does not end inquiry (Pennsylvania) · Go Syfert
← Pennsylvania issues

does not end inquiry in Pennsylvania

65 Pennsylvania opinions name it 6 courts 1975–2026 15 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 (40)

CaseFollowedCited
Commonwealth v. Bennettgreen
pa · 2007 · cited in 3 Pennsylvania opinions naming this issue, 2020–2021
2 sentences

2021The “newly-discovered facts” exception requires a petitioner to plead and prove that “1) the facts upon which the claim was predicted were unknown and 2) could not have been ascertained by the exercise of due diligence.” Commonwealth v. Bennett, 593 Pa. 382 , 930 A.2d 1264, 1272 (2007) (quotation marks and quotation omitted).

2020The “newly-discovered facts” exception requires a petitioner to plead and prove that “1) the facts upon which the claim was predicted were unknown and 2) could not have been ascertained by the exercise of due diligence.” Commonwealth v. Bennett, 593 Pa. 382 , 930 A.2d 1264, 1272 (2007) (quotation marks and quotation omitted).

33
Com. v. Seeney, T.green
pasuperct · 2024 · cited in 2 Pennsylvania opinions naming this issue, 2026–2026
2 sentences

2026See -8- J-A17039-24 Commonwealth v. Seeney, 316 A.3d 645 , 651 n.3 (Pa.Super. 2024).

2026See -8- J-A17039-24 Commonwealth v. Seeney, 316 A.3d 645 , 651 n.3 (Pa.Super. 2024).

22
Montgomery v. Louisianagreen
· 2016 · cited in 5 Pennsylvania opinions naming this issue, 2016–2020
2 sentences

2020See 42 Pa.C.S.A. § 9545(b)(1).1 This does not end our inquiry, however, as Appellant alleges he is entitled to the timeliness exception under Subsection 9545(b)(1)(iii) pursuant to Miller v. Alabama, 567 U.S. 460 , 132 S.Ct. 2455 (2012), and Montgomery v. Louisiana, ____ U.S. ____, 136 S.Ct. 718 (2016).

2019Accordingly, Appellant's instant PCRA petition, which was filed on March 1, 2016, is patently untimely. -4 J -S78036-18 However, this does not end our inquiry as Appellant invokes Montgomery v. Louisiana, U.S. , 136 S.Ct. 718 (2016),3 and contends that he has met the following timeliness exception: "the right asserted is a constitutional right that was recognized by the Supreme Court of the United States or the Supreme Court of Pennsylvania after the time period provided in this section and has been held by that court to apply retroactively." 42 Pa.C.S.A. § 9545(b)(1)(iii).

15
Miller v. Alabamagreen
scotus · 2012 · cited in 3 Pennsylvania opinions naming this issue, 2018–2020
2 sentences

2020See 42 Pa.C.S.A. § 9545(b)(1).1 This does not end our inquiry, however, as Appellant alleges he is entitled to the timeliness exception under Subsection 9545(b)(1)(iii) pursuant to Miller v. Alabama, 567 U.S. 460 , 132 S.Ct. 2455 (2012), and Montgomery v. Louisiana, ____ U.S. ____, 136 S.Ct. 718 (2016).

2020See 42 Pa.C.S.A. § 9545(b)(1).1 This does not end our inquiry, however, as Appellant alleges he is entitled to the timeliness exception under Subsection 9545(b)(1)(iii) pursuant to Miller v. Alabama, 567 U.S. 460 , 132 S.Ct. 2455 (2012), and Montgomery v. Louisiana, ____ U.S. ____, 136 S.Ct. 718 (2016).

13
Zappacosta, J. v. McAvoy, C.green
pasuperct · 2024 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
1 sentence

2026See Zappacosta, 325 A.3d at 788 .4 On November 18, 2024, the trial court entered the Second Default Judgment against Rillema pursuant to Rule 1037(c).

11
United States v. William Harrisgreen
ca3 · 2006 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
1 sentence

2026See id.

11
Triffin v. DiSalvogreen
pasuperct · 1994 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
2 sentences

2026See In re Est. of S.G.L., 885 A.2d 73 , 73 n.1 (Pa. Super. 2005) (noting that failure to address issue in argument section of the appellate brief renders the claim waived). - 19 - J-A24002-25 This does not end our inquiry, because although the attorney–client privilege only protects communications with licensed attorneys, “[t]he privilege for communications of a client with his lawyer hinges upon the client’s belief that he is consulting a lawyer in that capacity and his manifested intention to seek professional legal advice.” Triffin v. DiSalvo, 643 A.2d 118, 120 (Pa. Super. 1994) (citation o

2026“It is sufficient if he reasonably believes that the person consulted is a lawyer, though in fact he is not.” Id. (citation omitted).

11
In re Estate of S.G.L.green
pasuperct · 2005 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
1 sentence

2026See In re Est. of S.G.L., 885 A.2d 73 , 73 n.1 (Pa. Super. 2005) (noting that failure to address issue in argument section of the appellate brief renders the claim waived). - 19 - J-A24002-25 This does not end our inquiry, because although the attorney–client privilege only protects communications with licensed attorneys, “[t]he privilege for communications of a client with his lawyer hinges upon the client’s belief that he is consulting a lawyer in that capacity and his manifested intention to seek professional legal advice.” Triffin v. DiSalvo, 643 A.2d 118, 120 (Pa. Super. 1994) (citation o

11
Gurecka, F. v. Carroll, R.green
pasuperct · 2017 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
1 sentence

2025See Gurecka v. Carroll, 155 A.3d 1071 (Pa.Super. 2017) (en banc).

11
Commonwealth v. Parrishgreen
pasuperct · 2018 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
1 sentence

2024However, this does not end our inquiry since, as Appellant acknowledges, the element of “[p]ossession can be found by proving actual possession, constructive possession, or joint constructive possession.” - 17 - J-S30037-24 Commonwealth v. Parrish, 191 A.3d 31, 36 (Pa.Super. 2018) (citation omitted).

11
Orman, L. v. Mortgage I.T.green
pasuperct · 2015 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
1 sentence

2024See Orman, supra. This does not end our inquiry, however, since the Bakers aver that, assuming, arguendo, Lackawanna County is an indispensable party, the trial court “should have afforded [the Bakers] the opportunity to join [the County] in the litigation[.]” The Bakers’ Brief at 34.

11
In Re: Est. of D.A.B., Appeal of: Byerley, D.green
pasuperct · 2022 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
2 sentences

2023See Byerley, 284 A.3d at 1239.

2023See Byerley, 284 A.3d at 1239 .

11
Commonwealth v. Randolphgreen
pasuperct · 2016 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023“To establish a voluntary consensual search, the Commonwealth must prove that a consent is the product of an essentially free and unconstrained choice - not the result of duress or coercion, express or implied, or a will overborne - under the totality of the circumstances.” Commonwealth v. Randolph, 151 A.3d 170, 179 (Pa. Super. 2016) (citation and internal quotation marks omitted).

11
Commonwealth v. Heckathorngreen
pa · 1967 · cited in 1 Pennsylvania opinions naming this issue, 2022–2022
1 sentence

2022See Smith, supra at 539 (citation omitted).

11
Hiller v. Fauseygreen
pa · 2006 · cited in 1 Pennsylvania opinions naming this issue, 2020–2020
1 sentence

2020Consequently, I agree that there is a compelling state interest at issue here. 46 United States v. O’Brien, 391 U.S. 367, 377 (1968) (outlining four factors to consider when determining the constitutionality of a content-neutral speech regulation). 47 See D.P. v. G.J.P., 146 A.3d 204, 211 (Pa. 2016) (“[T]he state, acting pursuant to its parens patriae power, has a compelling interest in safeguarding children from various kinds of physical and emotional harm and promoting their wellbeing”); Hiller v. Fausey, 904 A.2d 875, 886 (Pa. 2006) (finding protection of children to be a compelling state i

11
United States v. O'Briengreen
scotus · 1968 · cited in 1 Pennsylvania opinions naming this issue, 2020–2020
1 sentence

2020Consequently, I agree that there is a compelling state interest at issue here. 46 United States v. O’Brien, 391 U.S. 367, 377 (1968) (outlining four factors to consider when determining the constitutionality of a content-neutral speech regulation). 47 See D.P. v. G.J.P., 146 A.3d 204, 211 (Pa. 2016) (“[T]he state, acting pursuant to its parens patriae power, has a compelling interest in safeguarding children from various kinds of physical and emotional harm and promoting their wellbeing”); Hiller v. Fausey, 904 A.2d 875, 886 (Pa. 2006) (finding protection of children to be a compelling state i

11
Commonwealth v. Pursellgreen
pa · 1999 · cited in 1 Pennsylvania opinions naming this issue, 2020–2020
1 sentence

2020See Commonwealth v. Pursell, 724 A.2d 293, 303-04 (Pa. 1999), cert. denied, 528 U.S. 1999 ).

11
D.P. v. G.J.P.green
pa · 2016 · cited in 1 Pennsylvania opinions naming this issue, 2020–2020
1 sentence

2020Consequently, I agree that there is a compelling state interest at issue here. 46 United States v. O’Brien, 391 U.S. 367, 377 (1968) (outlining four factors to consider when determining the constitutionality of a content-neutral speech regulation). 47 See D.P. v. G.J.P., 146 A.3d 204, 211 (Pa. 2016) (“[T]he state, acting pursuant to its parens patriae power, has a compelling interest in safeguarding children from various kinds of physical and emotional harm and promoting their wellbeing”); Hiller v. Fausey, 904 A.2d 875, 886 (Pa. 2006) (finding protection of children to be a compelling state i

11
Commonwealth v. Snydergreen
pasuperct · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
1 sentence

2019See Snyder, supra at 170 .

11
Commonwealth v. Edmistonred
pa · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
2 sentences

2019The proper question with respect to Subsection 9545(b)(1)(i)’s timeliness exception is “whether the government interfered with Appellant’s ability to present his claim and whether Appellant was duly diligent in seeking the facts on which his claims are based.” Commonwealth v. Edmiston, 619 Pa. 549 , 65 A.3d 339, 345 (2013) (citations omitted).

2019The proper question with respect to Subsection 9545(b)(1)(i)’s timeliness exception is “whether the government interfered with Appellant’s ability to present his claim and whether Appellant was duly diligent in seeking the facts on which his claims are based.” Commonwealth v. Edmiston, 619 Pa. 549 , 65 A.3d 339, 345 (2013) (citations omitted).

11
Commonwealth v. Alcorngreen
pasuperct · 1997 · cited in 1 Pennsylvania opinions naming this issue, 2017–2017
1 sentence

2017See Commonwealth v. Alcorn, 703 A.2d 1054 , 1056–57 (Pa.Super. 1997).

11
Commonwealth v. Prestongreen
pasuperct · 2006 · cited in 1 Pennsylvania opinions naming this issue, 2017–2017
11
Com. v. AGgreen
pasuperct · 2008 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
11
Commonwealth v. Heidlergreen
pasuperct · 1999 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
11
Commonwealth v. Julianogreen
pa · 1985 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
11
Commonwealth v. Abu-Jamalgreen
pa · 2008 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
11
Commonwealth v. Marshallgreen
pasuperct · 2003 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
11
Commonwealth v. Rickabaughgreen
pasuperct · 1997 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
11
Commonwealth v. Noelgreen
pasuperct · 2012 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
11
Commonwealth v. Petrollgreen
pa · 1999 · cited in 1 Pennsylvania opinions naming this issue, 2014–2014
11
Commonwealth v. Ardingergreen
pasuperct · 2003 · cited in 1 Pennsylvania opinions naming this issue, 2014–2014
11
Commonwealth v. Kylegreen
pa · 2005 · cited in 1 Pennsylvania opinions naming this issue, 2012–2012
11
Dorsey v. Beardgreen
pa · 2009 · cited in 1 Pennsylvania opinions naming this issue, 2009–2009
11
Commonwealth v. McClendongreen
pasuperct · 2005 · cited in 1 Pennsylvania opinions naming this issue, 2008–2008
11
Commonwealth v. Edmundsgreen
pa · 1991 · cited in 1 Pennsylvania opinions naming this issue, 2008–2008
11
Lowenfield v. Phelpsgreen
scotus · 1988 · cited in 1 Pennsylvania opinions naming this issue, 2006–2006
11
Commonwealth v. Acostagreen
pasuperct · 2003 · cited in 1 Pennsylvania opinions naming this issue, 2005–2005
11
McClintock v. Worksgreen
pasuperct · 1998 · cited in 1 Pennsylvania opinions naming this issue, 2000–2000
11
Opie v. Richartgreen
pasuperct · 1991 · cited in 1 Pennsylvania opinions naming this issue, 1999–1999
11
Keystone Raceway Corp. v. State Harness Racing Commissiongreen
pa · 1961 · cited in 1 Pennsylvania opinions naming this issue, 1976–1976
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 (31)

CaseCitedYears
Slaughter v. Philadelphia Court of Common Pleas green
pa · 2007
2 sentences

2021The “newly-discovered facts” exception requires a petitioner to plead and prove that “1) the facts upon which the claim was predicted were unknown and 2) could not have been ascertained by the exercise of due diligence.” Commonwealth v. Bennett, 593 Pa. 382 , 930 A.2d 1264, 1272 (2007) (quotation marks and quotation omitted).

2020The “newly-discovered facts” exception requires a petitioner to plead and prove that “1) the facts upon which the claim was predicted were unknown and 2) could not have been ascertained by the exercise of due diligence.” Commonwealth v. Bennett, 593 Pa. 382 , 930 A.2d 1264, 1272 (2007) (quotation marks and quotation omitted).

32020–2021
Alleyne v. United States green
· 2013
2 sentences

2017This does not end our inquiry, however, as Appellant alleges he is entitled to the “new constitutional right” exception based on the U.S. Supreme Court’s decisions in Alleyne, supra, and Montgomery, supra. -6- J-S24032-17 To invoke the “new constitutional right” exception of 42 Pa.C.S.A. § 9545(b)(1)(iii), the petitioner must plead and prove that “the right asserted is a constitutional right that was recognized by the Supreme Court of the United States or the Supreme Court of Pennsylvania after the time period provided in this section and has been held by that court to apply retroactively.” 42

2016This does not end our inquiry, however, as Appellant alleges he is entitled to the “new constitutional right” exception based on the U.S. Supreme Court’s decisions in Alleyne v. United States, 133 S.Ct. 2151 (2013), and Montgomery v. Louisiana, 136 S.Ct. 718 (2016), as well as the Pennsylvania Supreme Court’s decision in Commonwealth v. Dickson, 591 Pa. 364 , 918 A.2d 95 (2007).

32016–2017
Commonwealth v. Colon green
pasuperct · 2014
1 sentence

2026This does not end our inquiry, however, as the Commonwealth was also required to establish “corroboration by other evidence of record.” Id. at 1040 .

12026–2026
Jones v. Mississippi green
scotus · 2021
1 sentence

2023However, this does not end our inquiry as Appellant contends that he is entitled to the timeliness exception set forth in 42 Pa.C.S.A. § 9545(b)(1)(iii) since Jones v. Mississippi, 141 S.Ct. 1307 (2021), fashioned a new constitutional right that applies retroactively.

12023–2023
Commonwealth v. Davis green
pasuperct · 2011
1 sentence

2021However, this does not end our inquiry, as the second step of the test requires that we “inspect[] the underlying facts that led to the conviction to determine if dishonesty or false statement facilitated the commission of the crime.” Id.

12021–2021
Commonwealth v. Small, E., Aplt. green
pa · 2018
1 sentence

2020However, this does not end our inquiry, as the Small Court held that, even if new evidence is “upon the same point,” the evidence is not cumulative if it “is of a different and ‘higher’ grade or character.” Id. at 974 .

12020–2020
Commonwealth v. Rivera green
pa · 2009
2 sentences

2019As the record reveals, Appellant did not object to the admission of the autopsy report, and, thus, he has waived his claim of error. 7 See Pa.R.A.P. 302(a) ("Issues not raised in the lower court are waived and cannot be raised for the first time on appeal."); Commonwealth v. Rivera , 603 Pa. 340 , 983 A.2d 1211 , 1229 (2009) (holding lack of contemporaneous objection results in waiver of issue on appeal). 8 This does not end our inquiry, however, as Appellant has preserved his claim that the trial court violated his Confrontation Clause rights when it permitted Dr. Collins to offer expert opin

2019As the record reveals, Appellant did not object to the admission of the autopsy report, and, thus, he has waived his claim of error. 7 See Pa.R.A.P. 302(a) ("Issues not raised in the lower court are waived and cannot be raised for the first time on appeal."); Commonwealth v. Rivera , 603 Pa. 340 , 983 A.2d 1211 , 1229 (2009) (holding lack of contemporaneous objection results in waiver of issue on appeal). 8 This does not end our inquiry, however, as Appellant has preserved his claim that the trial court violated his Confrontation Clause rights when it permitted Dr. Collins to offer expert opin

12019–2019
Carpenter v. United States green
scotus · 2018
1 sentence

2019Specifically, he avers the -6- J-S43032-19 warrantless seizure of his cell-site location information3 violated the United States Supreme Court’s recent Opinion in Carpenter v. United States, ___ U.S. ___, 138 S.Ct. 2206 (2018), which was filed on June 22, 2018.4 In Carpenter, the High Court addressed the issue of cell-site location information and an individual’s expectations of privacy for Fourth Amendment purposes.

12019–2019
Commonwealth v. Barndt green
pasuperct · 2013
1 sentence

2017Barndt, supra. This does not end our inquiry, however, as Appellant alternatively argues that his counsel directly and specifically misinformed him about the consequences of pleading guilty at lower court docket number CP-33-CR- -8- J-S69038-17 0000171-2015.

12017–2017
Commonwealth v. Dickson green
pa · 2007
12016–2016
Peugh v. United States green
scotus · 2013
12016–2016
Commonwealth v. Gamboa-Taylor green
pa · 2000
12016–2016
Commonwealth v. Natividad green
pa · 2001
12015–2015
Commonwealth v. Freeman green
pa · 2003
12015–2015
Maxim Crane Works v. Workers' Compensation Appeal Board green
pacommwct · 2007
12014–2014
Commonwealth v. Kriston green
pa · 1991
12012–2012
Commonwealth v. Stafford green
pasuperct · 2011
12012–2012
Dilks v. Flohr Chevrolet green
pa · 1963
12010–2010
Commonwealth v. Clark green
pasuperct · 2004
12009–2009
Commonwealth v. Touw green
pasuperct · 2001
12009–2009
Roe v. Flores-Ortega green
scotus · 2000
12009–2009
Prudential Property & Casualty Insurance v. Hinson green
paed · 2003
12007–2007
Prince v. Massachusetts green
scotus · 1944
12006–2006
Wisconsin v. Yoder green
scotus · 1972
12006–2006
Commonwealth v. Aponte green
pa · 2004
12005–2005
Commonwealth v. Hoetzel green
pasuperct · 1981
12005–2005
Green v. Mizner green
pasuperct · 1997
12000–2000
Clymire v. McKivitz green
pa · 1986
11999–1999
Federal Deposit Insurance Corporation v. Hinkson green
ca3 · 1988
11999–1999
Bell v. Beneficial Consumer Discount Co. green
pa · 1975
11990–1990
Smith v. Hooey green
scotus · 1969
11975–1975

Where else courts name it

PA 65 (1975–2026) CA 47 (1977–2026) TX 38 (1977–2023) IL 32 (1980–2024) OH 29 (1986–2026) GA 25 (1989–2024) TN 20 (1991–2025) NY 20 (1980–2025) IN 17 (1988–2016) CT 14 (1985–2021) MI 13 (1977–2025) AZ 13 (1981–2019) MD 12 (1984–2016) WA 12 (1994–2022) MO 10 (1982–2023) AK 9 (1978–2023) OK 9 (1988–2022) IA 9 (1981–2023) MA 8 (1977–2024) WI 8 (1980–2025) CO 7 (2004–2024) VA 7 (1985–2022) UT 7 (1990–2025) NM 7 (2008–2023) MN 6 (2002–2016) FL 6 (1980–2025) DC 6 (1978–2017) LA 5 (1962–2017) NC 5 (1998–2024) KS 5 (1976–2021) KY 4 (1999–2024) SC 4 (1997–2022) HI 4 (1980–2017) SD 4 (1998–2025) ND 3 (2004–2013) NJ 3 (1981–2018) MT 3 (2003–2017) OR 3 (1975–2012) VT 3 (1997–2024) NV 2 (2018–2018) RI 2 (1989–2014) ID 2 (1989–2017) AR 2 (1988–2020) NH 2 (1978–2007) MS 2 (1999–2002) NE 2 (2004–2023)

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