Edmunds analysis in Pennsylvania

2025Our Supreme Court has held that this is sufficient for preserving a constitutional departure claim. -3- J-S47041-24 See Commonwealth v. Alexander, 243 A.3d 177 , 193 n.8 (Pa. 2020) (holding Alexander “sufficiently preserved” his constitutional departure issue where “[t]he motion to suppress used a pre-printed check box form” challenging a warrantless search and defense counsel argued at the suppression hearing that his motion was “based on [enumerated federal constitutional provisions] and the broader protections of Pennsylvania Constitution, Article One Section Eight”).3 The Majority faults R

2025Our Supreme Court has held that this is sufficient for preserving a constitutional departure claim. -3- J-S47041-24 See Commonwealth v. Alexander, 243 A.3d 177 , 193 n.8 (Pa. 2020) (holding Alexander “sufficiently preserved” his constitutional departure issue where “[t]he motion to suppress used a pre-printed check box form” challenging a warrantless search and defense counsel argued at the suppression hearing that his motion was “based on [enumerated federal constitutional provisions] and the broader protections of Pennsylvania Constitution, Article One Section Eight”).3 The Majority faults R

2020See White, 669 A.2d at 903-04 (Montemuro, J., concurring) (“In the instant case, the Majority has failed to employ the Edmunds analysis in deciding that Article I, Section 8 of the Pennsylvania Constitution provides more protections than the Fourth Amendment of the United States Constitution . . . .”); id. at 910 (Castille, J., dissenting) (“I agree with Mr. Justice Montemuro that in providing Pennsylvania citizens broader protections under the Pennsylvania Constitution than are provided under analogous provisions of the federal constitution, as the majority purports to do, the four-prong test

2020See White, 669 A.2d at 903-04 (Montemuro, J., concurring) (“In the instant case, the Majority has failed to employ the Edmunds analysis in deciding that Article I, Section 8 of the Pennsylvania Constitution provides more protections than the Fourth Amendment of the United States Constitution . . . .”); id. at 910 (Castille, J., dissenting) (“I agree with Mr. Justice Montemuro that in providing Pennsylvania citizens broader protections under the Pennsylvania Constitution than are provided under analogous provisions of the federal constitution, as the majority purports to do, the four-prong test

2020See Shaw, 770 A.2d at 305-06 (Castille, J., dissenting) (noting that the majority cited a plurality portion of Denoncourt that “lacks precedential value,” while In re June 1979 “never so much as cited Article I, § 8.”). [J-51-2020] - 50 declined to follow the high Court’s interpretation of the First Amendment in interpreting our analogous Article I, Section 7 provision, we cited Article I, Section 1 as forming a component of our Edmunds analysis.

2012See Edmunds, 526 Pa. at 390 , 586 A.2d at 895 (''[W]e find it important to set forth certain factors to be briefed and analyzed by litigants in each case hereafter implicating a provision of the Pennsylvania constitution.”) Indeed, a mere five months prior to the Melendez decision our Court stated: “Edmunds expresses the idea that it may be helpful to address the concerns listed therein, not that these concerns must be addressed in order for a claim . asserted under the Pennsylvania Constitution to be cognizable.” Commonwealth v. White, 543 Pa. 45, 50 , 669 A.2d 896, 899 (1995); see also Commo

2013But see Commonwealth v. White, 543 Pa. 45, 50 , 669 A.2d 896, 899 (1995) (stating that failure to follow the Edmunds protocol does not constitute a fatal waiver of state constitutional claims); Commonwealth v. Swinehart, 541 Pa. 500 , 509 n. 6, 664 A.2d 957 , 961 n. 6 (1995) (noting that Edmunds factors are "helpful” but not mandatory).

2013But see Commonwealth v. White, 543 Pa. 45, 50 , 669 A.2d 896, 899 (1995) (stating that failure to follow the Edmunds protocol does not constitute a fatal waiver of state constitutional claims); Commonwealth v. Swinehart, 541 Pa. 500 , 509 n. 6, 664 A.2d 957 , 961 n. 6 (1995) (noting that Edmunds factors are "helpful” but not mandatory).

2014See, e.g., Russo, supra at 1200, 1205-13 (after conducting a detailed Edmunds analysis, concluding that the open fields doctrine is equally applicable under the Fourth Amendment or Article I, Section 8); Commonwealth v. Duncan, 572 Pa. 438 , 817 A.2d 455, 459, 469 (2003) (distinguishing DeJohn, supra, in holding that the defendant-appellant had no reasonable expectation of privacy under Article I, Section 8 in the name and address information provided by his bank to the police); In re D.M., 566 Pa. 445 , 781 A.2d 1161, 1163 (2001) (concluding that there was “no reason at this juncture to embra

2014See, e.g., Russo, supra at 1200, 1205-13 (after conducting a detailed Edmunds analysis, concluding that the open fields doctrine is equally applicable under the Fourth Amendment or Article I, Section 8); Commonwealth v. Duncan, 572 Pa. 438 , 817 A.2d 455, 459, 469 (2003) (distinguishing DeJohn, supra, in holding that the defendant-appellant had no reasonable expectation of privacy under Article I, Section 8 in the name and address information provided by his bank to the police); In re D.M., 566 Pa. 445 , 781 A.2d 1161, 1163 (2001) (concluding that there was “no reason at this juncture to embra

2025Accordingly, Appellant’s sentence of life imprisonment without parole is constitutional for the offense of second-degree murder as it does not “clearly, palpably, and plainly violates constitutional rights.” Baker, supra. Finally, we do not analyze the Edmunds factors because Pennsylvania courts have consistently determined that the Pennsylvania Constitution is coextensive with the federal Constitution on the point of cruel and unusual - 11 - J-S09039-25 punishment.

2025Accordingly, Appellant’s sentence of life imprisonment without parole is constitutional for the offense of second-degree murder as it does not “clearly, palpably, and plainly violates constitutional rights.” Baker, supra. Finally, we do not analyze the Edmunds factors because Pennsylvania courts have consistently determined that the Pennsylvania Constitution is coextensive with the federal Constitution on the point of cruel and unusual - 11 - J-S09039-25 punishment.

2019See, e.g. , Commonwealth v. Arroyo , 555 Pa. 125 , 723 A.2d 162 , 166 n.6 (1999) (failure to engage in an Edmunds analysis in lower court "does not result in waiver of a state constitutional claim").

2019See, e.g. , Commonwealth v. Arroyo , 555 Pa. 125 , 723 A.2d 162 , 166 n.6 (1999) (failure to engage in an Edmunds analysis in lower court "does not result in waiver of a state constitutional claim").

2017Hence, the OISA departs from the Fourth Amendment as to the constitutional meaning of probable cause – a departure that is in tension with this Court’s past pronouncements, see, e.g., Commonwealth v. Glass, 562 Pa. 187, 197 , 754 A.2d 655, 661 (2000) (“The standard for evaluating whether probable cause exists for the issuance of a search warrant is the same under both the Fourth Amendment and Article I, §8[.]”), and which is undertaken without a supporting Edmunds analysis.

2017Hence, the OISA departs from the Fourth Amendment as to the constitutional meaning of probable cause – a departure that is in tension with this Court’s past pronouncements, see, e.g., Commonwealth v. Glass, 562 Pa. 187, 197 , 754 A.2d 655, 661 (2000) (“The standard for evaluating whether probable cause exists for the issuance of a search warrant is the same under both the Fourth Amendment and Article I, §8[.]”), and which is undertaken without a supporting Edmunds analysis.

2025See Oberholzer v. Galapo, 322 A.3d 153 , 173 (Pa. 2024); Pap’s A.M.; Western Pennsylvania II; Tate; and William Goldman Theaters, Inc.6 Moreover, Appellants argue that Pennsylvania’s state action doctrine is consistent with federal law, 7 and an Edmunds analysis is only necessary “when interpreting a provision of the Pennsylvania Constitution that is invoked in support of a departure from federal law[.]” Wharton, 263 A.3d at 569 (quoting Jubelirer v. Rendell, 953 A.2d 514, 523 (Pa. 2008)).

2025See Oberholzer v. Galapo, 322 A.3d 153 , 173 (Pa. 2024); Pap’s A.M.; Western Pennsylvania II; Tate; and William Goldman Theaters, Inc.6 Moreover, Appellants argue that Pennsylvania’s state action doctrine is consistent with federal law, 7 and an Edmunds analysis is only necessary “when interpreting a provision of the Pennsylvania Constitution that is invoked in support of a departure from federal law[.]” Wharton, 263 A.3d at 569 (quoting Jubelirer v. Rendell, 953 A.2d 514, 523 (Pa. 2008)).

2024See, e.g., League of Women Voters, 178 A.3d at 802 - 03 (“certain of the Edmunds factors obviously may assist us in our analysis[]”); Robinson Township, 83 A.3d at 944 (“some of the Edmunds factors obviously are helpful in our analysis[]”); see also McLinko, 279 A.3d 539 (although not labelled as an Edmunds analysis, all four factors discussed).

2024See, e.g., League of Women Voters, 178 A.3d at 802 - 03 (“certain of the Edmunds factors obviously may assist us in our analysis[]”); Robinson Township, 83 A.3d at 944 (“some of the Edmunds factors obviously are helpful in our analysis[]”); see also McLinko, 279 A.3d 539 (although not labelled as an Edmunds analysis, all four factors discussed).

2024See, e.g., League of Women Voters, 178 A.3d at 802 - 03 (“certain of the Edmunds factors obviously may assist us in our analysis[]”); Robinson Township, 83 A.3d at 944 (“some of the Edmunds factors obviously are helpful in our analysis[]”); see also McLinko, 279 A.3d 539 (although not labelled as an Edmunds analysis, all four factors discussed).

2024See, e.g., League of Women Voters, 178 A.3d at 802 - 03 (“certain of the Edmunds factors obviously may assist us in our analysis[]”); Robinson Township, 83 A.3d at 944 (“some of the Edmunds factors obviously are helpful in our analysis[]”); see also McLinko, 279 A.3d 539 (although not labelled as an Edmunds analysis, all four factors discussed).

2024The scholarly analysis thoroughly discussed the four Edmunds factors, and we adopt Justice Todd’s compelling analysis as our own.”). 23 Id. at 190 (quoting Gary, 91 A.3d at 152-53 (Todd, J., dissenting)) (citations omitted); see also id. at 192 (“Vehicles contain a variety of features that let users store items away from public view such as trunks, glove boxes, and internal storage compartments.

2024The scholarly analysis thoroughly discussed the four Edmunds factors, and we adopt Justice Todd’s compelling analysis as our own.”). 23 Id. at 190 (quoting Gary, 91 A.3d at 152-53 (Todd, J., dissenting)) (citations omitted); see also id. at 192 (“Vehicles contain a variety of features that let users store items away from public view such as trunks, glove boxes, and internal storage compartments.

2014See, e.g., Russo, supra at 1200, 1205-13 (after conducting a detailed Edmunds analysis, concluding that the open fields doctrine is equally applicable under the Fourth Amendment or Article I, Section 8); Commonwealth v. Duncan, 572 Pa. 438 , 817 A.2d 455, 459, 469 (2003) (distinguishing DeJohn, supra, in holding that the defendant-appellant had no reasonable expectation of privacy under Article I, Section 8 in the name and address information provided by his bank to the police); In re D.M., 566 Pa. 445 , 781 A.2d 1161, 1163 (2001) (concluding that there was “no reason at this juncture to embra

2014See, e.g., Russo, supra at 1200, 1205-13 (after conducting a detailed Edmunds analysis, concluding that the open fields doctrine is equally applicable under the Fourth Amendment or Article I, Section 8); Commonwealth v. Duncan, 572 Pa. 438 , 817 A.2d 455, 459, 469 (2003) (distinguishing DeJohn, supra, in holding that the defendant-appellant had no reasonable expectation of privacy under Article I, Section 8 in the name and address information provided by his bank to the police); In re D.M., 566 Pa. 445 , 781 A.2d 1161, 1163 (2001) (concluding that there was “no reason at this juncture to embra

2008See Commonwealth v. White, 543 Pa. 45 , 669 A.2d 896 (1995); Commonwealth v. Mason, 535 Pa. 560 , 637 A.2d 251 (1993); Commonwealth v. Hess, 532 Pa. 607 , 617 A.2d 307 (1992); see also Commonwealth v. Perry, 568 Pa. 499 , 798 A.2d 697, 714 (2002) (Castille, J., concurring); Commonwealth v. Shaw, 564 Pa. 617 , 770 A.2d 295, 304 (2001) (Castille, J., dissenting, joined by Saylor, J.).

2008See Commonwealth v. White, 543 Pa. 45 , 669 A.2d 896 (1995); Commonwealth v. Mason, 535 Pa. 560 , 637 A.2d 251 (1993); Commonwealth v. Hess, 532 Pa. 607 , 617 A.2d 307 (1992); see also Commonwealth v. Perry, 568 Pa. 499 , 798 A.2d 697, 714 (2002) (Castille, J., concurring); Commonwealth v. Shaw, 564 Pa. 617 , 770 A.2d 295, 304 (2001) (Castille, J., dissenting, joined by Saylor, J.).

2026Similarly, in Batts I, supra, notwithstanding the fact that the argument was developed primarily in terms of the Eighth Amendment and that Batts had not provided a fully developed Edmunds analysis, then-Justice Thomas Saylor, writing for a unanimous Court, explained that our Court’s prior holdings that Section 13 was co-extensive with the Eighth Amendment arose only in discrete contexts, and, while rejecting a Section 13 claim in that appeal, offered that textual differences between the two Constitutions could provide a basis for greater protections under the Pennsylvania Constitution if our C

2026Op. at 27-28. 15 Commonwealth v. Zettlemoyer, 454 A.2d 937, 967 (Pa. 1982) (holding that the “rights secured by the Pennsylvania prohibition against ‘cruel punishments’ are co- extensive with those secured by the Eighth and Fourteenth Amendments”); see Maj Op. at 54 (critiquing Zettlemoyer’s “incomplete account of the Commonwealth’s constitutional past”). 16 I am increasingly skeptical of decisions, like Zettlemoyer, that tether the meaning of the Pennsylvania Constitution to the interpretation of the United States Constitution, particularly with regard to provisions, such as Article I, Sectio

2024Commonwealth v. Thompson, 289 A.3d 1104, 1111 (Pa. Super. 2023) (“The Alexander Court’s rejection of the United States Supreme Court’s views on the privacy interests involved in an automobile may well support some limitations on the inventory search doctrine.”). 25 See DePaul v. Commonwealth, 969 A.2d 536, 547 (Pa. 2009) (noting that, “[g]iven this Court’s extensive consideration of Article I, Section 7 under the Edmunds factors” in an earlier decision, “there is no reason to engage in a full-blown Edmunds analysis here”). [J-6-2024, 85 MAP 2023] - 10 our continued adherence to the rule that i

2024Commonwealth v. Thompson, 289 A.3d 1104, 1111 (Pa. Super. 2023) (“The Alexander Court’s rejection of the United States Supreme Court’s views on the privacy interests involved in an automobile may well support some limitations on the inventory search doctrine.”). 25 See DePaul v. Commonwealth, 969 A.2d 536, 547 (Pa. 2009) (noting that, “[g]iven this Court’s extensive consideration of Article I, Section 7 under the Edmunds factors” in an earlier decision, “there is no reason to engage in a full-blown Edmunds analysis here”). [J-6-2024, 85 MAP 2023] - 10 our continued adherence to the rule that i

2020See Commonwealth v. Edmunds, 586 A.2d 887, 895 (Pa. 1991) (to raise challenge for higher protection under Pennsylvania Constitution appellant must “brief and analyze” four factors including text of the Pennsylvania provision, history of the provision, related caselaw from other states, and policy considerations). - 19 - J-A08032-20 & J-A08033-20 The Pennsylvania Supreme Court recently explained the fundamental differences between procedural and substantive due process concerns:13 Procedural due process “is a flexible concept which ‘varies with the particular situation.’” Bundy v. Wetzel, 646 P

2020See Commonwealth v. Edmunds, 586 A.2d 887, 895 (Pa. 1991) (to raise challenge for higher protection under Pennsylvania Constitution appellant must “brief and analyze” four factors including text of the Pennsylvania provision, history of the provision, related caselaw from other states, and policy considerations). - 19 - J-A08032-20 & J-A08033-20 The Pennsylvania Supreme Court recently explained the fundamental differences between procedural and substantive due process concerns:13 Procedural due process “is a flexible concept which ‘varies with the particular situation.’” Bundy v. Wetzel, 646 P

2017Gaffney, 733 A.2d at 622 ("Appellant has failed to present any compelling reason for our departure from the standards appropriate for determining whether an ex post facto violation pursuant to the federal constitution has occurred and we find no independent reasons for doing so.”); accord Commonwealth v. McElhenny, 329 Pa.Super. 240 , 478 A.2d 447, 450 (1984) (rejecting the argument that Article I, Section 17 of the Pennsylvania Constitution provides greater protection.than the corresponding federal provision, and noting that Pennsylvania courts "have, generally, interpreted the Pennsylvania c

2017Gaffney, 733 A.2d at 622 ("Appellant has failed to present any compelling reason for our departure from the standards appropriate for determining whether an ex post facto violation pursuant to the federal constitution has occurred and we find no independent reasons for doing so.”); accord Commonwealth v. McElhenny, 329 Pa.Super. 240 , 478 A.2d 447, 450 (1984) (rejecting the argument that Article I, Section 17 of the Pennsylvania Constitution provides greater protection.than the corresponding federal provision, and noting that Pennsylvania courts "have, generally, interpreted the Pennsylvania c

2017Gaffney, 733 A.2d at 622 ("Appellant has failed to present any compelling reason for our departure from the standards appropriate for determining whether an ex post facto violation pursuant to the federal constitution has occurred and we find no independent reasons for doing so.”); accord Commonwealth v. McElhenny, 329 Pa.Super. 240 , 478 A.2d 447, 450 (1984) (rejecting the argument that Article I, Section 17 of the Pennsylvania Constitution provides greater protection.than the corresponding federal provision, and noting that Pennsylvania courts "have, generally, interpreted the Pennsylvania c

2017Gaffney, 733 A.2d at 622 ("Appellant has failed to present any compelling reason for our departure from the standards appropriate for determining whether an ex post facto violation pursuant to the federal constitution has occurred and we find no independent reasons for doing so.”); accord Commonwealth v. McElhenny, 329 Pa.Super. 240 , 478 A.2d 447, 450 (1984) (rejecting the argument that Article I, Section 17 of the Pennsylvania Constitution provides greater protection.than the corresponding federal provision, and noting that Pennsylvania courts "have, generally, interpreted the Pennsylvania c

2014Commonwealth v. Edmunds, 526 Pa. 374 , 586 A.2d 887, 894-95 (1991) (stating that “it is both important and necessary that we undertake an independent analysis of the Pennsylvania Constitution, each time a provision of that fundamental document is implicated” and setting forth “certain factors to be briefed and analyzed by litigants in each case hereafter implicating a provision of the Pennsylvania [Constitution”); Commonwealth v. Russo, 594 Pa. 119 , 934 A.2d 1199, 1213 (2007) (holding, after conducting an Edmunds analysis, that the Fourth Amendment and Article I, Section 8 of the Pennsylvania

2014Commonwealth v. Edmunds, 526 Pa. 374 , 586 A.2d 887, 894-95 (1991) (stating that “it is both important and necessary that we undertake an independent analysis of the Pennsylvania Constitution, each time a provision of that fundamental document is implicated” and setting forth “certain factors to be briefed and analyzed by litigants in each case hereafter implicating a provision of the Pennsylvania [Constitution”); Commonwealth v. Russo, 594 Pa. 119 , 934 A.2d 1199, 1213 (2007) (holding, after conducting an Edmunds analysis, that the Fourth Amendment and Article I, Section 8 of the Pennsylvania

2014See, e.g., Russo, supra at 1200, 1205-13 (after conducting a detailed Edmunds analysis, concluding that the open fields doctrine is equally applicable under the Fourth Amendment or Article I, Section 8); Commonwealth v. Duncan, 572 Pa. 438 , 817 A.2d 455, 459, 469 (2003) (distinguishing DeJohn, supra, in holding that the defendant-appellant had no reasonable expectation of privacy under Article I, Section 8 in the name and address information provided by his bank to the police); In re D.M., 566 Pa. 445 , 781 A.2d 1161, 1163 (2001) (concluding that there was “no reason at this juncture to embra

2014See, e.g., Russo, supra at 1200, 1205-13 (after conducting a detailed Edmunds analysis, concluding that the open fields doctrine is equally applicable under the Fourth Amendment or Article I, Section 8); Commonwealth v. Duncan, 572 Pa. 438 , 817 A.2d 455, 459, 469 (2003) (distinguishing DeJohn, supra, in holding that the defendant-appellant had no reasonable expectation of privacy under Article I, Section 8 in the name and address information provided by his bank to the police); In re D.M., 566 Pa. 445 , 781 A.2d 1161, 1163 (2001) (concluding that there was “no reason at this juncture to embra

2014Commonwealth v. Edmunds, 526 Pa. 374 , 586 A.2d 887, 894-95 (1991) (stating that “it is both important and necessary that we undertake an independent analysis of the Pennsylvania Constitution, each time a provision of that fundamental document is implicated” and setting forth “certain factors to be briefed and analyzed by litigants in each case hereafter implicating a provision of the Pennsylvania [Constitution”); Commonwealth v. Russo, 594 Pa. 119 , 934 A.2d 1199, 1213 (2007) (holding, after conducting an Edmunds analysis, that the Fourth Amendment and Article I, Section 8 of the Pennsylvania

2014Commonwealth v. Edmunds, 526 Pa. 374 , 586 A.2d 887, 894-95 (1991) (stating that “it is both important and necessary that we undertake an independent analysis of the Pennsylvania Constitution, each time a provision of that fundamental document is implicated” and setting forth “certain factors to be briefed and analyzed by litigants in each case hereafter implicating a provision of the Pennsylvania [Constitution”); Commonwealth v. Russo, 594 Pa. 119 , 934 A.2d 1199, 1213 (2007) (holding, after conducting an Edmunds analysis, that the Fourth Amendment and Article I, Section 8 of the Pennsylvania

2007See Appellant's Brief at 11-12 (citing, inter alia, Commonwealth v. Shaw, 564 Pa. 617 , 770 A.2d 295 (2001)) (requiring warrant for seizure of hospital-administered blood-alcohol content test results under Article I, Section 8 where warrant not required under Fourth Amendment) (lacking Edmunds analysis); Commonwealth v. Matos, 543 Pa. 449 , 672 A.2d 769 (1996) (holding that police pursuit of individual is a "seizure" within meaning of Article I, Section 8 even though it is not under Fourth Amendment) (applying Edmunds ); Commonwealth v. White, 543 Pa. 45 , 669 A.2d 896 (1995) (rejecting federa

2007See Appellant's Brief at 11-12 (citing, inter alia, Commonwealth v. Shaw, 564 Pa. 617 , 770 A.2d 295 (2001)) (requiring warrant for seizure of hospital-administered blood-alcohol content test results under Article I, Section 8 where warrant not required under Fourth Amendment) (lacking Edmunds analysis); Commonwealth v. Matos, 543 Pa. 449 , 672 A.2d 769 (1996) (holding that police pursuit of individual is a "seizure" within meaning of Article I, Section 8 even though it is not under Fourth Amendment) (applying Edmunds ); Commonwealth v. White, 543 Pa. 45 , 669 A.2d 896 (1995) (rejecting federa

2016As this Court held in Perez , ”[t]he Edmunds analysis is mandatory and a failure to provide it precludes the consideration of a state constitutional claim independent of its federal counterpart.” Perez, 97 A.3d at 760 (citations omitted).

2015See Baker, supra; Edmunds, supra. Perez, 97 A.3d at 759-60 .

2014See, e.g., Russo, supra at 1200, 1205-13 (after conducting a detailed Edmunds analysis, concluding that the open fields doctrine is equally applicable under the Fourth Amendment or Article I, Section 8); Commonwealth v. Duncan, 572 Pa. 438 , 817 A.2d 455, 459, 469 (2003) (distinguishing DeJohn, supra, in holding that the defendant-appellant had no reasonable expectation of privacy under Article I, Section 8 in the name and address information provided by his bank to the police); In re D.M., 566 Pa. 445 , 781 A.2d 1161, 1163 (2001) (concluding that there was “no reason at this juncture to embra

2007See Commonwealth v. Glass, 562 Pa. 187 , 754 A.2d 655, 661 (2000) (challenge to anticipatory search warrant) (characterizing Edmunds as "the four-part methodology to aid in evaluating state constitutional claims"); Commonwealth v. Cleckley, 558 Pa. 517 , 738 A.2d 427, 430 (1999) (applying Edmunds to assess validity of consent search under Pennsylvania Constitution); Commonwealth v. Waltson, 555 Pa. 223 , 724 A.2d 289, 291 (1998) (challenge that warrant was overbroad) ("In Commonwealth v. Edmunds , this court proffered a methodology for analyzing issues which arise pursuant to the Pennsylvania

2013Accord Blum by Blum v. Merrell Dow Pharm., Inc., 534 Pa. 97 , 626 A.2d 537, 550 (1993) (Larsen, J. concurring, joined by Papa-dakos, J.) (where appellant grounds claim only upon state constitutional provision, it is unnecessary to subject case to Edmunds analysis; Edmunds analysis “is appropriate only when there is a question of whether our constitution provides a source of individual rights which is alternative to and independent of rights guaranteed by the United States Constitution”). .

2013Accord Blum by Blum v. Merrell Dow Pharm., Inc., 534 Pa. 97 , 626 A.2d 537, 550 (1993) (Larsen, J. concurring, joined by Papa-dakos, J.) (where appellant grounds claim only upon state constitutional provision, it is unnecessary to subject case to Edmunds analysis; Edmunds analysis “is appropriate only when there is a question of whether our constitution provides a source of individual rights which is alternative to and independent of rights guaranteed by the United States Constitution”). .