certification hearing (Pennsylvania) · Go Syfert
← Pennsylvania issues

certification hearing in Pennsylvania

68 Pennsylvania opinions name it 4 courts 1966–2024 9 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 (37)

CaseFollowedCited
Commonwealth v. Pandergreen
pasuperct · 2014 · cited in 5 Pennsylvania opinions naming this issue, 2017–2020
2 sentences

2020A PCRA petitioner is not required to provide an affidavit from the proposed witness, and instead, “the certification requirement can be met by an attorney or pro se petitioner certifying what the witness will testify regarding.” Id. at 642 (citations omitted). - 10 - J-S23029-20 With respect to Appellant’s claim that Trial Counsel were ineffective for not investigating Bond, neither his PCRA petition nor appellate brief specify any new information that would have been gained from such an investigation.

2018Additionally, “the certification requirement can be met by an attorney or pro se petitioner certifying what the witness will testify regarding.” Commonwealth v. Pander, 100 A.3d 626, 642 (Pa. 2014).

55
Commonwealth v. Spuckgreen
pasuperct · 2014 · cited in 3 Pennsylvania opinions naming this issue, 2019–2023
2 sentences

2023Pa.R.A.P. 2135(a)(1), (d).11 Notably, Appellant’s brief does not contain "a certificate of compliance with the word count limit," as required by Rule 2135(a)(1) and (d).12 “The certification requirement is not limited to counsel: Pro se litigants, too, are obliged to provide a certification for a primary brief that exceeds thirty pages.” Commonwealth v. Spuck, 86 A.3d 870, 873 (Pa. Super. 2014) (citation omitted).

2019"The certification requirement is not limited to counsel: Pro se litigants, too, are *511 obliged to provide a certification for a primary brief that exceeds thirty pages." Commonwealth v. Spuck , 86 A.3d 870 , 873 (Pa. Super. 2014), citing Pa.R.A.P. 2135(d) ("[T]he attorney or the unrepresented filing party shall include a certification that the brief complies with the word count limits." (emphasis added) ).

23
Commonwealth v. Browngreen
pasuperct · 2001 · cited in 3 Pennsylvania opinions naming this issue, 2014–2020
2 sentences

2020Commonwealth v. Brown, 767 A.2d 576, 583 (Pa.Super. 2001). “[T]he certification requirement can be met by an attorney or pro se petitioner certifying what the witness will testify - 10 - J-S07025-20 regarding[;]” the certification requirement can also be met by the proposed witness or the witness’ attorney.

2018Brown, 767 A.2d at 583 ; 42 Pa.C.S. § 9545(d)(1); Pa.R.Crim.P. 902(A)(15).

23
Goodman v. Pennsylvania Board of Probation and Parolegreen
pa · 2010 · cited in 2 Pennsylvania opinions naming this issue, 2021–2024
2 sentences

2024Rather, the sole purpose of a certification hearing, as established by the Juvenile Act, is to determine “if there is a prima facie case that the child committed the delinquent act alleged, the delinquent act would be considered a felony if committed by an adult, and if there are reasonable grounds to believe that the public interest would be served by the transfer of the case for criminal prosecution.” Commonwealth v. In re E.F., 995 A.2d 326, 329 (Pa. 2010).

2021Id. at 328.

22
DiLucido v. Terminix International, Inc.green
pasuperct · 1996 · cited in 2 Pennsylvania opinions naming this issue, 2001–2005
2 sentences

2005The purpose behind this “requirement is to determine whether the class representatives’ overall position on the common issues is sufficiently aligned with that of the absent class members, to ensure that the pursuit of their interests will advance those of the proposed class members.” DiLucido v. Terminix International Inc., 450 Pa. Super. 393, 404 , 676 A.2d 1237, 1242 (1996).

2005The purpose behind this “requirement is to determine whether the class representatives’ overall position on the common issues is sufficiently aligned with that of the absent class members, to ensure that the pursuit of their interests will advance those of the proposed class members.” DiLucido v. Terminix International Inc., 450 Pa. Super. 393, 404 , 676 A.2d 1237, 1242 (1996).

22
Commonwealth v. Mossgreen
pa · 1988 · cited in 2 Pennsylvania opinions naming this issue, 1999–2005
2 sentences

2005Due to the deficiency of the record of the initial juvenile hearing, we are constrained to remand the case for a new certification hearing to determine whether Appellant’s waiver into the adult court was knowing, voluntary and intelligent. ¶ 5 When evaluating the certification decision of the juvenile court, we are mindful that: The Superior Court must not upset the certification decision of a juvenile court unless the court has either failed to provide “specific reasons for its conclusion that the juvenile is not amenable to treatment” or “the court committed a gross abuse of discretion.” Com

2005Due to the deficiency of the record of the initial juvenile hearing, we are constrained to remand the case for a new certification hearing to determine whether Appellant’s waiver into the adult court was knowing, voluntary and intelligent. ¶ 5 When evaluating the certification decision of the juvenile court, we are mindful that: The Superior Court must not upset the certification decision of a juvenile court unless the court has either failed to provide “specific reasons for its conclusion that the juvenile is not amenable to treatment” or “the court committed a gross abuse of discretion.” Com

22
Cook v. Highland Water & S. Auth.green
pacommwct · 1987 · cited in 2 Pennsylvania opinions naming this issue, 2002–2002
2 sentences

2002This requires that the “class representatives’ overall position on the common issues [be] sufficiently aligned with that of the absent class members to ensure that pursuit of [those] interests will advance those of the proposed class members.” Cook, 530 A.2d at 505, n. 8 .

2002This requires that the "class representatives' overall position on the common issues [be] sufficiently aligned with that of the absent class members to ensure that pursuit of [those] interests will advance those of the proposed class members." Cook, 530 A.2d at 505, n. 8 .

22
Commonwealth v. Beygreen
pasuperct · 1977 · cited in 5 Pennsylvania opinions naming this issue, 1978–1985
2 sentences

1985In Commonwealth v. Bey, 249 Pa.Super. 185 , 375 A.2d 1304 (1977), the defendant was convicted of rape and involuntary deviate sexual intercourse in the criminal court after being certified as a juvenile.

1985In Commonwealth v. Bey, 249 Pa.Super. 185 , 375 A.2d 1304 (1977), the defendant was convicted of rape and involuntary deviate sexual intercourse in the criminal court after being certified as a juvenile.

15
Commonwealth v. Stokesgreen
pasuperct · 1980 · cited in 2 Pennsylvania opinions naming this issue, 2005–2024
2 sentences

2024See also Commonwealth v. Lux, 445 A.2d 185 (Pa. Super. 1982) (when record did not indicate that juvenile division judge properly considered child’s amenability to treatment, supervision, or rehabilitation when certifying his case for trial in adult criminal court, case was remanded for a new certification hearing, and judgment of sentence entered after trial was vacated, pending the outcome of the new certification hearing); Commonwealth v. Stokes, 421 A.2d 240 (Pa. Super. 1980) (same).

2005Due to the deficiency of the record of the initial juvenile hearing, we are constrained to remand the case for a new certification hearing to determine whether Appellant’s waiver into the adult court was knowing, voluntary and intelligent. ¶ 5 When evaluating the certification decision of the juvenile court, we are mindful that: The Superior Court must not upset the certification decision of a juvenile court unless the court has either failed to provide “specific reasons for its conclusion that the juvenile is not amenable to treatment” or “the court committed a gross abuse of discretion.” Com

12
In re Deleviegreen
pasuperct · 2019 · cited in 2 Pennsylvania opinions naming this issue, 2022–2024
2 sentences

2024Furthermore, Appellant highlights that there was testimony that Dr. Tenthoff was the cause of his harm, arguing that “[b]ased on the evidence in Appellant’s case-in-chief, a reasonable jury could have easily concluded Appellees’ failure to properly diagnose, treat, and manage Appellant’s ____________________________________________ 4 “The certification requirement is not limited to counsel: Pro se litigants, too, are obliged to provide a certification for a primary brief that exceeds thirty pages.” In re deLevie, 204 A.3d 505, 510-11 (Pa.Super. 2019).

2022“The certification requirement is not limited to counsel: Pro se litigants, too, are obliged to provide a certification for a primary brief that exceeds thirty pages.” In re Delevie, 204 A.3d 505, 510-11 (Pa. Super. 2019) (citations omitted).

12
Commonwealth v. Luxgreen
pasuperct · 1982 · cited in 2 Pennsylvania opinions naming this issue, 1982–2024
2 sentences

2024See also Commonwealth v. Lux, 445 A.2d 185 (Pa. Super. 1982) (when record did not indicate that juvenile division judge properly considered child’s amenability to treatment, supervision, or rehabilitation when certifying his case for trial in adult criminal court, case was remanded for a new certification hearing, and judgment of sentence entered after trial was vacated, pending the outcome of the new certification hearing); Commonwealth v. Stokes, 421 A.2d 240 (Pa. Super. 1980) (same).

1982In Commonwealth v. Lux, 299 Pa.Superior Ct. 136, 445 A.2d 185 (1982) a panel of this court vacated the transfer order and remanded for a new certification hearing because there was not an adequate demonstration of nonamenability.

12
Weinberg v. Sun Company, Inc.green
pasuperct · 1999 · cited in 2 Pennsylvania opinions naming this issue, 2002–2004
2 sentences

2004Weinberg v. Sun Company Inc., 740 A.2d 1152, 1171 (Pa. Super. 1999), aff’d in part and rev’d in part on other grounds, 565 Pa. 612 , 777 A.2d 442 (2001). (5) Class Action Provides a Fair and Efficient Method for Adjudication The final prerequisite for class certification is whether a class action provides a fair and efficient method for adjudication of the controversy under the criteria set forth in Rule 1708.

2002Weinberg, 740 A.2d at 1162 . ¶ 12 Despite having broad discretion and liberal license, Rule 1707 does limit the court’s inquiries at the certification hearing: The hearing is confined to a consideration of the class action allegations and is not concerned with the merits of the controversy or with attacks on the other averments of the complaint.

12
Griffin v. Californiagreen
scotus · 1965 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
1 sentence

2024See Griffin, 380 U.S. at 614 .

11
Mazza v. Commonwealth, Department of Transportation, Bureau of Driver Licensinggreen
pacommwct · 1997 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
1 sentence

2021“An administrative agency is a creature of statute and cannot exercise powers that are not explicitly given to it by the legislature.” Mazza v. Dep’t of Transp., Bureau of Driver Licensing, 692 A.2d 251, 252 (Pa. Cmwlth. 1997).

11
Commonwealth v. Prestongreen
pasuperct · 2006 · cited in 1 Pennsylvania opinions naming this issue, 2018–2018
1 sentence

2018As we require a complete record to decide the issues, and may not consider documents not included in the certified record, see Commonwealth v. Preston, 904 A.2d 1, 7 (Pa.Super. 2006) (en banc), we ordered the trial court to supplement the record with the requisite portions of the juvenile case file.

11
Commonwealth v. Roneygreen
pa · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
1 sentence

2015See Pa.R.A.P. 2135(d) (‘[T]he attorney or the unrepresented filing party shall include a certification that the brief complies with the word count limits.’ (emphasis added).” Id.

11
Popowsky v. Pennsylvania Public Utility Commissiongreen
pa · 2007 · cited in 1 Pennsylvania opinions naming this issue, 2011–2011
2 sentences

2011Id., 594 Pa. at 610-11 , 937 A.2d at 1056-57 (emphasis added).

2011Id., 594 Pa. at 610-11 , 937 A.2d at 1056-57 (emphasis added).

11
Commonwealth v. Jacksongreen
pa · 1999 · cited in 1 Pennsylvania opinions naming this issue, 2010–2010
11
Rauch v. United Instruments, Inc.green
pasuperct · 1987 · cited in 1 Pennsylvania opinions naming this issue, 2002–2002
11
Cribb v. United Health Clubs Inc.green
pa · 1984 · cited in 1 Pennsylvania opinions naming this issue, 2002–2002
11
Dolgow v. Andersongreen
nyed · 1968 · cited in 1 Pennsylvania opinions naming this issue, 1999–1999
11
Miller v. Federal Kemper Insurancegreen
pa · 1986 · cited in 1 Pennsylvania opinions naming this issue, 1999–1999
11
Prince George Center, Inc. v. United States Gypsum Co.green
pasuperct · 1997 · cited in 1 Pennsylvania opinions naming this issue, 1999–1999
11
Commonwealth v. Buehlgreen
pa · 1986 · cited in 1 Pennsylvania opinions naming this issue, 1997–1997
11
Commonwealth v. Browngreen
pa · 1979 · cited in 1 Pennsylvania opinions naming this issue, 1994–1994
11
Commonwealth v. Williamsgreen
pasuperct · 1974 · cited in 1 Pennsylvania opinions naming this issue, 1993–1993
11
Commonwealth v. Duncanred
pa · 1987 · cited in 1 Pennsylvania opinions naming this issue, 1988–1988
11
Seibel v. Allstate Insurancegreen
pasuperct · 1985 · cited in 1 Pennsylvania opinions naming this issue, 1986–1986
11
Commonwealth v. Pelkeygreen
pa · 1985 · cited in 1 Pennsylvania opinions naming this issue, 1986–1986
11
Kruth v. Liberty Mutual Insurancegreen
pa · 1985 · cited in 1 Pennsylvania opinions naming this issue, 1986–1986
11
In Re HOTEL TELEPHONE CHARGESgreen
ca9 · 1974 · cited in 1 Pennsylvania opinions naming this issue, 1986–1986
11
Commonwealth v. Johnsongreen
pasuperct · 1982 · cited in 1 Pennsylvania opinions naming this issue, 1984–1984
11
Commonwealth v. Sextongreen
pasuperct · 1977 · cited in 1 Pennsylvania opinions naming this issue, 1979–1979
11
Commonwealth v. MacKeygreen
pa · 1972 · cited in 1 Pennsylvania opinions naming this issue, 1977–1977
11
Allegheny Beverage Corp. v. Conel Corp.green
pa · 1972 · cited in 1 Pennsylvania opinions naming this issue, 1977–1977
11
United States v. Wadegreen
scotus · 1967 · cited in 1 Pennsylvania opinions naming this issue, 1977–1977
11
Coleman v. Alabamagreen
scotus · 1970 · cited in 1 Pennsylvania opinions naming this issue, 1970–1970
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 (30)

CaseCitedYears
Kent v. United States green
scotus · 1966
2 sentences

2024The Commonwealth contended that this would be akin to what the United States Supreme Court did to cure an improper waiver of a juvenile’s case to adult criminal court in the case of Kent v. United States, 383 U.S. 541 (1966), 10 discussed at greater length herein, and that such a course of action was appropriate because “the structure of District of Columbia and Pennsylvania laws in this regard are similar, and . . . should be interpreted similarly.” Taylor III, slip op. at 21. 10 Briefly, in Kent, a juvenile who was arrested in the District of Columbia (D.C.) and charged with multiple crimes

1983In order to comply with the statute, the lower court need not make a formal statement or conventional findings of fact but "the statement should be sufficient to demonstrate that . . . the question [of certification] has received the careful consideration of the Juvenile Court; and it must set forth the basis for the order with sufficient specificity to permit meaningful review." Kent v. United States, 383 U.S. 541, 561 , 86 S.Ct. 1045, 1057 , 16 L.Ed.2d 84 (1966).

41973–2024
Commonwealth v. Greiner green
pa · 1978
2 sentences

2024Id.

1985In Commonwealth v. Greiner, 479 Pa. 364 , 388 A.2d 698 (1978), the appellant was convicted of criminal conspiracy, attempted murder, attempted kidnapping and aggravated assault; he appealed the judgment of sentence of the Court of Common Pleas of Lancaster County.

31980–2024
Commonwealth v. Sexton green
pa · 1979
2 sentences

1984This was so even though at the certification hearing “[the defendant] was the only young and black male in the courtroom where [the] case was announced by his name and the complaintant, while never having viewed [the defendant] in a non-suggestive setting, had been given [the defendant’s] name by the police.” Id., 485 Pa. at 22 n. 4, 400 A.2d at 1292 n. 4.

1984This was so even though at the certification hearing “[the defendant] was the only young and black male in the courtroom where [the] case was announced by his name and the complaintant, while never having viewed [the defendant] in a non-suggestive setting, had been given [the defendant’s] name by the police.” Id., 485 Pa. at 22 n. 4, 400 A.2d at 1292 n. 4.

31980–1984
In Re GAULT green
scotus · 1967
2 sentences

2020From this authority, Taylor deduces that “it is clear that the Fifth Amendment ‘applies’ to a certification hearing.” Id. at 24 (citing Commonwealth v. Batty, 393 A.2d 435 , 439 n.3 (Pa. 1978)).

1972We conclude that these events constituted more than sufficient notice to appellant’s parents under any test and therefore need not decide whether such notice is constitutionally mandated by the Supreme Court’s decision in Re Gault, 387 U.S. 1 , 18 L.

21972–2020
Commonwealth v. Dugger green
pa · 1985
2 sentences

1988Id.

1988Id.

21988–1988
Tumey v. Ohio green
scotus · 1927
1 sentence

2024The Commonwealth distinguishes this matter from the types of errors the high Court deemed structural in prior cases, such as the use of a coerced confession at trial, Payne v. Arkansas, 356 U.S. 560 (1958), the denial of the right to counsel, Gideon v. Wainwright, 372 U.S. 335 (1963), and a judge presiding over a trial who was not impartial, Tumey v. Ohio, 273 U.S. 510 (1927), as well as the errors which our Court deemed structural or per se in Lewis, Kelly, and the Interest of J.M.B., supra, on the basis that in those cases the defendant’s liberty was directly at stake in the proceedings.

12024–2024
Payne v. Arkansas green
scotus · 1958
1 sentence

2024The Commonwealth distinguishes this matter from the types of errors the high Court deemed structural in prior cases, such as the use of a coerced confession at trial, Payne v. Arkansas, 356 U.S. 560 (1958), the denial of the right to counsel, Gideon v. Wainwright, 372 U.S. 335 (1963), and a judge presiding over a trial who was not impartial, Tumey v. Ohio, 273 U.S. 510 (1927), as well as the errors which our Court deemed structural or per se in Lewis, Kelly, and the Interest of J.M.B., supra, on the basis that in those cases the defendant’s liberty was directly at stake in the proceedings.

12024–2024
Gideon v. Wainwright green
scotus · 1963
1 sentence

2024The Commonwealth distinguishes this matter from the types of errors the high Court deemed structural in prior cases, such as the use of a coerced confession at trial, Payne v. Arkansas, 356 U.S. 560 (1958), the denial of the right to counsel, Gideon v. Wainwright, 372 U.S. 335 (1963), and a judge presiding over a trial who was not impartial, Tumey v. Ohio, 273 U.S. 510 (1927), as well as the errors which our Court deemed structural or per se in Lewis, Kelly, and the Interest of J.M.B., supra, on the basis that in those cases the defendant’s liberty was directly at stake in the proceedings.

12024–2024
Janicik v. Prudential Insurance Co. of America green
pasuperct · 1982
1 sentence

2023Id. at 457 . 6 “At the certification hearing, the court will have before it the class action allegations in the complaint, the defendant’s answer to these allegations, any depositions or admissions relating to these allegations and any testimony relating to those allegations that may be offered at the hearing.” Pa.R.Civ.P. 1707, 1977 Explanatory Comment. 8 A. Commonality and Predominance We begin our analysis by considering Staniec’s position that the trial court committed legal errors in analyzing the commonality and predominance requirements for class certification.

12023–2023
Rawson v. Commonwealth, Department of Transportation, Bureau of Driver Licensing green
pacommwct · 2014
1 sentence

2021Our recent case law construing the certification requirement in Section 1532 of the Vehicle Code reasoned that “[PennDOT’s] action must be predicated upon a proper record of conviction.” Rawson, 99 A.3d at 147 ; see also Thorpe v. Department of Transportation, Bureau of Driver Licensing, 214 A.3d 335 (Pa. Cmwlth. 2019).

12021–2021
Commonwealth v. Batty green
pa · 1978
1 sentence

2020From this authority, Taylor deduces that “it is clear that the Fifth Amendment ‘applies’ to a certification hearing.” Id. at 24 (citing Commonwealth v. Batty, 393 A.2d 435 , 439 n.3 (Pa. 1978)).

12020–2020
Commonwealth v. Redmond neutral
pa · 2019
1 sentence

2020Commonwealth v. Taylor, 204 A.3d 361 (Pa. 2019) (per curiam). [J-97-2019] - 8 that Taylor had never admitted to committing the crimes he pled not guilty to, and also that Taylor’s attorney had not admitted in open court that Taylor committed the alleged crimes”).

12020–2020
Delaware Riverkeeper Network v. Secretary Pennsylvania Department of Environmental Protection green
ca3 · 2016
1 sentence

2018Once an applicant files a Water Quality Certification application, the Clean Water Act gives the relevant state agency (here, the DEP) one year from the filing date of the application to return a decision; a failure to do so results in waiver of the certification requirement. 33 U.S.C. § 1341 (a)(1); Leidy Line, 3 833 F.3d at 369 .

12018–2018
Weinberg v. Sun Co., Inc. green
pa · 2001
12004–2004
Com., Dept. of Transp. v. McCafferty green
pa · 2000
12002–2002
Commonwealth v. Sanders green
pa · 1985
12001–2001
Commonwealth v. Frankenfield green
pasuperct · 1991
12001–2001
Commonwealth v. Proctor neutral
pasuperct · 1995
12001–2001
Commonwealth v. Potts green
pasuperct · 1996
11999–1999
Aronson v. City of Pittsburgh green
pacommwct · 1986
11997–1997
Commonwealth v. Stocker green
pasuperct · 1993
11997–1997
Cavanaugh v. Allegheny Ludlum Steel Corp. green
pa · 1987
11990–1990
Commonwealth v. Goodman green
pa · 1985
11988–1988
Commonwealth v. Hoffman green
pa · 1987
11988–1988
Parker v. Commonwealth, Department of Public Welfare green
pacommwct · 1980
11984–1984
Commonwealth v. Riggins green
pa · 1977
11984–1984
State v. Dinkins green
utah · 1981
11983–1983
Commonwealth v. Richman green
pa · 1974
11977–1977
Freeman Appeal green
pasuperct · 1968
11969–1969
Larry O. Black v. United States green
cadc · 1965
11966–1966

Statutes the citing opinions construe

PA § 42 Pa. Cons. Stat. § 6355 (8) PA § 42 Pa. Cons. Stat. § 9545 (4) PA § 42 Pa. Cons. Stat. § 6302 (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

TX 235 (1951–2026) IL 89 (1975–2026) PA 68 (1966–2024) LA 50 (1937–2025) CA 38 (1960–2025) OK 35 (1973–2006) NY 22 (1958–2025) OH 19 (1981–2024) GA 17 (1982–2025) NJ 16 (1979–2024) NV 14 (1969–2024) MO 13 (1926–2024) CT 12 (1991–2025) NC 11 (1980–2020) DC 11 (1963–2022) UT 11 (1982–2025) MN 11 (2000–2016) CO 11 (1980–2021) FL 10 (1980–2025) MD 10 (1983–2020) AL 10 (1985–2012) AR 10 (1987–2016) KS 10 (1992–2012) MI 10 (1986–2022) ND 9 (1982–2025) MS 8 (1991–2016) TN 7 (2012–2025) HI 6 (1971–2025) KY 6 (2018–2022) MA 6 (1982–2014) IN 6 (1896–2012) ID 5 (1978–2009) WA 5 (2002–2026) NH 5 (1982–1997) VA 5 (2001–2025) ME 4 (1997–2019) OR 4 (1995–2016) IA 4 (1989–2009) RI 3 (1991–2004) NM 3 (2004–2010) MT 2 (1989–2006)

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