case-by-case analysis (Pennsylvania) · Go Syfert
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case-by-case analysis in Pennsylvania

60 Pennsylvania opinions name it 7 courts 1974–2025 12 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 (29)

CaseFollowedCited
Commonwealth v. McAfeegreen
pasuperct · 2004 · cited in 4 Pennsylvania opinions naming this issue, 2006–2022
2 sentences

2022Commonwealth v. McAfee, 849 A.2d 270, 274 (Pa. Super. 2004).

2006Commonwealth v. McAfee, 849 A.2d 270, 274 (Pa.Super.2004). ¶ 19 We conduct a case-by-case analysis to determine what allegations constitute a substantial question.

44
Commonwealth v. Kylegreen
pa · 2005 · cited in 4 Pennsylvania opinions naming this issue, 2005–2017
2 sentences

2017“This interpretation and resultant bright-line rule,” the Court explained, “will obviate the necessity of evi-dentiary hearings into the particulars of each electronic monitoring program around the Commonwealth, which would be necessary to implement a case-by-case test.” Id. at 22.

2015In Chiappini, the lead opinion, authored by Justice Zappala and joined by then Chief Justice Flaherty and Justice Newman, “suggested a case-by-case test for determining whether a person on an electronic monitoring program has spent time in Section 9760 custody, which would require the examination of the extent of control exercised by those in authority in the program.” Kyle, supra, 874 A.2d at 19 .

34
Commonwealth v. Brickergreen
pasuperct · 2012 · cited in 3 Pennsylvania opinions naming this issue, 2016–2017
2 sentences

2017“A claim that a sentence is manifestly excessive such that it constitutes too severe a punishment raises a substantial question.” Commonwealth v. Kelly, 33 A.3d 638, 640 (Pa. Super. 2011); Commonwealth v. Perry, 883 A.2d 599, 602 (Pa. Super. 2005) (appellant raised a substantial question when he claimed that a sentencing court imposed an excessive sentence and failed to consider substantial mitigating factors). “[A]n averment that the court sentenced based solely on the seriousness of the offense and failed to consider all relevant factors raises a - 13 - J-S89040-16 substantial question.” Com

2016“We conduct a case-by-case analysis to determine what allegations constitute a substantial question.” Commonwealth v. Malovich, 903 A.2d 1247, 1252 (Pa. Super. 2006) (citation omitted); see also 42 Pa.C.S. § 9781(b). “[A]n averment that the court sentenced based solely on the seriousness of the offense and failed to consider all relevant factors raises a substantial question.” Commonwealth v. Bricker, 41 A.3d 872, 875 (Pa. Super. 2012) (citation omitted).

33
Commonwealth v. Malovichgreen
pasuperct · 2006 · cited in 3 Pennsylvania opinions naming this issue, 2016–2017
2 sentences

2017“We conduct a case-by-case analysis to determine what allegations constitute a substantial question.” Commonwealth v. Malovich, 903 A.2d 1247, 1252 (Pa. Super. 2006) (citation omitted); see also 42 Pa.C.S. § 9781(b).

2016“We conduct a case-by-case analysis to determine what allegations constitute a substantial question.” Commonwealth v. Malovich, 903 A.2d 1247, 1252 (Pa. Super. 2006) (citation omitted); see also 42 Pa.C.S. § 9781(b).

33
Commonwealth v. Sweeneygreen
pa · 1987 · cited in 5 Pennsylvania opinions naming this issue, 1998–2020
2 sentences

2016Therefore, “resolution of the problem turns upon a case by case analysis with particular attention to the reasons given by the trial court at the time the request for withdrawal is denied.” Id.

1998Therefore, “resolution of the problem turns upon a case by case analysis with particular attention to the reasons given by the trial court at the time the request for withdrawal is denied.” Id.

25
Commonwealth v. BOROVICHKAgreen
pasuperct · 2011 · cited in 2 Pennsylvania opinions naming this issue, 2022–2025
2 sentences

2025See Commonwealth v. Borovichka, 18 A.3d 1242, 1250 (Pa. Super. 2011).

2022Rather, when determining whether suppression is the appropriate remedy, a court should consider the totality of the circumstances of the case.” Commonwealth v. Borovichka, 18 A.3d 1242, 1249 (Pa. Super. 2011) (citing O’ Shea, supra at 1030 ); see also Commonwealth v. Henry, 943 A.2d 967, 972 (Pa.Super. 2008) (when deciding suppression issues based on MPJA violations, a reviewing court must engage in a case-by-case analysis, based on the totality of the circumstances).

22
Commonwealth v. Henrygreen
pasuperct · 2008 · cited in 2 Pennsylvania opinions naming this issue, 2011–2022
2 sentences

2022Rather, when determining whether suppression is the appropriate remedy, a court should consider the totality of the circumstances of the case.” Commonwealth v. Borovichka, 18 A.3d 1242, 1249 (Pa. Super. 2011) (citing O’ Shea, supra at 1030 ); see also Commonwealth v. Henry, 943 A.2d 967, 972 (Pa.Super. 2008) (when deciding suppression issues based on MPJA violations, a reviewing court must engage in a case-by-case analysis, based on the totality of the circumstances).

2011Commonwealth v. Henry, 943 A.2d 967, 972 (Pa. Super.2008).

22
Commonwealth v. Perrygreen
pasuperct · 2005 · cited in 2 Pennsylvania opinions naming this issue, 2016–2017
2 sentences

2017“A claim that a sentence is manifestly excessive such that it constitutes too severe a punishment raises a substantial question.” Commonwealth v. Kelly, 33 A.3d 638, 640 (Pa. Super. 2011); Commonwealth v. Perry, 883 A.2d 599, 602 (Pa. Super. 2005) (appellant raised a substantial question when he claimed that a sentencing court imposed an excessive sentence and failed to consider substantial mitigating factors). “[A]n averment that the court sentenced based solely on the seriousness of the offense and failed to consider all relevant factors raises a - 13 - J-S89040-16 substantial question.” Com

2016“A claim that a sentence is manifestly excessive such that it constitutes too severe a punishment raises a substantial question.” Commonwealth v. Kelly, 33 A.3d 638, 640 (Pa. Super. 2011); -6- J-S71044-16 Commonwealth v. Perry, 883 A.2d 599, 602 (Pa. Super. 2005) (concluding appellant raised a substantial question when he claimed that a sentencing court imposed an excessive sentence and failed to consider substantial mitigating factors). “[A]n averment that the court sentenced based solely on the seriousness of the offense and failed to consider all relevant factors raises a substantial questi

22
Commonwealth v. Kellygreen
pasuperct · 2011 · cited in 2 Pennsylvania opinions naming this issue, 2016–2017
2 sentences

2017“A claim that a sentence is manifestly excessive such that it constitutes too severe a punishment raises a substantial question.” Commonwealth v. Kelly, 33 A.3d 638, 640 (Pa. Super. 2011); Commonwealth v. Perry, 883 A.2d 599, 602 (Pa. Super. 2005) (appellant raised a substantial question when he claimed that a sentencing court imposed an excessive sentence and failed to consider substantial mitigating factors). “[A]n averment that the court sentenced based solely on the seriousness of the offense and failed to consider all relevant factors raises a - 13 - J-S89040-16 substantial question.” Com

2016“A claim that a sentence is manifestly excessive such that it constitutes too severe a punishment raises a substantial question.” Commonwealth v. Kelly, 33 A.3d 638, 640 (Pa. Super. 2011); -6- J-S71044-16 Commonwealth v. Perry, 883 A.2d 599, 602 (Pa. Super. 2005) (concluding appellant raised a substantial question when he claimed that a sentencing court imposed an excessive sentence and failed to consider substantial mitigating factors). “[A]n averment that the court sentenced based solely on the seriousness of the offense and failed to consider all relevant factors raises a substantial questi

22
Commonwealth v. Chester, M., Aplt.green
pa · 2014 · cited in 2 Pennsylvania opinions naming this issue, 2015–2016
2 sentences

2016See Chester, supra at 65 .

2015See Chester, 101 A.3d at 65 .

22
Commonwealth v. Mageegreen
pasuperct · 2017 · cited in 2 Pennsylvania opinions naming this issue, 2019–2023
2 sentences

2023Sandusky, 203 A.3d at 1102 (quoting Magee, 177 A.3d at 322-23 ).

2023Sandusky, 203 A.3d at 1102 (quoting Magee, 177 A.3d at 322-23 ).

12
Commonwealth v. Vanskivergreen
pasuperct · 2003 · cited in 2 Pennsylvania opinions naming this issue, 2005–2006
2 sentences

2006After Chiappini , came the Delaware County 2003 en banc Superior court decision in Commonwealth v. Vanskiver, 819 A.2d 69 (Pa.Super.2003), which denied credit for time served, but did so employing the case-by-case basis of Chiap-pini, and concluding that the terms of the electronic monitoring were not so restrictive as to be considered “in custody.” To the extent Vanskiver used the case-by-case test, it also was overruled by Kyle .

2005See Vanskiver, 819 A.2d at 79 (Graci, J., concurring).

12
D'Agata National Inc. v. Workmen's Compensation Appeal Boardgreen
pacommwct · 1984 · cited in 1 Pennsylvania opinions naming this issue, 2022–2022
1 sentence

2022Remaining aware that this is a case-by-case inquiry and that each matter will depend on its evidence, the foregoing cases suggest that the personal comfort doctrine may apply when the claimant’s time away from the work premises is informal in nature, purely devoted to personal comfort of a physical nature, such as a cigarette break or to procure food, and brief enough that the course of employment is not broken. 1912 Hoover House Rest., 103 A.3d at 444 (cigarette break outside of restaurant); Dixon, 764 A.2d at 637 (takeout food from restaurant in building lobby); D’Agata, 479 A.2d at 99 (cup

11
U.S. Airways v. Workers' Compensation Appeal Boardgreen
pacommwct · 2000 · cited in 1 Pennsylvania opinions naming this issue, 2022–2022
1 sentence

2022Remaining aware that this is a case-by-case inquiry and that each matter will depend on its evidence, the foregoing cases suggest that the personal comfort doctrine may apply when the claimant’s time away from the work premises is informal in nature, purely devoted to personal comfort of a physical nature, such as a cigarette break or to procure food, and brief enough that the course of employment is not broken. 1912 Hoover House Rest., 103 A.3d at 444 (cigarette break outside of restaurant); Dixon, 764 A.2d at 637 (takeout food from restaurant in building lobby); D’Agata, 479 A.2d at 99 (cup

11
1912 Hoover House Restaurant v. Workers' Compensation Appeal Boardgreen
pacommwct · 2014 · cited in 1 Pennsylvania opinions naming this issue, 2022–2022
1 sentence

2022Remaining aware that this is a case-by-case inquiry and that each matter will depend on its evidence, the foregoing cases suggest that the personal comfort doctrine may apply when the claimant’s time away from the work premises is informal in nature, purely devoted to personal comfort of a physical nature, such as a cigarette break or to procure food, and brief enough that the course of employment is not broken. 1912 Hoover House Rest., 103 A.3d at 444 (cigarette break outside of restaurant); Dixon, 764 A.2d at 637 (takeout food from restaurant in building lobby); D’Agata, 479 A.2d at 99 (cup

11
Giant Eagle, Inc. v. Workers' Compensation Appeal Boardgreen
pa · 2012 · cited in 1 Pennsylvania opinions naming this issue, 2018–2018
1 sentence

2018Giant Eagle , 39 A.3d at 298 (conducting an ambiguity analysis as to the meaning of "compensation" in section 314(a) and concluding that it "need not always include medical benefits").

11
Commonwealth v. Chiappinigreen
pa · 2001 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
11
Commonwealth v. Chopakgreen
pa · 1992 · cited in 1 Pennsylvania opinions naming this issue, 2013–2013
11
McGonagle v. Union Fidelity Corp.green
pa · 1989 · cited in 1 Pennsylvania opinions naming this issue, 2013–2013
11
McKune v. Lilegreen
scotus · 2002 · cited in 1 Pennsylvania opinions naming this issue, 2011–2011
11
Sykes v. Glaxo-SmithKlinegreen
paed · 2007 · cited in 1 Pennsylvania opinions naming this issue, 2011–2011
11
Com. v. Dentgreen
pa · 2005 · cited in 1 Pennsylvania opinions naming this issue, 2006–2006
11
Commonwealth v. Drucegreen
pasuperct · 2005 · cited in 1 Pennsylvania opinions naming this issue, 2005–2005
11
Commonwealth v. McCalmangreen
pasuperct · 2002 · cited in 1 Pennsylvania opinions naming this issue, 2005–2005
11
United States v. Cronicgreen
scotus · 1984 · cited in 1 Pennsylvania opinions naming this issue, 2003–2003
11
In Re Estate of Brockermangreen
pa · 1984 · cited in 1 Pennsylvania opinions naming this issue, 2002–2002
11
Matukonis v. Trainergreen
pasuperct · 1995 · cited in 1 Pennsylvania opinions naming this issue, 1998–1998
11
Rossi v. Pennsylvania State Universitygreen
pa · 1985 · cited in 1 Pennsylvania opinions naming this issue, 1989–1989
11
Holden v. Hardygreen
· 1898 · cited in 1 Pennsylvania opinions naming this issue, 1974–1974
11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Beachem v. Unemployment Compensation Board of Reviewgreen
pacommwct · 2000 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
1 sentence

2024Id.; Shaffer, 928 A.2d at 394 ; but see Beachem, 760 A.2d at 71 .

11

Also cited on this issue (28)

CaseCitedYears
Commonwealth v. Devlin green
pa · 1975
2 sentences

2020The Court emphasized that a case-by-case inquiry, which considered the nature of the crime and the age of the victim, was appropriate, and the Commonwealth must only fix the date of the offense “with reasonable certainty.” Id. at 890-92 .

2019The Court emphasized that a case-by-case inquiry, which considered the nature of the crime and the age of the victim, was appropriate, and the Commonwealth must only fix the date of the offense “with reasonable certainty.” Id. at 890-92 . - 13 - J-A29018-18 In this case, the trial court considered the facts and the controlling authority and concluded that the Commonwealth had fixed the time frame of the charged offenses with “reasonable certainty” considering the age of the victim at the time of the alleged crimes.

32019–2024
Joella, R. v. Cole, A. green
pasuperct · 2019
2 sentences

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).

22023–2024
Remy v. Michael D'S Carpet Outlets green
pa · 1990
2 sentences

2019However, Pennsylvania does not adopt a per se rule on subrogation, but instead adopts a case by case analysis.”) (citing Remy, 571 A.2d 446 ); see also Dattel Family Ltd.

2019However, Pennsylvania does not adopt a per se rule on subrogation, but instead adopts a case by case analysis.”) (citing Remy, 571 A.2d 446 ); see also Dattel Family Ltd.

22019–2019
Commonwealth v. Kriston green
pa · 1991
2 sentences

2007Kyle thus noted that the Chiappini plurality’s case-by-case test was an aberration within a general trend against allowing credit for home arrest, which had been in place since Commonwealth v. Kriston, 527 Pa. 90 , 588 A.2d 898 (1991) (holding that credit generally is not due for time spent on home monitoring, but for equitable reasons, credit was awarded). ¶ 12 The Kyle Court, with only Justice Newman dissenting, concluded that: In summary, the proposed case-by-case test for credit for time served, as set forth by the lead opinion in Chiappini , was not endorsed by a majority of the Court and

2007Kyle thus noted that the Chiappini plurality’s case-by-case test was an aberration within a general trend against allowing credit for home arrest, which had been in place since Commonwealth v. Kriston, 527 Pa. 90 , 588 A.2d 898 (1991) (holding that credit generally is not due for time spent on home monitoring, but for equitable reasons, credit was awarded). ¶ 12 The Kyle Court, with only Justice Newman dissenting, concluded that: In summary, the proposed case-by-case test for credit for time served, as set forth by the lead opinion in Chiappini , was not endorsed by a majority of the Court and

22005–2007
Shaffer v. Unemployment Compensation Board of Review green
pacommwct · 2007
1 sentence

2024Id.; Shaffer, 928 A.2d at 394 ; but see Beachem, 760 A.2d at 71 .

12024–2024
In Re Broad Mountain Development Co., LLC green
pacommwct · 2011
1 sentence

2023In re Broad Mountain, 17 A.3d at 443 .

12023–2023
Commonwealth v. Strickler green
pa · 2000
1 sentence

2023The totality-of-the-circumstances test [ultimately centers] on whether the suspect has in some way been restrained by physical force or show of coercive authority. [See Strickler, 757 A.2d at 890 ].

12023–2023
Commonwealth v. Hann green
pa · 2013
1 sentence

2023The Court reviewed practices in other jurisdictions and concluded the language of Rule 536(A)(2)(d) “implicates a case-by-case analysis of when forfeiture is or is not proper, and whether that forfeiture should be for the full sum of the bail or some reduced amount.” Id. at 67 .

12023–2023
Commonwealth v. O'Shea green
pa · 1989
1 sentence

2022Rather, when determining whether suppression is the appropriate remedy, a court should consider the totality of the circumstances of the case.” Commonwealth v. Borovichka, 18 A.3d 1242, 1249 (Pa. Super. 2011) (citing O’ Shea, supra at 1030 ); see also Commonwealth v. Henry, 943 A.2d 967, 972 (Pa.Super. 2008) (when deciding suppression issues based on MPJA violations, a reviewing court must engage in a case-by-case analysis, based on the totality of the circumstances).

12022–2022
Strickland v. Washington green
scotus · 1984
1 sentence

2020Id.

12020–2020
Dale Manufacturing Co. v. Bressi green
pa · 1980
1 sentence

2018Co., 421 A.2d at 654 . [J-24-2018] - 7 “compensation,” as used in article III of the WCA, is required whenever that word is capable of at least two valid interpretations.

12018–2018
In Re KTEL green
pasuperct · 2009
1 sentence

2016Id. (declining to quash or dismiss appeal or to waive issues, in light of purpose to expedite disposition of children’s fast track appeals, where mother filed her concise statement three days after notice of appeal and late filing did not prejudice other parties in case).

12016–2016
Commonwealth v. Sandusky green
pasuperct · 2013
1 sentence

2015Id. at 668 .

12015–2015
S.J.S. v. M.J.S. green
pasuperct · 2013
12014–2014
O'Reilly v. (a) Hickory On Green Homeowners Ass'n green
pacommwct · 2011
12013–2013
Bruesewitz v. Wyeth Inc. green
ca3 · 2009
12011–2011
Commonwealth v. Conahan green
pa · 1991
12007–2007
Commonwealth v. Frye green
pasuperct · 2004
12006–2006
Morgan's Home Equipment Corp. v. Martucci green
pa · 1957
12005–2005
United Refining Co. v. Unemployment Compensation Board of Review green
pacommwct · 1995
12003–2003
Wilkes-Barre Iron & Wire Works, Inc. v. Pargas of Wilkes-Barre, Inc. green
pa · 1985
11995–1995
Motheral v. Burkhart green
pa · 1990
11995–1995
Skinner v. Flymo, Inc. green
pa · 1986
11991–1991
Burger King Corp. v. Rudzewicz green
scotus · 1985
11991–1991
Angelet v. Shivar green
kyctapp · 1980
11990–1990
Gillespie-Linton v. Miles green
mdctspecapp · 1984
11990–1990
Sostock v. Reiss green
illappct · 1980
11990–1990
Jacob v. New Kensington Y.M.C.A. green
pasuperct · 1983
11986–1986

Statutes the citing opinions construe

PA § 18 Pa. Cons. Stat. § 3123 (4) PA § 42 Pa. Cons. Stat. § 9541 (4) PA § 42 Pa. Cons. Stat. § 9760 (4) PA § 18 Pa. Cons. Stat. § 2701 (3) PA § 18 Pa. Cons. Stat. § 4304 (3) PA § 18 Pa. Cons. Stat. § 5121 (3) PA § 42 Pa. Cons. Stat. § 9721 (3) PA § 42 Pa. Cons. Stat. § 9781 (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

TN 121 (1985–2026) CA 110 (1974–2026) IL 90 (1978–2025) NY 83 (1972–2026) TX 75 (1972–2025) OH 72 (1979–2025) WA 63 (1986–2026) CT 61 (1986–2025) PA 60 (1974–2025) NJ 55 (1958–2026) LA 53 (1985–2024) NM 49 (1983–2024) FL 43 (1976–2026) CO 43 (1976–2026) NC 40 (1984–2026) ID 34 (1978–2026) RI 32 (1985–2022) WI 30 (1977–2024) MD 29 (1975–2025) MI 28 (1981–2024) MO 24 (1964–2021) IA 23 (1996–2023) MS 23 (1979–2024) KS 22 (1981–2022) MA 21 (1982–2024) VA 21 (1980–2024) SC 20 (1984–2020) OR 18 (1952–2025) AZ 18 (1985–2025) MN 17 (1988–2025) UT 17 (1989–2025) KY 16 (1987–2026) GA 14 (1992–2023) NE 12 (1983–2023) MT 11 (1993–2025) HI 10 (1994–2025) OK 9 (1983–2022) ND 9 (1985–2024) WV 8 (1983–2025) DC 8 (1986–2016) VT 8 (1992–2020) AL 7 (1986–2007) AK 7 (1983–2022) IN 7 (1993–2019) NV 6 (2008–2016) WY 6 (1984–2024) ME 5 (1992–2018) AR 5 (1981–2008) NH 4 (1991–2007) SD 3 (2001–2023) DE 2 (2013–2025)

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.

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