Pa. 174 , 66 A. 2d 774 , and conclude from the fact of recovery by plaintiff in each of these cases that as a general proposition of law the proprietor of a public place of amusement warrants the physical *31 safety of bis paid patrons.

11953–1953
Durning v. Hyman green
pa · 1926
2 sentences

1953In support of what they denote as “this exceptional doctrine” they cite Durning v. Hyman, 286 Pa. 376 , 133 A. 568 , and Skeen v. Stanley Co. of America, 362 Pa. 174 , 66 A. 2d 774 , and conclude from the fact of recovery by plaintiff in each of these cases that as a general proposition of law the proprietor of a public place of amusement warrants the physical *31 safety of bis paid patrons.

1953In support of what they denote as “this exceptional doctrine” they cite Durning v. Hyman, 286 Pa. 376 , 133 A. 568 , and Skeen v. Stanley Co. of America, 362 Pa. 174 , 66 A. 2d 774 , and conclude from the fact of recovery by plaintiff in each of these cases that as a general proposition of law the proprietor of a public place of amusement warrants the physical *31 safety of bis paid patrons.

11953–1953
Appleby v. Barrett green
pasuperct · 1905
1 sentence

1919A defendant’s set-off must be pleaded with as much certainty as a plaintiff’s statement of claim: Law v. Waldron, 230 Pa. 458 ; Appleby v. Barrett, 28 Pa. Superior Ct. 349 .

11919–1919
Law v. Waldron neutral
pa · 1911
1 sentence

1919A defendant’s set-off must be pleaded with as much certainty as a plaintiff’s statement of claim: Law v. Waldron, 230 Pa. 458 ; Appleby v. Barrett, 28 Pa. Superior Ct. 349 .

11919–1919
Ege v. Kille green
· 1877
1 sentence

1898The cases of property which is part of the realty, but the value of which depends on its conversion into personalty, such as coal, iron ore, etc., have a different and exceptional rule of their own, because they involve expense and risk in the conversion of the material, which is realty in place, into personalty in the market, and to measure the value in place by the value in market, less the cost of getting it there, would, as was said by our Brother Green in Fulmer’s Appeal, 128 Pa. 24 , be giving “ a share in the profits of carrying on the business without being subject to the risks or poss

11898–1898
Fulmer v. Williams green
pactcompllehigh · 1889
1 sentence

1898The cases of property which is part of the realty, but the value of which depends on its conversion into personalty, such as coal, iron ore, etc., have a different and exceptional rule of their own, because they involve expense and risk in the conversion of the material, which is realty in place, into personalty in the market, and to measure the value in place by the value in market, less the cost of getting it there, would, as was said by our Brother Green in Fulmer’s Appeal, 128 Pa. 24 , be giving “ a share in the profits of carrying on the business without being subject to the risks or poss

11898–1898

Where else courts name it

LA 56 (1934–2025) CA 22 (1911–2026) PA 11 (1898–2026) NJ 8 (1926–2023) NY 7 (1876–1937) WV 6 (1950–2016) MA 6 (1901–1985) KY 6 (1877–1946) MO 4 (1886–1977) AL 4 (1864–1997) AZ 4 (1961–2019) WY 3 (1971–1991) KS 3 (1907–2021) IN 3 (1910–1990) DC 3 (2008–2023) MD 3 (1948–2009) RI 2 (1938–1957) TN 2 (1988–2001) WA 2 (1912–2019) MI 2 (1927–1962) OH 2 (1972–1995) OR 2 (1932–2013) TX 2 (1957–2014) NH 2 (1901–1954) NC 2 (1955–2008)

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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