germaneness test in Pennsylvania

2019The gist of these decisions is that a bill will be held to violate the single-subject rule only if it includes topics with “unrelated subject matter,” id. at 303 , 877 A.2d at 400 , where “unrelated” connotes that any attempt to tie the provisions together within a single, unifying subject necessarily involves an overly-broad topic – such as the business of the courts, municipalities, or the economic wellbeing of the Commonwealth – which would empty the germaneness test of all meaning.

2019The gist of these decisions is that a bill will be held to violate the single-subject rule only if it includes topics with “unrelated subject matter,” id. at 303 , 877 A.2d at 400 , where “unrelated” connotes that any attempt to tie the provisions together within a single, unifying subject necessarily involves an overly-broad topic – such as the business of the courts, municipalities, or the economic wellbeing of the Commonwealth – which would empty the germaneness test of all meaning.

2023Washington, 188 A.3d at 1151 ; Stilp, 905 A.2d at 959 ; PAGE, 877 A.2d at 410 . [J-50-2022] - 28 However, when the court must hypothesize an “unduly expansive” subject to sustain an enactment, the General Assembly has violated its constitutional mandate.

2019Stilp v. Commonwealth, 588 Pa. 539, 603 , 905 A.2d 918, 956 (2006) (quotation marks and citation omitted).

2013Id. at 588 (citing, e.g., DeWeese v. Weaver, 824 A.2d 364 (Pa.Cmwlth.2003) (finding the theme “business of the courts” too encompassing to uphold a law regulating DNA records and apportioning negligence liability); Pa. Ass’n of Rental Dealers v. Com., 123 Pa.Cmwlth. 533 , 554 A.2d 998 (1989) (holding that the topic of “economic well-being of the Commonwealth” would turn the germaneness requirement into a nullity)).

2003But see Pennsylvania *578 Ass’n of Rental Dealers v. Commonwealth, 123 Pa.Cmwlth. 533, 540 , 554 A.2d 998,1002 (1989) (rejecting an argument that all the challenged amendments were germane to the single topic of the “economic well being of the Commonwealth,” as that would render the germaneness test meaningless); DeWeese, 824 A.2d at 370 (rejecting the position that expunging criminal DNA records and apportioning negligence liability are both germane to the single subject of “the business of the courts”).

2018See Leach v. Commonwealth, 636 Pa. 81 , 141 A.3d 426 , 433-434 (2016) (provisions criminalizing scrap metal theft and granting standing to individuals to challenge the constitutionality of municipalities' lost or stolen gun ordinances could not be unified under the general subjects of "regulation of firearms" or "the ability to own a firearm"); Neiman (holding that the proposed subjects of "refining civil remedies" or "judicial remedies" were too broad to be unifying subjects for multiple provisions of a bill pertaining to: deficiency judgment procedures, statutes of limitations for personal i

2018See Leach v. Commonwealth, 636 Pa. 81 , 141 A.3d 426 , 433-434 (2016) (provisions criminalizing scrap metal theft and granting standing to individuals to challenge the constitutionality of municipalities' lost or stolen gun ordinances could not be unified under the general subjects of "regulation of firearms" or "the ability to own a firearm"); Neiman (holding that the proposed subjects of "refining civil remedies" or "judicial remedies" were too broad to be unifying subjects for multiple provisions of a bill pertaining to: deficiency judgment procedures, statutes of limitations for personal i

2015See id. 6 Defendants requested reconsideration or reargument en banc, stating, among other things, that the court should have applied the laches -doctrine to avoid setting aside, on procedural grounds, a statute that had been enacted 22 years earlier and whose provisions had been relied on by hundreds, if not thousands, of litigants and potential litigants — including ■ felony defendants whose charges were not dismissed at a preliminary hearing and individuals who elected not to assert wrongful-birth claims due to the substantive validity of Section 8305.