67 Pennsylvania opinions name it 6 courts 1971–2026 14 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.
| Case | Followed | Cited |
|---|---|---|
Commonwealth v. Furrergreen2 sentences2017See Commonwealth v. Furrer, 48 A.3d 1279 , 1281 n.3 (Pa. Super. 2012) (issues not developed in an appellate brief with pertinent authority are waived, citing Pa.R.A.P. 2119(a)). . 2017See Commonwealth v. Furrer, 48 A.3d 1279 , 1281 n.3 (Pa. Super. 2012) (issues not developed in an appellate brief with pertinent authority are waived, citing Pa.R.A.P. 2119(a)). . | 4 | 4 |
Hopewell Township Board of Supervisors v. Gollagreen2 sentences2017Realen, 838 A.2d at 728 ; C & M Developers, 820 A.2d at 151 . “[T]he function of judicial review, when the validity of a zoning ordinance is challenged, is to engage in a meaningful inquiry into the reasonableness of the restriction on land use in light of the deprivation of landowner’s freedom thereby incurred.” Realen, 838 A.2d at 729 (quoting Hopewell Township Board of Supervisors v. Golla, 452 A.2d 1337, 1342 (Pa. 1982)). 2003Hopewell Township Board of Supervisors v. Golla, 499 Pa. 246 , 452 A.2d 1337, 1341-42 (1982). *729 Hence, the function of judicial review, when the validity of a zoning ordinance is challenged, is to engage in a meaningful inquiry into the reasonableness of the restriction on land use in light of the deprivation of landowner's freedom thereby incurred. | 3 | 6 |
cluster 754792green2 sentences2025Without question, the Board (acting through the elections office staff) violated procedural due process when it segregated electors’ presumptively disqualified ballots, and then, via unnecessarily opaque coding in the SURE system, knowingly triggered an email notice to electors that affirmatively misled them about their voting rights.52 See, e.g., In re R.M., 790 A.2d 300, 306-07 (Pa. 2002) (parenthetically explaining “notice which is confusing, misleading, or inaccurate is insufficient to meet procedural due process requirements, because such notice does not adequately safeguard the right to 2002Cf. Walters v. Reno, 145 F.3d 1032, 1043 (9th Cir.1998)(concluding that notice which is confusing, misleading, or inaccurate is insufficient to meet procedural due process requirements, because such notice does *307 not adequately safeguard the right to a meaningful hearing). | 3 | 3 |
Mahonski, J. v. Engel, C.green2 sentences2018Mahonski, supra (finding waiver of all claims where statement was overly vague, redundant, and contained multiple sub- issues); Ray, supra (finding waiver of all claims where the appellant failed to identify his claims in an adequate and concise manner). 2018Mahonski, supra (finding waiver of all claims where statement was overly vague, redundant, and contained multiple sub- issues); Ray, supra (finding waiver of all claims where the appellant failed to identify his claims in an adequate and concise manner). | 2 | 5 |
In Re RMgreen2 sentences2025Without question, the Board (acting through the elections office staff) violated procedural due process when it segregated electors’ presumptively disqualified ballots, and then, via unnecessarily opaque coding in the SURE system, knowingly triggered an email notice to electors that affirmatively misled them about their voting rights.52 See, e.g., In re R.M., 790 A.2d 300, 306-07 (Pa. 2002) (parenthetically explaining “notice which is confusing, misleading, or inaccurate is insufficient to meet procedural due process requirements, because such notice does not adequately safeguard the right to 2011See In re R.M., 567 Pa. at 654 , 790 A.2d at 305 . | 2 | 2 |
Commonwealth v. Beshoregreen2 sentences2019See also Commonwealth v. B.D.G., 959 A.2d 362, 371-72 (Pa. Super. 2008) (“When an appellant fails to develop his issue in an argument and fails to cite any legal authority, the issue is waived.”); Commonwealth v. Beshore, 916 A.2d 1128, 1140 (Pa. Super. 2007) (failure to develop an adequate argument in an appellate brief may result in waiver of the claim under Pa.R.A.P. 2119). ____________________________________________ 3 At this writing, Commonwealth v. Slocum, 86 A.3d 272 (Pa. Super. 2014), is the only published opinion discussing sufficiency relative to 18 Pa.C.S.A. § 2909. 2019See also Commonwealth v. B.D.G., 959 A.2d 362, 371-72 (Pa. Super. 2008) (“When an appellant fails to develop his issue in an argument and fails to cite any legal authority, the issue is waived.”); Commonwealth v. Beshore, 916 A.2d 1128, 1140 (Pa. Super. 2007) (failure to develop an adequate argument in an appellate brief may result in waiver of the claim under Pa.R.A.P. 2119). ____________________________________________ 3 At this writing, Commonwealth v. Slocum, 86 A.3d 272 (Pa. Super. 2014), is the only published opinion discussing sufficiency relative to 18 Pa.C.S.A. § 2909. | 2 | 2 |
Commonwealth v. B.D.G.green2 sentences2019See also Commonwealth v. B.D.G., 959 A.2d 362, 371-72 (Pa. Super. 2008) (“When an appellant fails to develop his issue in an argument and fails to cite any legal authority, the issue is waived.”); Commonwealth v. Beshore, 916 A.2d 1128, 1140 (Pa. Super. 2007) (failure to develop an adequate argument in an appellate brief may result in waiver of the claim under Pa.R.A.P. 2119). ____________________________________________ 3 At this writing, Commonwealth v. Slocum, 86 A.3d 272 (Pa. Super. 2014), is the only published opinion discussing sufficiency relative to 18 Pa.C.S.A. § 2909. 2019See also Commonwealth v. B.D.G., 959 A.2d 362, 371-72 (Pa. Super. 2008) (“When an appellant fails to develop his issue in an argument and fails to cite any legal authority, the issue is waived.”); Commonwealth v. Beshore, 916 A.2d 1128, 1140 (Pa. Super. 2007) (failure to develop an adequate argument in an appellate brief may result in waiver of the claim under Pa.R.A.P. 2119). ____________________________________________ 3 At this writing, Commonwealth v. Slocum, 86 A.3d 272 (Pa. Super. 2014), is the only published opinion discussing sufficiency relative to 18 Pa.C.S.A. § 2909. | 2 | 2 |
Commonwealth v. Hammgreen1 sentence2026In addition, Pa.R.A.P. 1925(b)(ii) requires a concise statement to "concisely identify each ruling or error that the appellant intends to challenge with sufficient detail to identify all pertinent issues for foe judge.” A 1925(b) statement which is. so “redundant, vague, incoherent, or confusing as to prevent foe lower court from engaging In a meaningful analysis , result in waiver of all claim presented," Commonwealth v. Ray, 134 A.3d 1109 (Pa. Super^016)< The Defendant’s claims are therefore waived, Nevertheless, foe Court will address the merits of the Defendant’s possible claim. 18 crimes | 1 | 1 |
Commonwealth v. Dodgegreen1 sentence2026See Commonwealth v. Dodge, 77 A.3d 1263, 1271 (Pa.Super. 2013) (explaining that an appellant must independently establish a substantial question for each sentencing issue raised). -8- J-S16021-26 [C]ontrary to [Appellant]’s assertion, this court reviewed [his] pre-sentencing report as stated prior to his sentencing. | 1 | 1 |
Commonwealth v. Flowersgreen1 sentence2025Appellant argues that the trial court did not have “sufficient information to constitute the functional equivalent of a pre- sentence report when it fashioned its sentence[.]” Appellant’s Brief, at 19. -4- J-S14039-25 This Court has held that “[a]n appellant's allegation that the trial court imposed sentence without considering the requisite statutory factors or stating adequate reasons for dispensing with a pre-sentence report [raises] a substantial question.” Commonwealth v. Kelly, 33 A.3d 638, 640 (Pa.Super. 2011) (quoting Commonwealth v. Flowers, 950 A.2d 330, 332 (Pa.Super. 2008)). | 1 | 1 |
Commonwealth v. Kellygreen1 sentence2025Appellant argues that the trial court did not have “sufficient information to constitute the functional equivalent of a pre- sentence report when it fashioned its sentence[.]” Appellant’s Brief, at 19. -4- J-S14039-25 This Court has held that “[a]n appellant's allegation that the trial court imposed sentence without considering the requisite statutory factors or stating adequate reasons for dispensing with a pre-sentence report [raises] a substantial question.” Commonwealth v. Kelly, 33 A.3d 638, 640 (Pa.Super. 2011) (quoting Commonwealth v. Flowers, 950 A.2d 330, 332 (Pa.Super. 2008)). | 1 | 1 |
Commonwealth v. Pruittgreen1 sentence2025To prove incompetence, a defendant must establish “he [i]s either unable to understand the nature of the proceedings against him or unable to participate in his own defense.” Commonwealth v. Flor, 998 A.2d 606, 617 (Pa. 2010) (quoting Commonwealth v. Pruitt, 951 A.2d 307, 316 (Pa. 2008)). | 1 | 1 |
Christian v. Pennsylvania Financial Responsibility Assigned Claims Plangreen1 sentence2025See Appellants’ Brief, 12 (the sanctions order was entered “without an evidentiary hearing, without any testimony of any kind, without the cross-examination of witnesses, and without considering any evidence proffered in [c]ourt[]”); id. at 14 (stating, almost verbatim from the first argument section, that the court ordered sanctions “without conducting a meaningful hearing, without testimony of any kind, without allowing for the cross-examination of witnesses, and without considering any evidence[]”). ____________________________________________ 4 The trial court also wrote, inter alia, that | 1 | 1 |
Commonwealth v. Florgreen1 sentence2025To prove incompetence, a defendant must establish “he [i]s either unable to understand the nature of the proceedings against him or unable to participate in his own defense.” Commonwealth v. Flor, 998 A.2d 606, 617 (Pa. 2010) (quoting Commonwealth v. Pruitt, 951 A.2d 307, 316 (Pa. 2008)). | 1 | 1 |
Goodwin, J. v. Goodwin, S.green1 sentence2024See Goodwin, supra. In her third, fourth, and fifth issues, Wife argues that the court did not engage in a meaningful analysis of the equitable distribution factors, especially in distributing the increase in value of the Moorestown property and Wife’s various investment accounts. | 1 | 1 |
Commonwealth v. McGarglegreen1 sentence2022After citing case law from various circuits, the Court held that “whenever a court can conduct a meaningful hearing to evaluate retrospectively the competency of the defendant, such a ____________________________________________ 5 Appellant cites to Commonwealth v. McGargle, 549 A.2d 198, 199 (1988), a case where the appellee was found incompetent prior to trial after an incompetency hearing. -7- J-S05036-22 hearing is permissible.” Id.(emphasis added). | 1 | 1 |
Gtech Corp. v. Commonwealth, Department of Revenuegreen1 sentence2021In that regard, Aetna cites GTECH Corp. v. Department of Revenue, 965 A.2d 1276, 1288 (Pa. Cmwlth. 2009) (agency cannot deny a bidder its right to a debriefing and provide such a right only “after the time has passed for a meaningful hearing”). | 1 | 1 |
Commonwealth v. Murraygreen1 sentence2021See Commonwealth v. Murray, 83 A.3d 137, 27 (Pa. 2013). | 1 | 1 |
Com. v. Sipps, M.green1 sentence2020Commonwealth v. Sipps, 225 A.3d 1110, 1116 (Pa. Super. 2019) (holding that a failure to cite to pertinent authority and develop a meaningful analysis renders an issue waived); see also Pa.R.A.P. 2119(a) (requiring an appellant to provide in argument section of brief “such discussion and citation of authorities as are deemed pertinent”). | 1 | 1 |
| Commonwealth v. Millergreen | 1 | 1 |
| Commonwealth v. Pantaliongreen | 1 | 1 |
| Commonwealth v. Gordygreen | 1 | 1 |
| Commonwealth v. Heastergreen | 1 | 1 |
| Tucker v. R.M. Toursgreen | 1 | 1 |
| Com. of Pa. v. Hansongreen | 1 | 1 |
| Jones v. Jonesgreen | 1 | 1 |
| Hatchard v. Westinghouse Broadcasting Co.green | 1 | 1 |
| Commonwealth v. McLauringreen | 1 | 1 |
| Commonwealth v. Johnsongreen | 1 | 1 |
| Commonwealth v. Antidormigreen | 1 | 1 |
| Commonwealth v. Weissgreen | 1 | 1 |
| Drope v. Missourigreen | 1 | 1 |
| In the Interest of R.M.green | 1 | 1 |
| Burton-Lister v. Siegel, Sivitz and Lebed Associatesgreen | 1 | 1 |
| Conroy v. Commercial Cas. Ins. Co.green | 1 | 1 |
| United States v. Renfroe, Adam O., Jr.green | 1 | 1 |
| Tedesco v. Municipal Authority of Hazle Townshipgreen | 1 | 1 |
| Bureau of Traffic Safety v. Quinlangreen | 1 | 1 |
| Murel v. Baltimore City Criminal Courtgreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Com. v. Ray, T., Jr.
green
2 sentences2026Pa.R.A.p. 1 925(b)(ii) requires a concise statement to “concisely identify each ruling or error that the appellant intends to challenge with sufficient detail to identify all pertinent issues for the judge.” 24 A 1925(b) statement which is so ‘‘redundant, vague, incoherent, or confusing as to prevent the lower court from engaging in a meaningful analysis result in waiver of all claim presented.” Commonwealth v. Ray, 134 A.3d 1109 (Pa. Super.2016). 2026In addition, Pa.R.A.P. 1925(b)(ii) requires a concise statement to "concisely identify each ruling or error that the appellant intends to challenge with sufficient detail to identify all pertinent issues for foe judge.” A 1925(b) statement which is. so “redundant, vague, incoherent, or confusing as to prevent foe lower court from engaging In a meaningful analysis , result in waiver of all claim presented," Commonwealth v. Ray, 134 A.3d 1109 (Pa. Super^016)< The Defendant’s claims are therefore waived, Nevertheless, foe Court will address the merits of the Defendant’s possible claim. 18 crimes | 7 | 2016–2026 |
Commonwealth v. Morris
green
2 sentences2021“Thus[,] in arriving at a meaningful standard to guide the trial court in its exercise of discretion, and to permit appellate courts to determine whether the trial court abused this discretion, we must weigh the possibility of prejudice and injustice caused by the consolidation against the consideration of judicial economy.” Id. 2021“Thus[,] in arriving at a meaningful standard to guide the trial court in its exercise of discretion, and to permit appellate courts to determine whether the trial court abused this discretion, we must weigh the possibility of prejudice and injustice caused by the consolidation against the consideration of judicial economy.” Id. | 3 | 2015–2021 |
C & M Developers, Inc. v. Bedminster Township Zoning Hearing Board
green
2 sentences2017Realen, 838 A.2d at 728 ; C & M Developers, 820 A.2d at 151 . “[T]he function of judicial review, when the validity of a zoning ordinance is challenged, is to engage in a meaningful inquiry into the reasonableness of the restriction on land use in light of the deprivation of landowner’s freedom thereby incurred.” Realen, 838 A.2d at 729 (quoting Hopewell Township Board of Supervisors v. Golla, 452 A.2d 1337, 1342 (Pa. 1982)). 2006In C & M Developers, our Supreme Court abrogated the rule that a large minimum lot requirement is per se unconstitutional absent extraordinary justification and stated that courts "must engage in a meaningful inquiry into the reasonableness of the restriction on land use in light of the deprivation of landowner’s freedom thereby incurred.” 573 Pa. at 15 , 820 A.2d at 151 . | 3 | 2006–2017 |
Commonwealth v. Kennedy
green
2 sentences2021Although the right to present “a meaningful defense strike[s] at the heart of due process of the law[,]” Commonwealth v. Kennedy, 305 A.2d 890 , 892–93 (Pa. 1973), a due process claim can be waived if raised for the first time on appeal. 1985Commonwealth v. Kennedy, 451 Pa. 483 , 305 A.2d 890 (1973). | 2 | 1985–2021 |
Commonwealth v. Slocum
green
2 sentences2019See also Commonwealth v. B.D.G., 959 A.2d 362, 371-72 (Pa. Super. 2008) (“When an appellant fails to develop his issue in an argument and fails to cite any legal authority, the issue is waived.”); Commonwealth v. Beshore, 916 A.2d 1128, 1140 (Pa. Super. 2007) (failure to develop an adequate argument in an appellate brief may result in waiver of the claim under Pa.R.A.P. 2119). ____________________________________________ 3 At this writing, Commonwealth v. Slocum, 86 A.3d 272 (Pa. Super. 2014), is the only published opinion discussing sufficiency relative to 18 Pa.C.S.A. § 2909. 2019See also Commonwealth v. B.D.G., 959 A.2d 362, 371-72 (Pa. Super. 2008) (“When an appellant fails to develop his issue in an argument and fails to cite any legal authority, the issue is waived.”); Commonwealth v. Beshore, 916 A.2d 1128, 1140 (Pa. Super. 2007) (failure to develop an adequate argument in an appellate brief may result in waiver of the claim under Pa.R.A.P. 2119). ____________________________________________ 3 At this writing, Commonwealth v. Slocum, 86 A.3d 272 (Pa. Super. 2014), is the only published opinion discussing sufficiency relative to 18 Pa.C.S.A. § 2909. | 2 | 2019–2019 |
In Re Appeal of Realen Valley Forge Greenes Associates
green
2 sentences2017Realen, 838 A.2d at 728 ; C & M Developers, 820 A.2d at 151 . “[T]he function of judicial review, when the validity of a zoning ordinance is challenged, is to engage in a meaningful inquiry into the reasonableness of the restriction on land use in light of the deprivation of landowner’s freedom thereby incurred.” Realen, 838 A.2d at 729 (quoting Hopewell Township Board of Supervisors v. Golla, 452 A.2d 1337, 1342 (Pa. 1982)). 2017Realen, 838 A.2d at 728 ; C & M Developers, 820 A.2d at 151 . “[T]he function of judicial review, when the validity of a zoning ordinance is challenged, is to engage in a meaningful inquiry into the reasonableness of the restriction on land use in light of the deprivation of landowner’s freedom thereby incurred.” Realen, 838 A.2d at 729 (quoting Hopewell Township Board of Supervisors v. Golla, 452 A.2d 1337, 1342 (Pa. 1982)). | 2 | 2011–2017 |
Jamison v. State, Department of Social Services, Division of Family Services
green
2 sentences2016Two years later, the circuit court held that the statute was unconstitutional under the United States and Missouri Constitutions because it infringed on Jamison’s and Dotson’s liberty interest in their reputation, nurses’ licenses and ability to seek employment in their chosen profession without first giving them “a meaningful hearing at a meaningful time.” Id. at 404 . 12 Jamison, a registered nurse, was the founder and chief executive officer of the facility. 2016Two years later, the circuit court held that the statute was unconstitutional under the United States and Missouri Constitutions because it infringed on Jamison’s and Dotson’s liberty interest in their reputation, nurses’ licenses and ability to seek employment in their chosen profession without first giving them “a meaningful hearing at a meaningful time.” Id. at 404 . | 2 | 2016–2016 |
Commonwealth v. Clair
green
2 sentences1976The reasons which supported our decision to adopt it as articulated in Clair are sound and as we noted there, a defendant’s recourse is an ineffective assistance of counsel claim, “[0]ur standard for effective assistance of counsel is a meaningful test and not simply a fictional standard which does no more than allow appellate courts the opportunity to select those alleged errors they may wish to review.” Commonwealth v. Clair, supra, 458 Pa. at 422 , 326 A.2d at 274 . 1976The reasons which supported our decision to adopt it as articulated in Clair are sound and as we noted there, a defendant’s recourse is an ineffective assistance of counsel claim, “[0]ur standard for effective assistance of counsel is a meaningful test and not simply a fictional standard which does no more than allow appellate courts the opportunity to select those alleged errors they may wish to review.” Commonwealth v. Clair, supra, 458 Pa. at 422 , 326 A.2d at 274 . | 2 | 1976–1994 |
Commonwealth v. Santiago
green
2 sentences2022Justice Saylor concurred in the result and shared several observations, including the fact that he was “able to join the [OAJC’s] affirmation of the PCRA court’s retrospective competency assessment because [the appellant] has not demonstrated that the trial court improperly failed to make a determination of his competency in the course of the [J-117-2020] - 9 a meaningful hearing to evaluate retrospectively the competency of the defendant, such a hearing is permissible.” Santiago, 855 A.2d at 693 . 2022In examining this possibility, a PCRA court first “must determine whether the defendant’s PCRA petition raises a material issue of fact concerning whether he was competent at the time of trial such that he would be entitled to a hearing on the claim.” Id. | 1 | 2022–2022 |
Everett v. Geroff
green
1 sentence2022Lastly, we acknowledge Ortiz-Benabe’s claim that he was entitled to a modification or correction of the VOP court’s sentencing order based on the VOP court’s statements that he was entitled to “credit for time served, with no duplicative credit” and the VOP court’s DC-300B form stating that the court awarded “credit for any/all time served in custody in this case.” Cf. Wyatt, 115 A.3d at 879 .8 However, Ortiz-Benabe fails to develop a meaningful claim ____________________________________________ 8 We note the VOP court’s sentencing order and DC-300B form may have created confusion. | 1 | 2022–2022 |
In the Interest of J.F.
green
1 sentence2020Cf. In re J.F., 27 A.3d 1017 (Pa. Super. 2011) (stating that “[b]ut for the particular circumstances of this case, we would find the lack of notice to be a fatal defect requiring remand[;]” and where the record reflected that the foster mother had attended the hearing and was aware of the purpose of the hearing, and a meaningful hearing was conducted). | 1 | 2020–2020 |
| Commonwealth v. Devlin green | 1 | 2019–2019 |
| Alleyne v. United States green | 1 | 2019–2019 |
| Commonwealth v. Marsh green | 1 | 2015–2015 |
| Lehigh Asphalt Paving & Construction Co. v. Board of Supervisors of East Penn Township green | 1 | 2006–2006 |
| People v. Mitchell green | 1 | 2004–2004 |
| Willie Reynolds v. Larry Norris, Arkansas Department of Correction green | 1 | 2004–2004 |
| State v. Bostwick green | 1 | 2004–2004 |
| State v. Snyder green | 1 | 2004–2004 |
| Bryan v. State green | 1 | 2004–2004 |
| State v. Johnson green | 1 | 2004–2004 |
| United States v. Michael A. S. Makris green | 1 | 2004–2004 |
| Commonwealth v. Kopp green | 1 | 2001–2001 |
| Pa. Pub. Util. Com'n v. Proc. Gas Consum. green | 1 | 2001–2001 |
| Commonwealth v. Two Electronic Poker Game MacHines green | 1 | 1994–1994 |
| Kay Estate green | 1 | 1992–1992 |
| Armstrong v. Manzo green | 1 | 1992–1992 |
| Memphis Light, Gas & Water Division v. Craft green | 1 | 1992–1992 |
| Mathews v. Eldridge green | 1 | 1992–1992 |
| Commonwealth v. Randall green | 1 | 1989–1989 |
| Reese v. Kassab green | 1 | 1971–1971 |
| Bell v. Burson green | 1 | 1971–1971 |
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.
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.