lowest evidentiary standard (Pennsylvania) · Go Syfert
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lowest evidentiary standard in Pennsylvania

49 Pennsylvania opinions name it 2 courts 2011–2025 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.

Followed or applied (19)

CaseFollowedCited
Carey v. Pennsylvania Department of Correctionsgreen
pacommwct · 2013 · cited in 15 Pennsylvania opinions naming this issue, 2014–2025
2 sentences

2025Because the so-called misidentification is merely a typographical error, Petitioners’ argument lacks merit. 8 Preponderance of the evidence is “the lowest evidentiary standard, . . . tantamount to a more likely than not inquiry.” Carey v. Pa. Dep’t of Corr., 61 A.3d 367, 374 (Pa. Cmwlth. 2013) (Carey) (quotation omitted). 6 Rothey, 185 A.3d at 464-65 ; Carey v. Pa. Dep’t of Corr., 61 A.3d 367, 372 (Pa. Cmwlth. 2013).

2025“A preponderance of the evidence standard, the lowest evidentiary standard, is tantamount to ‘a more likely than not’ inquiry.” Carey v. Pa. Dep’t of Corr., 61 A.3d 367, 374 (Pa. Cmwlth. 2013). 8 provisions of this act shall not apply.” Section 3101.1 of the RTKL, 65 P.S. § 67.3101.1.

1015
Delaware County v. Schaefer Ex Rel. Philadelphia Inquirergreen
pacommwct · 2012 · cited in 13 Pennsylvania opinions naming this issue, 2014–2025
2 sentences

2025“A preponderance of the evidence standard, the lowest evidentiary standard, is tantamount to a more likely than not inquiry.” Borough of Pottstown v. Suber-Aponte, 202 A.3d 173 , 180 n.11 (Pa. Cmwlth. 2019) (quoting Delaware County v. Schaefer, 45 A.3d 1149, 1156 (Pa. Cmwlth. 2012)).

2021Inquirer, 45 A.3d 1149, 1156 (Pa. Cmwlth. 2012) (“A preponderance of the evidence standard, the lowest evidentiary standard, is tantamount to a more likely than not inquiry.”).

913
West Chester University of PA v. B. Schackner and The Pittsburgh Post-Gazette, and Bravo Group, Inc.green
pacommwct · 2015 · cited in 3 Pennsylvania opinions naming this issue, 2018–2023
2 sentences

2023Chester Univ. of Pa. v. Schackner, 124 A.3d 382, 393 (Pa. Cmwlth. 2015).

2020It is well settled that “[a]n agency may meet its burden through an unsworn attestation or a sworn affidavit.” Schackner, 124 A.3d at 393 .

23
Helwig v. Commonwealth, Department of Transportation, Bureau of Driver Licensinggreen
pacommwct · 2014 · cited in 2 Pennsylvania opinions naming this issue, 2016–2016
2 sentences

2016“A preponderance of the evidence standard, the lowest evidentiary standard, is tantamount to ‘a more likely than not’ inquiry.” Helwig v. Department of Transportation, Bureau of Driver Licensing, 99 A.3d 153, 158 (Pa. Cmwlth. 2014) (quoting Carey v. Department of Corrections, 61 A.3d 367, 374 (Pa. Cmwlth. 2013)).

2016“A preponderance of the evidence standard, the lowest evidentiary standard, is tantamount to ‘a more likely than not’ inquiry.” Helwig v. Department of Transportation, Bureau of Driver Licensing, 99 A.3d 153, 158 (Pa. Cmwlth. 2014) (quoting Carey v. Department of Corrections, 61 A.3d 367, 374 (Pa. Cmwlth. 2013)).

22
Smith Ex Rel. Smith Butz, LLC v. Pennsylvania Department of Environmental Protectiongreen
pacommwct · 2017 · cited in 6 Pennsylvania opinions naming this issue, 2020–2021
2 sentences

2021“The preponderance of the evidence standard, which is ‘the lowest evidentiary standard, is tantamount to a more likely than not inquiry.’” Smith on behalf of Smith Butz, LLC v. Pa. Dep’t of Env’t Prot., 161 A.3d 1049 , 1059 n.10 (Pa. Cmwlth. 2017) (citation omitted).

2021The Department filed a position statement and proffered the attestations of Mr. Kegg, who stated that these records fell under the noncriminal investigation 7 “The preponderance of the evidence standard, which is ‘the lowest evidentiary standard, is tantamount to a more likely than not inquiry.’” Smith on behalf of Smith Butz, LLC v. Pa. Dep’t of Env’t Prot., 161 A.3d 1049 , 1059 n.10 (Pa. Cmwlth. 2017) (citation omitted). 8 Act of June 18, 1998, P.L. 655, 35 P.S. §§ 1331.1-1331.18. 9 exemption.

16
Borough of Pottstown v. S. Suber-Apontegreen
pacommwct · 2019 · cited in 3 Pennsylvania opinions naming this issue, 2021–2025
2 sentences

2025“A preponderance of the evidence standard, the lowest evidentiary standard, is tantamount to a more likely than not inquiry.” Borough of Pottstown v. Suber-Aponte, 202 A.3d 173 , 180 n.11 (Pa. Cmwlth. 2019) (quoting Delaware County v. Schaefer, 45 A.3d 1149, 1156 (Pa. Cmwlth. 2012)).

2021“A preponderance of the evidence standard, the lowest evidentiary standard, is tantamount to a more likely than not inquiry.”7 Borough of Pottstown v. Suber-Aponte, 202 A.3d 173 , 180 n.11 (Pa. Cmwlth. 2019) (quoting Del.

13
Commonwealth v. Assorted Consumer Fireworksgreen
pacommwct · 2011 · cited in 2 Pennsylvania opinions naming this issue, 2011–2019
2 sentences

2019Id. at 1101 n.10 (citing Commonwealth v. Assorted Consumer Fireworks, 16 A.3d 554 , 558 n.10 (Pa. Cmwlth. 2011)).

2011Commonwealth v. Assorted Consumer Fireworks, 16 A.3d 554, n. 10 (Pa.Cmwlth.2011). 11 .

12
Commonwealth v. $6,425.00 Seized from Esquilingreen
pa · 2005 · cited in 2 Pennsylvania opinions naming this issue, 2011–2014
2 sentences

2014Esquilin, 880 A.2d at 529 .

2011See Commonwealth v. $6,425 Seized from Esquilin, 583 Pa. 544, 555 , 880 A.2d 523, 529 (2005). 11 .

12
Pennsylvania State Police v. Office of Open Recordsgreen
pacommwct · 2010 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
1 sentence

2025In addition, “[w]here a record falls within an exemption under Section 708(b) [of the RTKL], it is not a public record as defined by the RTKL and an agency is not required to redact the record.” Castillo v. Pa. State Police, 310 A.3d 831 , 836 (Pa. Cmwlth. 2024) (quoting Pa. State Police v. Off. of Open Recs., 5 A.3d 473, 481 (Pa. Cmwlth. 2010)). 9 “A preponderance of the evidence standard, the lowest evidentiary standard, is tantamount to a more likely than not inquiry.” Del.

11
Office of the Governor v. R.H. Davis, Jr.green
pacommwct · 2015 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
1 sentence

2025See Davis, 122 A.3d at 1191 ; Carey v. Pa. Dep’t of Corr., 61 A.3d 367, 372 (Pa. Cmwlth. 2013).

11
Mitchell v. Office of Open Recordsgreen
pacommwct · 2010 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
1 sentence

2021Twp. of Worcester v. Off. of Open Recs., 129 A.3d 44, 60 (Pa. Cmwlth. 2016); Off. of the Governor v. Scolforo, 65 A.3d 1095, 1103-04 (Pa. Cmwlth. 2013) (en banc); Mitchell v. Off. of Open Recs., 997 A.2d 1262, 1265 (Pa. Cmwlth. 2010). “[A] generic determination or conclusory statements are not sufficient to justify the exemption of public records.” Scolforo, 65 A.3d at 1103 . 9 “A preponderance of the evidence standard, the lowest evidentiary standard, is tantamount to a more likely than not inquiry.” Delaware Cnty. v. Schaefer ex rel.

11
Township of Worcester v. Office of Open Recordsgreen
pacommwct · 2016 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
1 sentence

2021Twp. of Worcester v. Off. of Open Recs., 129 A.3d 44, 60 (Pa. Cmwlth. 2016); Off. of the Governor v. Scolforo, 65 A.3d 1095, 1103-04 (Pa. Cmwlth. 2013) (en banc); Mitchell v. Off. of Open Recs., 997 A.2d 1262, 1265 (Pa. Cmwlth. 2010). “[A] generic determination or conclusory statements are not sufficient to justify the exemption of public records.” Scolforo, 65 A.3d at 1103 . 9 “A preponderance of the evidence standard, the lowest evidentiary standard, is tantamount to a more likely than not inquiry.” Delaware Cnty. v. Schaefer ex rel.

11
Office of the Governor v. Scolforogreen
pacommwct · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
2 sentences

2021Twp. of Worcester v. Off. of Open Recs., 129 A.3d 44, 60 (Pa. Cmwlth. 2016); Off. of the Governor v. Scolforo, 65 A.3d 1095, 1103-04 (Pa. Cmwlth. 2013) (en banc); Mitchell v. Off. of Open Recs., 997 A.2d 1262, 1265 (Pa. Cmwlth. 2010). “[A] generic determination or conclusory statements are not sufficient to justify the exemption of public records.” Scolforo, 65 A.3d at 1103 . 9 “A preponderance of the evidence standard, the lowest evidentiary standard, is tantamount to a more likely than not inquiry.” Delaware Cnty. v. Schaefer ex rel.

2021Twp. of Worcester v. Off. of Open Recs., 129 A.3d 44, 60 (Pa. Cmwlth. 2016); Off. of the Governor v. Scolforo, 65 A.3d 1095, 1103-04 (Pa. Cmwlth. 2013) (en banc); Mitchell v. Off. of Open Recs., 997 A.2d 1262, 1265 (Pa. Cmwlth. 2010). “[A] generic determination or conclusory statements are not sufficient to justify the exemption of public records.” Scolforo, 65 A.3d at 1103 . 9 “A preponderance of the evidence standard, the lowest evidentiary standard, is tantamount to a more likely than not inquiry.” Delaware Cnty. v. Schaefer ex rel.

11
Pennsylvania State Troopers Ass'n v. Scolforogreen
pacommwct · 2011 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
1 sentence

2019As such, the requested record, the employee complaint against the Requester, falls squarely within the exemption described in RTKL Section 708(b)(17)(i), 65 P.S. § 67.708(b)(17)(i), exempting records “relating to a noncriminal investigation, including . . . [c]omplaints submitted to an agency.” As stated, in order to establish an exemption from disclosure under the RTKL, an agency need only satisfy the preponderance of the evidence standard, which is the lowest evidentiary standard and “has been defined as ‘such proof as leads the fact-finder . . . to find that the existence of a contested fac

11
Community Country Day School v. Commonwealthgreen
pacommwct · 1980 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
1 sentence

2019“A preponderance of the evidence standard, the lowest evidentiary standard, is tantamount to a more likely than not inquiry.” Delaware County v. Schaefer ex rel. promulgated pursuant to the Commonwealth Documents Law[,] [Act of July 31, 1968, P.L. 769, as amended, 45 P.S. §§ 1102-1602, 45 Pa.C.S. §§ 501-907,] have no force or effect and may not form the basis of an agency’s action.” Cmty. Country Day Sch. v. Dep’t of Educ., 414 A.2d 428, 431 (Pa. Cmwlth. 1980).

11
Department of Transportation v. Agricultural Lands Condemnation Approval Boardgreen
pacommwct · 2010 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
1 sentence

2019Lands Condemnation Approval Bd., 5 A.3d 821, 827 (Pa. Cmwlth. 2010)).

11
D'ALESSANDRO v. Pennsylvania State Policegreen
pa · 2007 · cited in 1 Pennsylvania opinions naming this issue, 2017–2017
1 sentence

2017As such, our Supreme Court has held that “hearsay evidence may generally be received and considered during an administrative proceeding.” D’Alessandro v. Pennsylvania State Police, 937 A.2d 404, 411-12 (Pa. 2007) (citing A.Y. v. Department of Public Welfare, 641 A.2d 1148, 1150 (Pa. 1994)). 9 (a) General rule.--A copy of a record of governmental action or inaction authenticated as provided in section 6103 (relating to proof of official records) shall be admissible as evidence that the governmental action or inaction disclosed therein was in fact taken or omitted. (b) Existence of facts.--A cop

11
A.Y. v. Commonwealth Department of Public Welfare, Allegheny County Children & Youth Servicesgreen
pa · 1994 · cited in 1 Pennsylvania opinions naming this issue, 2017–2017
1 sentence

2017As such, our Supreme Court has held that “hearsay evidence may generally be received and considered during an administrative proceeding.” D’Alessandro v. Pennsylvania State Police, 937 A.2d 404, 411-12 (Pa. 2007) (citing A.Y. v. Department of Public Welfare, 641 A.2d 1148, 1150 (Pa. 1994)). 9 (a) General rule.--A copy of a record of governmental action or inaction authenticated as provided in section 6103 (relating to proof of official records) shall be admissible as evidence that the governmental action or inaction disclosed therein was in fact taken or omitted. (b) Existence of facts.--A cop

11
Com. v. ARgreen
pasuperct · 2010 · cited in 1 Pennsylvania opinions naming this issue, 2014–2014
1 sentence

2014Commonwealth v. A.R., 990 A.2d 1, 4, n.5 (Pa. Super. 2010); see also Carey v. Pennsylvania Dept. of Corrections, 61 A.3d 367, 374 (Pa. Cmwlth. 2013) - 10 - J-S68009-14 (“A preponderance of the evidence standard, the lowest evidentiary standard, is tantamount to ‘a more likely than not’ inquiry.”).

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 (7)

CaseCitedYears
Jaeger v. Bureau of Workers' Compensation Fee Review Hearing Office green
pacommwct · 2011
2 sentences

2019Id. at 1101 n.10 (citing Commonwealth v. Assorted Consumer Fireworks, 16 A.3d 554 , 558 n.10 (Pa. Cmwlth. 2011)).

2012Jaeger v. Bureau of Workers’ Compensation Fee Review Hearing Office (American Casualty of Reading do CHA), 24 A.3d 1097 (Pa.Cmwlth.2011). 10 With these principles in mind, this Court will address Schaefer’s requests by examining, in context, the plain language of the Personal Harm/Personal Security Exception.

32012–2019
California Borough v. A.G. Rothey green
pacommwct · 2018
1 sentence

2025Because the so-called misidentification is merely a typographical error, Petitioners’ argument lacks merit. 8 Preponderance of the evidence is “the lowest evidentiary standard, . . . tantamount to a more likely than not inquiry.” Carey v. Pa. Dep’t of Corr., 61 A.3d 367, 374 (Pa. Cmwlth. 2013) (Carey) (quotation omitted). 6 Rothey, 185 A.3d at 464-65 ; Carey v. Pa. Dep’t of Corr., 61 A.3d 367, 372 (Pa. Cmwlth. 2013).

12025–2025
PA State Police, Aplt. v. Grove, M. green
pa · 2017
1 sentence

2023Accordingly, the criminal investigation exemption covers prosecutorial materials including “notes of interviews with victims, suspects and witnesses assembled for the specific purpose of investigation.” Grove, 161 A.3d at 893 . 12 “A preponderance of the evidence standard, the lowest evidentiary standard, is tantamount to a more likely than not inquiry.” Delaware County v. Schaefer ex rel.

12023–2023
Sherry v. Radnor Township School District green
pacommwct · 2011
1 sentence

2021Dist., 20 A.3d 515 (Pa. Cmwlth. 2011). 19 “A preponderance of the evidence standard, the lowest evidentiary standard, is tantamount to a more likely than not inquiry.” Delaware County v. Schaefer ex rel.

12021–2021
Pa. State Police v. Slaughter green
pacommwct · 2016
1 sentence

2017This is the lowest evidentiary standard and, as such, “an ALJ must affirm the [PSP]’s determination if the [PSP] presents evidence showing that it is ‘more likely than not’ that the applicant was involuntarily committed pursuant to Section 302 or 303 of the MHPA.” Gorry, 144 A.3d at 217 (citing Slaughter, 138 A.3d at 73 ). 11 In addition, we also note that Section 505 of the Administrative Agency Law provides that “Commonwealth agencies shall not be bound by technical rules of evidence at agency hearings, and all relevant evidence of reasonably probative value may be received.” 2 Pa. C.S. § 50

12017–2017
R. Gorry v. PA State Police green
pacommwct · 2016
1 sentence

2017This is the lowest evidentiary standard and, as such, “an ALJ must affirm the [PSP]’s determination if the [PSP] presents evidence showing that it is ‘more likely than not’ that the applicant was involuntarily committed pursuant to Section 302 or 303 of the MHPA.” Gorry, 144 A.3d at 217 (citing Slaughter, 138 A.3d at 73 ). 11 In addition, we also note that Section 505 of the Administrative Agency Law provides that “Commonwealth agencies shall not be bound by technical rules of evidence at agency hearings, and all relevant evidence of reasonably probative value may be received.” 2 Pa. C.S. § 50

12017–2017
Bowling v. Office of Open Records green
pa · 2013
1 sentence

2016Bowling v. Office of Open Records, 75 A.3d 453 (Pa. 2013).

12016–2016

Statutes the citing opinions construe

PA § 18 Pa. Cons. Stat. § 9102 (9) PA § 18 Pa. Cons. Stat. § 9106 (8) PA § 18 Pa. Cons. Stat. § 4904 (4) PA § 12 Pa. Cons. Stat. § 5302 (3) PA § 75 Pa. Cons. Stat. § 1519 (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.

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