first part test (Pennsylvania) · Go Syfert
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first part test in Pennsylvania

59 Pennsylvania opinions name it 9 courts 1904–2026 11 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 (28)

CaseFollowedCited
Scarpitti v. Weborggreen
pa · 1992 · cited in 3 Pennsylvania opinions naming this issue, 2005–2014
2 sentences

2006We concluded that the first part of the test sets forth a standing requirement that leaves “discretion with the court to determine whether recognition of [intended] beneficiary status would be appropriate,” while the second part of the test defines “the two types of claimants who may be intended as third party beneficiaries.” Scarpitti, 609 A.2d at 150 .

2006We concluded that the first part of the test sets forth a standing requirement that leaves "discretion with the court to determine whether recognition of [intended] beneficiary status would be appropriate," while the second part of the test defines "the two types of claimants who may be intended as third party beneficiaries." Scarpitti, 609 A.2d at 150 .

23
Kachinski v. Workmen's Compensation Appeal Boardgreen
pa · 1987 · cited in 4 Pennsylvania opinions naming this issue, 2007–2008
2 sentences

2008The first part of the test states: "The employer who seeks to modify a claimant’s benefits on the basis that he has recovered some or all of this ability must first produce medical evidence of a change in condition.” Id. at 252, 532 A.2d at 380 (emphasis added).

2008The first part of the test states: "The employer who seeks to modify a claimant's benefits on the basis that he has recovered some or all of this ability must first produce medical evidence of a change in condition." Id. at 252, 532 A.2d at 380 (emphasis added).

14
Commonwealth v. Fitzpatrickgreen
pasuperct · 1995 · cited in 2 Pennsylvania opinions naming this issue, 1999–2002
2 sentences

2002Commonwealth v. Fitzpatrick, 446 Pa.Super. 87 , 666 A.2d 323, 325 (1995). ¶ 7 In the first part of our analysis, we must focus on whether Officer Magerl had the reasonable suspicion necessary to subject Appellant to an investigatory stop and frisk.

2002Commonwealth v. Fitzpatrick, 446 Pa.Super. 87 , 666 A.2d 323, 325 (1995). ¶ 7 In the first part of our analysis, we must focus on whether Officer Magerl had the reasonable suspicion necessary to subject Appellant to an investigatory stop and frisk.

12
Wilder & Miller, P.C. v. Commonwealthgreen
pacommwct · 1987 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
1 sentence

2024Bd. of Rev., 525 A.2d 852, 856 (Pa. Cmwlth. 1987) (“A claimant is attached to the labor force as long as she is able to do some type of work and there is a reasonable opportunity for securing such work in the vicinity of her residence.”) (emphasis added).5 Turning to the first part of the inquiry, we conclude that the presumption that Claimant was able and available to work was rebutted by evidence of Claimant’s limitation on her availability to accept the work offered by Employer – i.e., hybrid in-person and remote instruction beginning on December 7, 2020.

11
Adoption of: J.B. Appeal of: L.M.green
pasuperct · 2024 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
1 sentence

2024See M.E.L., 298 A.3d at 127; see also J.M.B., 308 A.3d at 1268 ; see also 18 Pa.C.S. § 4301; 23 Pa.C.S. § 3304(a)(1).

11
Bruno, D., Aplts. v. Erie Insurancegreen
pa · 2014 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
1 sentence

2024See id.

11
Commonwealth v. Kalichakgreen
pasuperct · 2008 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
1 sentence

2015However, Hall has not filed a post-sentence motion. “[W]hen a court revokes probation and imposes a new sentence, a criminal defendant needs to preserve challenges to the discretionary aspects of that new sentence either by objecting during the revocation sentencing or by filing a post-sentence motion.” Commonwealth v. Kalichak, 943 A.2d 285, 289 (Pa. Super. 2008); see also Commonwealth v. Colon, 102 A.3d 1033 (Pa. Super. 2014).

11
Commonwealth v. Washingtongreen
pasuperct · 1976 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
1 sentence

2015See Conunonwealth v. Stewart, 84 A.3d 701°, 712 (Pa.Super. 2013); Commonwealth v. Washington, 361 A.2d 670, 674 (Pa.Super. 1976).

11
Alex v. Gavingreen
pa · 2014 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
1 sentence

2015See Conunonwealth v. Stewart, 84 A.3d 701°, 712 (Pa.Super. 2013); Commonwealth v. Washington, 361 A.2d 670, 674 (Pa.Super. 1976).

11
Commonwealth v. Colongreen
pasuperct · 2014 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
1 sentence

2015However, Hall has not filed a post-sentence motion. “[W]hen a court revokes probation and imposes a new sentence, a criminal defendant needs to preserve challenges to the discretionary aspects of that new sentence either by objecting during the revocation sentencing or by filing a post-sentence motion.” Commonwealth v. Kalichak, 943 A.2d 285, 289 (Pa. Super. 2008); see also Commonwealth v. Colon, 102 A.3d 1033 (Pa. Super. 2014).

11
Joe v. Prison Health Services, Inc.green
pacommwct · 2001 · cited in 1 Pennsylvania opinions naming this issue, 2008–2008
2 sentences

2008The first part of the inquiry is whether attorney-client privilege does indeed apply to a particular communication.") (citations omitted); Carbis Walker, supra at 581 ("[T]he party who has asserted the attorney-client privilege must initially set forth facts showing that the privilege has been properly invoked. . . .") (citation omitted); Joe v. Prison Health Servs., 782 A.2d 24, 31 (Pa.Cmwlth. 2001) ("The party asserting the privilege has the initial burden to prove that it is properly invoked, and the party seeking to overcome the privilege has the burden to prove an application exception to

2008The first part of the inquiry is whether attorney-client privilege does indeed apply to a particular communication.”) (citations omitted); Carbis Walker, supra at 581 ("[Tlhe party who has asserted the attorney-client privilege must initially set forth facts showing that the privilege has been properly invoked_”) (citation omitted); Joe v. Prison Health Servs., 782 A.2d 24, 31 (Pa.Cmwlth.2001) ("The party asserting the privilege has the initial burden to prove that it is properly invoked, and the party seeking to overcome the privilege has the burden to prove an application exception to the pr

11
Milne v. Milnegreen
pa · 1989 · cited in 1 Pennsylvania opinions naming this issue, 2008–2008
2 sentences

2008Caplan v. Caplan, 400 Pa.Super. 352 , 583 A.2d 823 (1990); see also Milne v. Milne, 383 Pa.Super. 177 , 556 A.2d 854 (1989). ¶ 19 With regard to the first part of the test, namely whether the child is physically and mentally able to engage in profitable employment, the trial court found that “the testimony presented on Dustin’s behalf [was] neither convincing [n]or complete enough to meet the standard of proof [in this case].” Trial Court Opinion, 9/12/07, at 10.

2008Caplan v. Caplan, 400 Pa.Super. 352 , 583 A.2d 823 (1990); see also Milne v. Milne, 383 Pa.Super. 177 , 556 A.2d 854 (1989). ¶ 19 With regard to the first part of the test, namely whether the child is physically and mentally able to engage in profitable employment, the trial court found that “the testimony presented on Dustin’s behalf [was] neither convincing [n]or complete enough to meet the standard of proof [in this case].” Trial Court Opinion, 9/12/07, at 10.

11
Popovitch v. Kasperlikgreen
pawd · 1947 · cited in 1 Pennsylvania opinions naming this issue, 2008–2008
11
Bonds v. Bondsgreen
pasuperct · 1997 · cited in 1 Pennsylvania opinions naming this issue, 2008–2008
2 sentences

2008Judicial decision gives no clear answer to this question.”), accord at § 2325 ("All involuntary disclosures ... are not protected by the privilege, on the principle that ... the law ... leaves to the client and attorney to take measures of caution....”); Carbis Walker, supra at 579 ("[T]he appellate courts of this jurisdiction have found waiver [of the attorney-client privilege] when the communication is made in the presence of or communicated to a third party or to the court ... ”), quoting Bonds v. Bonds, 455 Pa.Super. 610 , 689 A.2d 275, 277 (1997); Popovitch v. Kasperlik, 70 F.Supp. 376, 3

2008Judicial decision gives no clear answer to this question.”), accord at § 2325 ("All involuntary disclosures ... are not protected by the privilege, on the principle that ... the law ... leaves to the client and attorney to take measures of caution....”); Carbis Walker, supra at 579 ("[T]he appellate courts of this jurisdiction have found waiver [of the attorney-client privilege] when the communication is made in the presence of or communicated to a third party or to the court ... ”), quoting Bonds v. Bonds, 455 Pa.Super. 610 , 689 A.2d 275, 277 (1997); Popovitch v. Kasperlik, 70 F.Supp. 376, 3

11
Carbis Walker, LLP v. Hill, Barth and King, LLCgreen
pasuperct · 2007 · cited in 1 Pennsylvania opinions naming this issue, 2008–2008
2 sentences

2008The first part of the inquiry is whether attorney-client privilege does indeed apply to a particular communication.") (citations omitted); Carbis Walker, supra at 581 ("[T]he party who has asserted the attorney-client privilege must initially set forth facts showing that the privilege has been properly invoked. . . .") (citation omitted); Joe v. Prison Health Servs., 782 A.2d 24, 31 (Pa.Cmwlth. 2001) ("The party asserting the privilege has the initial burden to prove that it is properly invoked, and the party seeking to overcome the privilege has the burden to prove an application exception to

2008The first part of the inquiry is whether attorney-client privilege does indeed apply to a particular communication.”) (citations omitted); Carbis Walker, supra at 581 ("[Tlhe party who has asserted the attorney-client privilege must initially set forth facts showing that the privilege has been properly invoked_”) (citation omitted); Joe v. Prison Health Servs., 782 A.2d 24, 31 (Pa.Cmwlth.2001) ("The party asserting the privilege has the initial burden to prove that it is properly invoked, and the party seeking to overcome the privilege has the burden to prove an application exception to the pr

11
Commonwealth v. Eddingsgreen
pasuperct · 1998 · cited in 1 Pennsylvania opinions naming this issue, 2007–2007
11
Dillon v. Workmen's Compensation Appeal Boardgreen
pa · 1994 · cited in 1 Pennsylvania opinions naming this issue, 2007–2007
11
Commonwealth v. Szuchongreen
pa · 1993 · cited in 1 Pennsylvania opinions naming this issue, 2006–2006
11
Clifton v. Suburban Cable TV Co., Inc.green
pasuperct · 1994 · cited in 1 Pennsylvania opinions naming this issue, 2005–2005
11
Clifton v. Suburban Cable Television Co.green
scotus · 1995 · cited in 1 Pennsylvania opinions naming this issue, 2005–2005
11
Clifton v. Suburban Cable Television Co.green
scotus · 1995 · cited in 1 Pennsylvania opinions naming this issue, 2005–2005
11
Brewer v. Scottgreen
scotus · 1995 · cited in 1 Pennsylvania opinions naming this issue, 2005–2005
11
United States v. Drivergreen
sdd · 1991 · cited in 1 Pennsylvania opinions naming this issue, 2001–2001
11
Oberti v. Board Of Educationgreen
ca3 · 1993 · cited in 1 Pennsylvania opinions naming this issue, 1998–1998
11
Jochynek v. Commonwealthgreen
pacommwct · 1977 · cited in 1 Pennsylvania opinions naming this issue, 1984–1984
11
United States v. Larry C. Smith, Etc., United States of America v. Marshall Carter, Etc.green
ca8 · 1972 · cited in 1 Pennsylvania opinions naming this issue, 1982–1982
11
Rothman v. Rothmangreen
pa · 1967 · cited in 1 Pennsylvania opinions naming this issue, 1974–1974
11
Thistle's Estategreen
pa · 1919 · cited in 1 Pennsylvania opinions naming this issue, 1930–1930
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 (43)

CaseCitedYears
Commonwealth v. Rementer green
pasuperct · 1991
2 sentences

2019Rementer , 598 A.2d at 1305 . *769 As to the first part of the test, the defendant's conduct need not be the only cause of the victim's death in order to establish a causal connection.

2008Rementer, 598 A.2d at 1305 . ¶ 14 As to the first part of the test, the defendant’s conduct need not be the only cause of the victim’s death in order to establish a causal connection.

111993–2025
Guy v. Liederbach green
pa · 1983
2 sentences

2013“The first part of the test sets forth a standing requirement... [which] leaves discretion with the trial court to determine whether recognition of third party beneficiary status would be ‘appropriate.’” Guy, 459 A.2d at 751 .

1993“Consequently, this court in Guy concluded: “There is thus a two part test for determining whether one is an intended third party beneficiary: (1) the recognition of the beneficiary’s right must be ‘appropriate to effectuate the intention of the parties,’ and (2) the performance must ‘satisfy an obligation of the promisee to pay money to the beneficiary’ or ‘the circumstances indicate that the promisee intends to give the beneficiary the benefit of the promised performance.’ “Guy v. Liederbach, 501 Pa. at 60 , 459 A.2d at 751 .The first part of the test sets forth a standing requirement which

31993–2013
Com. v. EM green
pa · 1999
2 sentences

2002We find that he did. ¶ 8 Recently, in Commonwealth v. E.M., 558 Pa. 16 , 735 A.2d 654 (1999), our Supreme Court revisited and summarized the jurisprudence surrounding the “investigatory stop and frisk” as follows: It is well established that a police officer may conduct a brief investigatory stop of an individual if the officer observes unusual conduct which leads him to reasonably conclude, in light of his experience, that criminal activity may be afoot.

1999We find that he did. ¶ 10 Recently, in Commonwealth v. E.M., 558 Pa. 16 , 735 A.2d 654 (1999), our supreme court revisited and summarized the jurisprudence surrounding the “investigatory stop and frisk.” In that case the court stated: It is well established that a police officer may conduct a brief investigatory stop of an individual if the officer observes unusual conduct which leads him to reasonably conclude, in light of his experience, that criminal activity may be afoot.

21999–2002
Commonwealth v. E.M. green
pa · 1999
2 sentences

2002We find that he did. ¶ 8 Recently, in Commonwealth v. E.M., 558 Pa. 16 , 735 A.2d 654 (1999), our Supreme Court revisited and summarized the jurisprudence surrounding the “investigatory stop and frisk” as follows: It is well established that a police officer may conduct a brief investigatory stop of an individual if the officer observes unusual conduct which leads him to reasonably conclude, in light of his experience, that criminal activity may be afoot.

1999We find that he did. ¶ 10 Recently, in Commonwealth v. E.M., 558 Pa. 16 , 735 A.2d 654 (1999), our supreme court revisited and summarized the jurisprudence surrounding the “investigatory stop and frisk.” In that case the court stated: It is well established that a police officer may conduct a brief investigatory stop of an individual if the officer observes unusual conduct which leads him to reasonably conclude, in light of his experience, that criminal activity may be afoot.

21999–2002
Style v. Shaub green
pasuperct · 2008
2 sentences

2026We observed that as to the first part of the test, i.e., whether the child was physically and mentally able to engage in profitable employment, Ms. Style failed to prove that the child was “not able to engage in profitable employment.” Id. at 410 .

2026“With regard to the second part of the test for rebutting the presumption, namely whether employment [wa]s available to the child at a supporting wage,” we found “little or no evidence in this regard.” Id.

12026–2026
New York State Rifle & Pistol Assn., Inc. v. Bruen green
scotus · 2022
1 sentence

2025The government must then justify its regulation by demonstrating that it is consistent with the Nation’s historical tradition of firearm regulation. 597 U.S. at 24 .5 The first part of the test requires the court to determine whether the Second Amendment applies to the legislated conduct, i.e., whether the challenged legislation infringes “the right of the people to keep and bear arms.” This Court has already determined that convicted felons are included in “the people” to whom the Second Amendment’s protections apply.

12025–2025
United States v. Rahimi green
scotus · 2024
1 sentence

2025With respect to the second part of the test, Farmer noted Rahimi stated, inter alia, that “[f]rom the earliest days of the common law, firearm[s] regulations have included provisions barring people from misusing weapons to harm or menace others.” Farmer, 329 A.3d at 454 (quoting Rahimi, 602 U.S. at 693 ).

12025–2025
Commonwealth v. Leaner green
pasuperct · 2019
1 sentence

2024Id. at 769 .

12024–2024
Apprendi v. New Jersey green
scotus · 2000
1 sentence

2020In other words, can the trial court omit any specific finding, special verdict slip, special[] interrogatory, or the like as to these essential elements, and/or direct a finding of this fact as to the grading of the underlying offense as a matter of law, notwithstanding Apprendi’s clear directive that “any fact that increases the penalty for a crime beyond the prescribed maximum penalty must be submitted to a jury, and proved beyond a reasonable doubt.” Apprendi, 530 U.S. at 490 . [Appellant] submits that the answer to this question is “no,” and that his [first-degree felony conviction at Coun

12020–2020
Commonwealth v. Mazeffa, R. green
pa · 2016
1 sentence

2020Criminal responsibility may be properly ____________________________________________ 5 While Kakhankham concerns events occurring after the General Assembly amended the drug delivery resulting in death statute to reduce the mens rea element to a recklessness standard, 132 A.3d at 994-95 , this Court’s holding is nevertheless relevant to our consideration of the foreseeability and causation of death resulting from heroin use. - 13 - J-A30036-19 assessed against an individual whose conduct was a direct and substantial factor in producing the death even though other factors combined with that con

12020–2020
Adoption of: M.A.B., A Minor, Appeal of: Erie OCY green
pasuperct · 2017
1 sentence

2018In re M.A.B., 166 A.3d at 445-46 .

12018–2018
Tincher, T. v. Omega Flex, Inc., Aplt. green
pa · 2014
1 sentence

2018As the Supreme Court noted, "in critical part, the trial court instructed the jury in accordance with the law as articulated in Azzarello and its progeny." Tincher , 104 A.3d at 407 ; see also Trial Court Opinion, 3/22/16, at 3 ("we charged as required by Azzarello ").

12018–2018
Nationwide Mutual Insurance v. Fleming green
pasuperct · 2007
2 sentences

2015If the court determines that the attorney-client privilege does apply, the court must then “engage in the second part of the inquiry: whether an exception or waiver applies, thereby overcoming the privilege and permitting disclosure.” Id., at 1265-1266 .

2015“The first part of the inquiry is whether the attorney-client privilege does indeed apply to a particular communication.” Id.

12015–2015
Bily v. Arthur Young & Co. green
cal · 1992
1 sentence

2013In responding to LandAmerica’s arguments and moving for summary judgment, Hospitality relies on Bily v. Arthur Young & Co., 834 P.2d 745 (Cal. 1992), Robert H.

12013–2013
Commonwealth v. Collins green
pa · 1997
1 sentence

2010Collins , at 55, 703 A.2d at 422 .

12010–2010
Joyner v. Southeastern Pennsylvania Transportation Authority green
pacommwct · 1999
12008–2008
Lewis v. Workers' Compensation Appeal Board green
pa · 2007
12008–2008
Caplan v. Caplan green
pa · 1990
2 sentences

2008Caplan v. Caplan, 400 Pa.Super. 352 , 583 A.2d 823 (1990); see also Milne v. Milne, 383 Pa.Super. 177 , 556 A.2d 854 (1989). ¶ 19 With regard to the first part of the test, namely whether the child is physically and mentally able to engage in profitable employment, the trial court found that “the testimony presented on Dustin’s behalf [was] neither convincing [n]or complete enough to meet the standard of proof [in this case].” Trial Court Opinion, 9/12/07, at 10.

2008Caplan v. Caplan, 400 Pa.Super. 352 , 583 A.2d 823 (1990); see also Milne v. Milne, 383 Pa.Super. 177 , 556 A.2d 854 (1989). ¶ 19 With regard to the first part of the test, namely whether the child is physically and mentally able to engage in profitable employment, the trial court found that “the testimony presented on Dustin’s behalf [was] neither convincing [n]or complete enough to meet the standard of proof [in this case].” Trial Court Opinion, 9/12/07, at 10.

12008–2008
Burger King Corp. v. Rudzewicz green
scotus · 1985
12002–2002
Hertzberg v. Zoning Board of Adjustment green
pa · 1998
12001–2001
Milne v. Crossett green
pa · 1998
12001–2001
United States v. Roland Richard Driver, A/K/A Roland Richard Mousseaux green
ca8 · 1991
12001–2001
Woods v. Commonwealth Department of Transportation red
pa · 1992
12001–2001
Medina v. United States green
scotus · 1992
12001–2001
Simpson v. Missouri green
scotus · 1992
12001–2001
Office of Disciplinary Counsel v. Keller green
pa · 1986
11995–1995
Commonwealth v. Ogontz Area Neighbors Ass'n green
pa · 1984
11993–1993
County of Venango v. Borough of Sugarcreek neutral
pacommwct · 1991
11993–1993
Borough of Tunkhannock v. County of Wyoming green
pacommwct · 1986
11993–1993
Commonwealth v. Skufca green
pa · 1974
11991–1991
Rando v. Estelle green
scotus · 1974
11991–1991
Skufca v. Pennsylvania green
scotus · 1974
11991–1991
Commonwealth v. Kaschik green
pasuperct · 1975
11982–1982
Commonwealth v. Schuck green
pa · 1960
11971–1971
Kistler v. Faller green
pa · 1960
11971–1971
Commonwealth v. Mount green
pa · 1969
11971–1971
Maris's Estate green
pa · 1930
11963–1963
Barium Steel Corp. v. Wiley green
pa · 1954
11959–1959
Betterman v. American Stores Co. green
pa · 1951
11959–1959
Miller's Estate neutral
pa · 1938
11942–1942

Statutes the citing opinions construe

PA § 18 Pa. Cons. Stat. § 2502 (6) PA § 18 Pa. Cons. Stat. § 303 (5)

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 125 (1974–2024) OH 95 (1975–2026) NM 90 (1971–2026) IL 75 (1887–2025) CA 68 (1882–2025) WA 64 (1905–2026) UT 63 (1911–2026) PA 59 (1904–2026) CT 56 (1898–2026) FL 39 (1937–2023) MO 39 (1900–2024) WI 32 (1909–2026) NY 32 (1860–2024) OR 28 (1928–2026) IA 27 (1866–2026) GA 25 (1994–2026) IN 22 (1894–2023) MD 22 (1919–2025) MA 21 (1907–2017) NJ 21 (1980–2024) NC 20 (1986–2026) MI 18 (1897–2025) MT 17 (1937–2022) KS 16 (1893–2026) AZ 16 (1966–2018) CO 16 (1909–2026) DC 13 (1947–2024) ND 13 (1955–2025) WY 11 (1961–2022) ME 11 (1909–2021) SD 11 (1951–2011) TN 10 (1979–2026) AL 10 (1983–2023) NE 10 (1987–2025) VT 10 (1916–2022) VA 10 (1837–2025) KY 10 (1882–2020) RI 10 (1993–2020) OK 10 (1898–2018) MS 9 (1884–2022) ID 9 (1909–2021) HI 8 (2002–2021) NH 8 (2003–2021) AR 8 (1923–2018) LA 7 (1997–2023) MN 6 (1919–2024) WV 6 (1890–2024) SC 5 (1993–2013) NV 5 (1998–2022) DE 3 (2008–2026) VI 2 (2010–2014) AK 2 (1986–2020)

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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