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58 Pennsylvania opinions name it 3 courts 1974–2026 17 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. Edmundsgreen2 sentences2025Compare [] Edmunds, [ 586 A.2d at 899 ]) (“[T]he exclusionary rule in Pennsylvania has consistently served to bolster the twin aims of Article I, Section 8; to-wit, the safeguarding of privacy and the fundamental requirement that warrants shall only be issued upon probable cause.”), with [] Leon, [ 468 U.S. at 916 ] (explaining that the federal exclusionary rule serves solely a deterrent purpose). 2025Compare [] Edmunds, [ 586 A.2d at 899 ]) (“[T]he exclusionary rule in Pennsylvania has consistently served to bolster the twin aims of Article I, Section 8; to-wit, the safeguarding of privacy and the fundamental requirement that warrants shall only be issued upon probable cause.”), with [] Leon, [ 468 U.S. at 916 ] (explaining that the federal exclusionary rule serves solely a deterrent purpose). | 2 | 2 |
Commonwealth v. Mourygreen2 sentences2019Before addressing the merits of Brown’s claim, we must determine whether: (1) the appeal is timely; (2) the issue was preserved; (3) the brief includes a Pa.R.A.P. 2119(f) statement; and (4) the statement raises a “substantial question that the sentence appealed from is not appropriate under the Sentencing Code.” See Commonwealth v. Heaster, 171 A.3d -9- J-S78024-18 268, 271-72 (Pa.Super. 2017) (quoting Commonwealth v. Moury, 992 A.2d 162, 170 (Pa.Super. 2010)), appeal denied, 181 A.3d 1078 (Pa. 2018). 2018“Challenges to the discretionary aspects of sentencing do not entitle an appellant to review as of right.” Commonwealth v. Moury, 992 A.2d 162, 170 (Pa. Super. 2010). | 2 | 2 |
Commonwealth v. Browngreen2 sentences2026Burton, 158 A.3d at 629 (to establish an after-discovered evidence claim under subsection 9543(a)(2)(vi), the petitioner must prove, inter alia, that the exculpatory evidence is not being offered solely to impeach credibility); see also Commonwealth v. Brown, 134 A.3d 1097, 1109 (Pa. Super. 2016) (upholding PCRA court’s rejection of Brown’s claim that he was entitled to an evidentiary hearing regarding after- discovered evidence based on newspaper articles detailing the misconduct of two Philadelphia Police detectives in cases unrelated to Brown’s, where, absent proof that these two officers h 2022In Commonwealth v. Brown, 134 A.3d 1097 (Pa. Super. 2016), this Court rejected Brown’s claim that he deserved an after-discovered-evidence hearing based on two newspaper articles discussing the misconduct of Philadelphia Police Detectives Ronald Dove and James Pitts in unrelated cases. | 1 | 3 |
Commonwealth v. Browngreen2 sentences2019Justice Donohue noted that "Brown's defense did not involve challenging the cause of the victim's death in any respect." Id. at 340. 2019Justice Donohue noted that “Brown’s defense did not involve challenging the cause of the victim’s death in any respect.” Id. at 340 . | 1 | 2 |
In re Adoption of A.C.green1 sentence2026Commonwealth v. Jacoby, 170 A.3d 1065, 1080 (Pa. 2017) (quotation marks and citations omitted).6 Brown’s brief summarizes the evidence against him at his trial, see Appellant’s Brief at 12-17, and then suggests, inter alia, that the Commonwealth adduced nothing that actually connected him to the murders. | 1 | 1 |
Com. v. Moose, C., Jr.green1 sentence2026See Moose, 245 A.3d at 1130 . | 1 | 1 |
Hudson v. Pa. Bd. of Prob. & Parolegreen1 sentence2026Considering the totality of the circumstances, we conclude the court properly found that the possibility of parole was not a term of Brown’s plea ____________________________________________ 4 See 18 Pa.C.S.A. § 1102(b) (“[A] person who has been convicted of murder of the second degree... shall be sentenced to a term of life imprisonment.”); Hudson v. Pennsylvania Board of Probation and Parole, 204 A.3d 392, 399 (Pa. 2019) (The Board lacks statutory authorization “to release on parole an inmate servicing a mandatory life sentence for second-degree murder.”) (citation omitted). 5 Because “a def | 1 | 1 |
Commonwealth v. Starkgreen1 sentence2026Considering the totality of the circumstances, we conclude the court properly found that the possibility of parole was not a term of Brown’s plea ____________________________________________ 4 See 18 Pa.C.S.A. § 1102(b) (“[A] person who has been convicted of murder of the second degree... shall be sentenced to a term of life imprisonment.”); Hudson v. Pennsylvania Board of Probation and Parole, 204 A.3d 392, 399 (Pa. 2019) (The Board lacks statutory authorization “to release on parole an inmate servicing a mandatory life sentence for second-degree murder.”) (citation omitted). 5 Because “a def | 1 | 1 |
Commonwealth v. Adamsgreen1 sentence2026After reviewing the record, we again find the court’s resolution of Brown’s claim, to the extent it delves into a harmless error analysis, ____________________________________________ Commonwealth v. Adams, 39 A.3d 310, 322 (Pa. Super. 2012) (cleaned up). - 16 - J-S05042-26 appropriately demonstrates that he is not entitled to relief: [The court] properly admitted Detective Ortiz’s testimony as evidence to the thoroughness of the police’s investigation rather than relying on the statement to establish the truth of the fact that someone heard gunshots in the area around the time that the murder | 1 | 1 |
Williams v. Madenspachergreen1 sentence2026Burton, 158 A.3d at 629 (to establish an after-discovered evidence claim under subsection 9543(a)(2)(vi), the petitioner must prove, inter alia, that the exculpatory evidence is not being offered solely to impeach credibility); see also Commonwealth v. Brown, 134 A.3d 1097, 1109 (Pa. Super. 2016) (upholding PCRA court’s rejection of Brown’s claim that he was entitled to an evidentiary hearing regarding after- discovered evidence based on newspaper articles detailing the misconduct of two Philadelphia Police detectives in cases unrelated to Brown’s, where, absent proof that these two officers h | 1 | 1 |
Commonwealth v. Johnsongreen2 sentences2025Id. at 184-85 . - 31 - J-S47041-24 immaterial to the constitutional analysis because Edmunds “turned on a determination that, under Article I, Section 8, the exclusionary rule in Pennsylvania serves other values besides deterrence; it also vindicates an individual’s right to privacy.” Id. at 188 . 2025Id. at 184-85 . - 31 - J-S47041-24 immaterial to the constitutional analysis because Edmunds “turned on a determination that, under Article I, Section 8, the exclusionary rule in Pennsylvania serves other values besides deterrence; it also vindicates an individual’s right to privacy.” Id. at 188 . | 1 | 1 |
Gillespie v. Pa. Bd. of Prob. & Parolegreen1 sentence2024See, e.g., Gillespie v. Pa. Bd. of Prob. & Parole, 505 A.2d 403 (Pa. Cmwlth. 1986) (quashing a petition for review filed in this Court less than six months after an inmate’s request for a parole interview, which the Board viewed as an application for parole); Giddings v. Tartler, 567 A.2d 766 (Pa. Cmwlth. 1989) (denying an inmate’s motion for judgment on the pleadings because his underlying petition for review was filed in this Court merely one day after his application to the Board); Marshall v. Jacobs, 575 A.2d 971 (Pa. Cmwlth. 1990) (dismissing a petition for review because an inmate had fi | 1 | 1 |
Com. v. Moore, B.green1 sentence2024See Commonwealth v. Moore, 307 A.3d 95, 100 (Pa.Super. 2023) (finding defendant waived issue when he filed motion to withdraw guilty plea after the court decided post-sentence motions).8 He also did not frame it as a claim of ineffectiveness, as he does now. | 1 | 1 |
Neitzke v. Williamsred1 sentence2023An action is frivolous under Rule 240(j) “if, on its face, it does not set forth a valid cause of action.” McGriff v. Vidovich, 699 A.2d 797, 799 (Pa. Cmwlth. 1997); see also Pa.R.Civ.P. 240(j)(1), Note (“A frivolous action or proceeding has been defined as one that ‘lacks an arguable basis either in law or in fact.’ Neitzke v. Williams, 490 U.S. 319 [] (1989).”). | 1 | 1 |
Commonwealth v. Prietogreen1 sentence2023We note that “in terms of its effect upon a case, a plea of [no-contest] is treated the same as a guilty plea.” Commonwealth v. Prieto, 206 A.3d 529, 533 (Pa. Super. 2019) (citation omitted). - 10 - J-S23022-23 the merits of the issue he would have pursued on appeal to be entitled to relief.” Commonwealth v. Spencer, 892 A.2d 840, 842 (Pa. Super. 2006). | 1 | 1 |
McGriff v. Vidovichgreen1 sentence2023An action is frivolous under Rule 240(j) “if, on its face, it does not set forth a valid cause of action.” McGriff v. Vidovich, 699 A.2d 797, 799 (Pa. Cmwlth. 1997); see also Pa.R.Civ.P. 240(j)(1), Note (“A frivolous action or proceeding has been defined as one that ‘lacks an arguable basis either in law or in fact.’ Neitzke v. Williams, 490 U.S. 319 [] (1989).”). | 1 | 1 |
Commonwealth v. Spencergreen1 sentence2023We note that “in terms of its effect upon a case, a plea of [no-contest] is treated the same as a guilty plea.” Commonwealth v. Prieto, 206 A.3d 529, 533 (Pa. Super. 2019) (citation omitted). - 10 - J-S23022-23 the merits of the issue he would have pursued on appeal to be entitled to relief.” Commonwealth v. Spencer, 892 A.2d 840, 842 (Pa. Super. 2006). | 1 | 1 |
Com. v. Davis, G.green1 sentence2022When asserting a claim of ineffective assistance of counsel, a petitioner must demonstrate: “(1) the underlying claim has arguable merit; (2) counsel had no reasonable strategic basis for his action or inaction; and, (3) but for the errors and omissions of counsel, there is a reasonable probability that the outcome of the proceedings would have been different.” Commonwealth v. Davis, 262 A.3d 589, 595 (Pa. Super. 2021) (citation ____________________________________________ 5 Brown’s brief does not comply with our Rules of Appellate Procedure in that it does not include the required content nor | 1 | 1 |
| Commonwealth v. Tysongreen | 1 | 1 |
| Commonwealth v. Robinsongreen | 1 | 1 |
| Commonwealth v. Currygreen | 1 | 1 |
| Com. v. Martingreen | 1 | 1 |
| Reilly v. Southeastern Pennsylvania Transportation Authoritygreen | 1 | 1 |
| Estelle v. Gamblegreen | 1 | 1 |
| Commonwealth v. Yarrisgreen | 1 | 1 |
| Commonwealth v. Lairdgreen | 1 | 1 |
| Wilkins v. Miller-Stevensgreen | 1 | 1 |
| Lichtman v. Glazergreen | 1 | 1 |
| Commonwealth v. Jonesgreen | 1 | 1 |
| Commonwealth v. Finleygreen | 1 | 1 |
| Commonwealth v. Lawsongreen | 1 | 1 |
| Harris v. Toys\ R\" Us-Penngreen | 1 | 1 |
| Commonwealth v. Ousleygreen | 1 | 1 |
| Eichman v. McKeongreen | 1 | 1 |
| Commonwealth v. Torresgreen | 1 | 1 |
| Commonwealth v. Jordangreen | 1 | 1 |
| Commonwealth v. McClendongreen | 1 | 1 |
| Bailey v. Storlazzigreen | 1 | 1 |
| Commonwealth v. Ladamusgreen | 1 | 1 |
| Commonwealth v. GOODMANgreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Brown v. Illinois
green
2 sentences2025As a matter of pure logic, however, it seems to me that the Brown factors should apply differently in Pennsylvania than in the federal forum, since the circumstances are to be considered “in light of the policy to be served by the exclusionary rule,” Brown, 422 U.S. at 604 , … and [the Pennsylvania Supreme] Court at least previously has maintained that the policies underlying the exclusionary rule are substantially broader under Pennsylvania jurisprudence than under federal Fourth Amendment law. 2025As a matter of pure logic, however, it seems to me that the Brown factors should apply differently in Pennsylvania than in the federal forum, since the circumstances are to be considered “in light of the policy to be served by the exclusionary rule,” Brown, 422 U.S. at 604 , … and [the Pennsylvania Supreme] Court at least previously has maintained that the policies underlying the exclusionary rule are substantially broader under Pennsylvania jurisprudence than under federal Fourth Amendment law. | 3 | 2010–2025 |
United States v. Leon
green
2 sentences2025Compare [] Edmunds, [ 586 A.2d at 899 ]) (“[T]he exclusionary rule in Pennsylvania has consistently served to bolster the twin aims of Article I, Section 8; to-wit, the safeguarding of privacy and the fundamental requirement that warrants shall only be issued upon probable cause.”), with [] Leon, [ 468 U.S. at 916 ] (explaining that the federal exclusionary rule serves solely a deterrent purpose). 2025Compare [] Edmunds, [ 586 A.2d at 899 ]) (“[T]he exclusionary rule in Pennsylvania has consistently served to bolster the twin aims of Article I, Section 8; to-wit, the safeguarding of privacy and the fundamental requirement that warrants shall only be issued upon probable cause.”), with [] Leon, [ 468 U.S. at 916 ] (explaining that the federal exclusionary rule serves solely a deterrent purpose). | 2 | 2010–2025 |
Smith v. Pennsylvania Board of Probation & Parole
green
2 sentences2016In Smith v. Pennsylvania Board of Probation and Parole, 683 A.2d 278 (Pa. 1996), our Supreme Court held that state appellate courts should consider a pro 1 Appellees note that these documents were not submitted to the trial court and thus are not part of the official record transmitted to this Court. 3 se inmate’s appeal from a governmental agency decision to be filed when the appeal is given to prison officials or placed in the prison mailbox. 2015In Smith v. Pennsylvania Board of Probation and Parole, 683 A.2d 278 (Pa. 1996), our Supreme Court held that state appellate courts should consider a pro 1 Appellees note that these documents were not submitted to the trial court and thus are not part of the official record transmitted to this Court. 3 se inmate’s appeal from a governmental agency decision to be filed when the appeal is given to prison officials or placed in the prison mailbox. | 2 | 2015–2016 |
In re Condemnation of Land Along Woodside Road as an Extension of Maplewood Drive in Frankstown
green
2 sentences2008The trial court determined that charter schools are public under Sections 1702-A and 1703-A of the Charter School Law, Act of March 10, 1949, P.L. 30, as amended, added by Section 1 of the Act of June 19, 1997, P.L. 225, 24 P.S. §§ 17-1702-A and 17-1703-A. As for Brown's claim that the condemnation and Gureghian's role as developer in the subsequent sale was not in the public interest, the trial court referred to Appeal of Heim, 151 Pa.Cmwlth. 438 , 617 A.2d 74 (1992), where this Court noted that a taking does not lose its public character merely because there may exist some feature of private 2008The trial court determined that charter schools are public under Sections 1702-A and 1703-A of the Charter School Law, Act of March 10, 1949, P.L. 30, as amended, added by Section 1 of the Act of June 19, 1997, P.L. 225, 24 P.S. §§ 17-1702-A and 17-1703-A. As for Brown's claim that the condemnation and Gureghian's role as developer in the subsequent sale was not in the public interest, the trial court referred to Appeal of Heim, 151 Pa.Cmwlth. 438 , 617 A.2d 74 (1992), where this Court noted that a taking does not lose its public character merely because there may exist some feature of private | 2 | 2008–2008 |
Commonwealth v. Abu-Jamal
green
1 sentence2026As with the petitioner in Abu-Jamal, supra, Brown’s claim is plainly underdeveloped and insufficient. | 1 | 2026–2026 |
Giurintano v. Department of General Services
green
1 sentence2025Requester directs this Court to its decision in Giurintano v. Department of General Services, 20 A.3d 613 (Pa. Cmwlth. 2011) (names of interpreters providing translation services are protected against disclosure as confidential proprietary information). | 1 | 2025–2025 |
Giddings v. Tartler
green
1 sentence2024See, e.g., Gillespie v. Pa. Bd. of Prob. & Parole, 505 A.2d 403 (Pa. Cmwlth. 1986) (quashing a petition for review filed in this Court less than six months after an inmate’s request for a parole interview, which the Board viewed as an application for parole); Giddings v. Tartler, 567 A.2d 766 (Pa. Cmwlth. 1989) (denying an inmate’s motion for judgment on the pleadings because his underlying petition for review was filed in this Court merely one day after his application to the Board); Marshall v. Jacobs, 575 A.2d 971 (Pa. Cmwlth. 1990) (dismissing a petition for review because an inmate had fi | 1 | 2024–2024 |
Marshall v. Jacobs
neutral
1 sentence2024See, e.g., Gillespie v. Pa. Bd. of Prob. & Parole, 505 A.2d 403 (Pa. Cmwlth. 1986) (quashing a petition for review filed in this Court less than six months after an inmate’s request for a parole interview, which the Board viewed as an application for parole); Giddings v. Tartler, 567 A.2d 766 (Pa. Cmwlth. 1989) (denying an inmate’s motion for judgment on the pleadings because his underlying petition for review was filed in this Court merely one day after his application to the Board); Marshall v. Jacobs, 575 A.2d 971 (Pa. Cmwlth. 1990) (dismissing a petition for review because an inmate had fi | 1 | 2024–2024 |
Commonwealth v. Brown
green
1 sentence2024Id. at 206-07 . | 1 | 2024–2024 |
Commonwealth v. Pollard
green
1 sentence2022After review, we conclude these claims are either refuted by Brown’s answers during the plea colloquy, Pollard, supra, or inconsequential when considering the totality of the circumstances surrounding Brown’s plea. | 1 | 2022–2022 |
Commonwealth v. Yeomans
green
1 sentence2022Yeomans, supra. This is especially true, considering the PCRA court’s conclusion that plea and appellate counsel provided credible testimony, but Brown’s PCRA hearing testimony was unworthy of belief. | 1 | 2022–2022 |
Commonwealth v. Young
green
1 sentence2022In Commonwealth v. Young, 695 A.2d 414 (Pa. Super. 1997), the defendant was charged with two counts of indecent assault: Section Pa.C.S.A. 3126(a)(1) (lack of consent- Count 2) and Section 3126(a)(4) (substantially impaired victim-Count 3). | 1 | 2022–2022 |
| Commonwealth v. Turner green | 1 | 2021–2021 |
| Commonwealth v. Olsen green | 1 | 2020–2020 |
| Commonwealth v. Robinson green | 1 | 2019–2019 |
| Commonwealth v. Heggins green | 1 | 2019–2019 |
| Com. of Pa. v. Hanson green | 1 | 2019–2019 |
| Hoever v. Belleis neutral | 1 | 2019–2019 |
| Commonwealth v. Barton green | 1 | 2019–2019 |
| Coulter, J. v. Lindsay, A. green | 1 | 2019–2019 |
| Africa v. Horn green | 1 | 2019–2019 |
| Tindell v. Department of Corrections green | 1 | 2019–2019 |
| Coulter v. Ramsden green | 1 | 2019–2019 |
| Commonwealth v. Paddy green | 1 | 2018–2018 |
| Lesko v. Lehman green | 1 | 2018–2018 |
| Commonwealth v. Mickell green | 1 | 2018–2018 |
| Commonwealth v. D'Amato green | 1 | 2018–2018 |
| Commonwealth v. Mitchell, W., Aplt. green | 1 | 2018–2018 |
| Commonwealth v. Brown green | 1 | 2017–2017 |
| Commonwealth v. Martz green | 1 | 2017–2017 |
| Alleyne v. United States green | 1 | 2016–2016 |
| Murtagh v. County of Berks green | 1 | 2015–2015 |
| Brown v. Progressive Insurance green | 1 | 2013–2013 |
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.