end inquiry in Pennsylvania

2018Nevertheless, "a well-crafted private criminal complaint cannot be the end of the inquiry for the prosecutor." Id. (quoting In re Private Criminal Complaint of Adams , 764 A.2d 577 , 580 (Pa.Super. 2000) ).

2017Nevertheless, even “a well-crafted private criminal complaint cannot be the end of the inquiry for the prosecutor.” Id. (quoting In re Private Complaint of Adams, 764 A.2d 577, 580 (Pa.Super. 2000).

2024Instead, Mutual Benefit says, “even if the landlord is required by the lease to insure the property, Pennsylvania courts must perform a case-by-case inquiry - 17 - J-A16024-23 into the reasonable expectations of the parties about whether the tenant would be an implied co-insured under the landlord’s insurance policy, based upon the language of the lease agreement itself.” Mutual Benefit’s Brief at 18-19 (citing Joella, supra).

2023Instead, Mutual Benefit says, “even if the landlord is required by the lease to insure the property, Pennsylvania courts must perform a case-by-case inquiry - 17 - J-A16024-23 into the reasonable expectations of the parties about whether the tenant would be an implied co-insured under the landlord’s insurance policy, based upon the language of the lease agreement itself.” Mutual Benefit’s Brief at 18-19 (citing Joella, supra).

2024Mutual Benefit posits that, "[i]f the mere existence of such a provision were the end of the inquiry, Pennsylvania would fall into the category of states that apply the bright-line anti- subrogation approach….” Id. (citations omitted); see also footnote 4, supra (quoting Joella and describing the anti-subrogation approach as espousing that, “unless the lease agreement expressly requires a tenant to procure fire insurance, the tenant is an implied co-insured of the landlord’s policy”).

2023Mutual Benefit posits that, "[i]f the mere existence of such a provision were the end of the inquiry, Pennsylvania would fall into the category of states that apply the bright-line anti- subrogation approach….” Id. (citations omitted); see also footnote 4, supra (quoting Joella and describing the anti-subrogation approach as espousing that, “unless the lease agreement expressly requires a tenant to procure fire insurance, the tenant is an implied co-insured of the landlord’s policy”).

2018Taxpayer Standing This is not the end of the inquiry, however, as the Pennsylvania Supreme Court articulated an exception to the traditional requirements for standing in Application of Biester , 487 Pa. 438 , 409 A.2d 848 (1979).

2018Taxpayer Standing This is not the end of the inquiry, however, as the Pennsylvania Supreme Court articulated an exception to the traditional requirements for standing in Application of Biester , 487 Pa. 438 , 409 A.2d 848 (1979).

2015Strickler, 563 Pa. [47,] 58-59, 757 A.2d at 889 -[8]90.

2012Strickler, 563 Pa. at 58-59 , 757 A.2d at 889-90 .

1983We find that the court met the requirements of the "Act," supra, making the necessary findings upon sufficient evidence, and stating them with a particularity to meet Commonwealth v. Bey, 249 Pa.Super. 185 , 375 A.2d 1304 (1977) and its mandate "that some statement of sufficient specificity must be supplied in order that a meaningful review can be had." Id., 268 Pa.Superior Ct. 336 at 339, 408 A.2d 493 at 495 (1979).

1983We find that the court met the requirements of the "Act," supra, making the necessary findings upon sufficient evidence, and stating them with a particularity to meet Commonwealth v. Bey, 249 Pa.Super. 185 , 375 A.2d 1304 (1977) and its mandate "that some statement of sufficient specificity must be supplied in order that a meaningful review can be had." Id., 268 Pa.Superior Ct. 336 at 339, 408 A.2d 493 at 495 (1979).

2026Here, Appellant challenges whether “the sentencing court erred when it imposed consecutive rather than concurrent sentences on each offense resulting in a harsh and excessive aggregate sentence of 144 to 480[’] months incarceration.” Anders Brief at 11 (unnecessary capitalization omitted). -7- J-A07045-26 Appellant argues it was an abuse of discretion for the court to impose “consecutive sentences[,] each at the higher end of the standard sentence range to the maximum period of incarceration… permitted….” Id.

2025Id. at 26a.

2025“However, . . . finding that venue is proper in one county is not the end of the analysis when the plaintiff has contracted to litigate in a different, also proper venue.” Id.

2025At the end of the hearing, the orphans’ court involuntarily ____________________________________________ child agrees.” In re T.S., 192 A.3d 1080 , 1082 n.2 (Pa. 2018) (citation omitted).

2025Therein, Kania acknowledges that his sentence was at the higher end of the standard range but nevertheless argues “the sentence was unduly harsh or excessive,” and “that the sentence was inconsistent with the Sentencing Code.” Id. -5- J-S26036-25 “Bald allegations of excessiveness … do not raise a substantial question to warrant appellate review.” Commonwealth v. Watson, 228 A.3d 928, 935 (Pa. Super. 2020).

2024Id. at 39a.

2024Appellant does not develop these arguments in the (Footnote Continued Next Page) -4- J-S34011-24 Appellant’s contention does not set forth a “plausible argument that the sentence violates a provision of the sentencing code or is contrary to the fundamental norms of the sentencing process.” Crump, 995 A.2d at 1282 .

2022And, [al]though ____________________________________________ 17See Commonwealth v. Markowitz, 32 A.3d 706, 715 (Pa. Super. 2011) (observing that, “an unjustified failure to file a requested [] appeal” constitutes per se ineffectiveness as the petitioner is left with the functional equivalent of no counsel (original quotation marks omitted)), appeal denied, 40 A.3d 1235 (Pa. 2012). - 16 - J-A22025-21 [Appellant] is not credible, on this point, Attorney Eshbach also indicated that she did not think that [the PCRA] court [] ruled at the end of that hearing.

2022He's not available to be a resource for [C]hild.” She also testified she did not believe termination of Father’s rights would cause irreparable harm to Child. **** At the end of that hearing, the trial court terminated Father’s parental rights to Child, pursuant to 23 Pa.C.S.[A.] § 2511(a)(1), (2), (5), (8) and (b)[, and changed Child’s permanency goal to adoption.] Father timely [appealed.] Interest of H.W., 270 A.3d 1171 (Pa. Super. 2021) (unpublished memorandum at *1-*3) (internal citations, indentation, and some quotations omitted; emphasis added).

2020This protection of preexisting arrangements, even if they are contrary to the Act’s requirements, reflects a concern “that the application of certain organizational requirements of the [Act] to pre[]existing planned communities could violate the constitutional prohibition against impairment of contracts and lead to confusion among unit owners and declarants.” Pinecrest Lake, 64 A.3d at 80 .

2018That is not the end of the inquiry, however, as we determined in Butler v. State Civil Service Commission, 426 A.2d 239 (Pa. Cmwlth. 1981), that the discovery rule may be applied to toll the 20-day period for appeals under the Act.

2018"It is well settled that the grant or refusal of a continuance rests in the discretion of the court or administrative agency to which the application is made, and its exercise of this discretion will not be reviewed except in clear cases of abuse." Blackledge v. Pennsylvania State Police , 62 Pa.Cmwlth. 188 , 435 A.2d 309 , 311 (1981).

2018"It is well settled that the grant or refusal of a continuance rests in the discretion of the court or administrative agency to which the application is made, and its exercise of this discretion will not be reviewed except in clear cases of abuse." Blackledge v. Pennsylvania State Police , 62 Pa.Cmwlth. 188 , 435 A.2d 309 , 311 (1981).

2018Finally, at the end of the hearing, the trial court reiterated, "[W]hat I have before me is all the original agreements, the consent [agreement] of January 18th, 2017, and the stipulated order of 8/28/17." Id. at 471b.