third-party doctrine (Pennsylvania) · Go Syfert
← Pennsylvania issues

third-party doctrine in Pennsylvania

48 Pennsylvania opinions name it 12 courts 1975–2025 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 (36)

CaseFollowedCited
Smith v. Marylandred
scotus · 1979 · cited in 8 Pennsylvania opinions naming this issue, 2019–2025
2 sentences

2025A consumer availing himself of the bank’s services necessarily had “take[n] the risk, in revealing his affairs to another, that the information [would] be conveyed by that person to the Government.” 38 33 Id. 34 425 U.S. 435 (1976). 35 442 U.S. 735 (1979). 36 Miller, 425 U.S. at 440 . 37 Id. at 442 . 38 Id. at 443 . [J-36A-2024, J-36B-2024 and J-36C-2024] - 11 The Court returned to the third-party doctrine three years later in Smith.

2025Smith, 442 U.S. at 745 . 72 Thus, the Court concluded, the third-party doctrine did not preclude an expectation of privacy in CSLI records.

48
United States v. Knottsgreen
scotus · 1983 · cited in 5 Pennsylvania opinions naming this issue, 2020–2025
2 sentences

2025This suggested to the Court that Jones had at least facial applicability, as both types of data are “detailed, encyclopedic, and effortlessly compiled.” 62 On the other hand, the Court explained, the third-party doctrine seemed to have little, if any, relevance in regard 58 Id. 59 Id. at 307 (discussing Jones). 60 Smith, 442 U.S. at 745. 61 Carpenter, 585 U.S. at 309 . 62 Id. [J-36A-2024, J-36B-2024 and J-36C-2024] - 16 to the collection of CSLI data.

2025This suggested to the Court that Jones had at least facial applicability, as both types of data are “detailed, encyclopedic, and effortlessly compiled.” 62 On the other hand, the Court explained, the third-party doctrine seemed to have little, if any, relevance in regard 58 Id. 59 Id. at 307 (discussing Jones). 60 Smith, 442 U.S. at 745. 61 Carpenter, 585 U.S. at 309 . 62 Id. [J-36A-2024, J-36B-2024 and J-36C-2024] - 16 to the collection of CSLI data.

45
Carpenter v. United Statesgreen
scotus · 2018 · cited in 11 Pennsylvania opinions naming this issue, 2019–2025
2 sentences

2025This suggested to the Court that Jones had at least facial applicability, as both types of data are “detailed, encyclopedic, and effortlessly compiled.” 62 On the other hand, the Court explained, the third-party doctrine seemed to have little, if any, relevance in regard 58 Id. 59 Id. at 307 (discussing Jones). 60 Smith, 442 U.S. at 745. 61 Carpenter, 585 U.S. at 309 . 62 Id. [J-36A-2024, J-36B-2024 and J-36C-2024] - 16 to the collection of CSLI data.

2025This suggested to the Court that Jones had at least facial applicability, as both types of data are “detailed, encyclopedic, and effortlessly compiled.” 62 On the other hand, the Court explained, the third-party doctrine seemed to have little, if any, relevance in regard 58 Id. 59 Id. at 307 (discussing Jones). 60 Smith, 442 U.S. at 745. 61 Carpenter, 585 U.S. at 309 . 62 Id. [J-36A-2024, J-36B-2024 and J-36C-2024] - 16 to the collection of CSLI data.

311
United States v. Millerred
scotus · 1976 · cited in 8 Pennsylvania opinions naming this issue, 2019–2025
2 sentences

2025A consumer availing himself of the bank’s services necessarily had “take[n] the risk, in revealing his affairs to another, that the information [would] be conveyed by that person to the Government.” 38 33 Id. 34 425 U.S. 435 (1976). 35 442 U.S. 735 (1979). 36 Miller, 425 U.S. at 440 . 37 Id. at 442 . 38 Id. at 443 . [J-36A-2024, J-36B-2024 and J-36C-2024] - 11 The Court returned to the third-party doctrine three years later in Smith.

2025A consumer availing himself of the bank’s services necessarily had “take[n] the risk, in revealing his affairs to another, that the information [would] be conveyed by that person to the Government.” 38 33 Id. 34 425 U.S. 435 (1976). 35 442 U.S. 735 (1979). 36 Miller, 425 U.S. at 440 . 37 Id. at 442 . 38 Id. at 443 . [J-36A-2024, J-36B-2024 and J-36C-2024] - 11 The Court returned to the third-party doctrine three years later in Smith.

38
Commonwealth v. Beaufordgreen
pa · 1984 · cited in 4 Pennsylvania opinions naming this issue, 2025–2025
2 sentences

2025That we chose not to follow the United States Supreme Court’s ruling in one circumstance—bank records—does not mean that we simultaneously and sub silentio eschewed the third-party doctrine in every conceivable circumstance. 101 Id. at 1290. 102 Burrows, 529 P.2d at 596 . 103 Melilli, 555 A.2d at 1258 (quoting Commonwealth v. Beauford, 475 A.2d 783, 790 (Pa. Super. 1984)). 104 Id. [J-36A-2024, J-36B-2024 and J-36C-2024] - 28 limited to “telephone communications,” which, as a matter of state constitutional law, “are regarded as private.” 105 DeJohn and Melilli are distinguishable from the insta

2025That we chose not to follow the United States Supreme Court’s ruling in one circumstance—bank records—does not mean that we simultaneously and sub silentio eschewed the third-party doctrine in every conceivable circumstance. 101 Id. at 1290. 102 Burrows, 529 P.2d at 596 . 103 Melilli, 555 A.2d at 1258 (quoting Commonwealth v. Beauford, 475 A.2d 783, 790 (Pa. Super. 1984)). 104 Id. [J-36A-2024, J-36B-2024 and J-36C-2024] - 28 limited to “telephone communications,” which, as a matter of state constitutional law, “are regarded as private.” 105 DeJohn and Melilli are distinguishable from the insta

24
United States v. Jonesgreen
scotus · 2012 · cited in 4 Pennsylvania opinions naming this issue, 2019–2020
2 sentences

2020Compare United States v. Knotts, 460 U.S. 276 (1983) (finding no expectation of privacy using a beeper to aid in tracking Knotts’ car because a person traveling in an automobile on public streets has no expectation of privacy in his movements from one place to another) with United States v. Jones, 565 U.S. 400, 405 (2012) (finding a search occurred when agents installed a GPS tracking device on Jones’ car and continuously monitored the vehicle’s movements for 28 days). - 14 - J-A09011-19 The second line of cases held that a person does not have a reasonable privacy interest in information he v

2020Compare United States v. Knotts, 460 U.S. 276 (1983) (finding no expectation of privacy using a beeper to aid in tracking Knotts’ car because a person traveling in an automobile on public streets has no expectation of privacy in his movements from one place to another) with United States v. Jones, 565 U.S. 400, 405 (2012) (finding a search occurred when agents installed a GPS tracking device on Jones’ car and continuously monitored the vehicle’s movements for 28 days). - 14 - J-A09011-19 The second line of cases held that a person does not have a reasonable privacy interest in information he v

24
Katz v. United Statesgreen
scotus · 1967 · cited in 2 Pennsylvania opinions naming this issue, 2025–2025
2 sentences

2025To the contrary, for purposes of federal law, the traditional third-party doctrine applies, and, thus, 86 See Katz, 389 U.S. at 361 (Harlan, J., concurring). 87 Smith, 442 U.S. at 743. 88 Id. [J-36A-2024, J-36B-2024 and J-36C-2024] - 25 Kurtz lacked an expectation of privacy in the material he voluntarily shared while using the internet.

2025To the contrary, for purposes of federal law, the traditional third-party doctrine applies, and, thus, 86 See Katz, 389 U.S. at 361 (Harlan, J., concurring). 87 Smith, 442 U.S. at 743. 88 Id. [J-36A-2024, J-36B-2024 and J-36C-2024] - 25 Kurtz lacked an expectation of privacy in the material he voluntarily shared while using the internet.

22
Com. v. Kurtz, J.green
pasuperct · 2023 · cited in 2 Pennsylvania opinions naming this issue, 2025–2025
2 sentences

2025The court explained that, “[b]y typing in his search query and pressing enter, [Kurtz] affirmatively turned over the contents of his search to Google, a third party, and voluntarily 6 Id. at 516, 536 . 7 Id. at 522 . 8 Id. at 520 (citing Commonwealth v. Kane, 210 A.3d 324, 330 (Pa. Super. 2019)). 9 Id. (citing Commonwealth v. Pacheco, 263 A.3d 626 , 636, 636 n.10 (Pa. 2021)). 10 Id. at 521 (collecting cases).

2025The court explained that, “[b]y typing in his search query and pressing enter, [Kurtz] affirmatively turned over the contents of his search to Google, a third party, and voluntarily 6 Id. at 516, 536 . 7 Id. at 522 . 8 Id. at 520 (citing Commonwealth v. Kane, 210 A.3d 324, 330 (Pa. Super. 2019)). 9 Id. (citing Commonwealth v. Pacheco, 263 A.3d 626 , 636, 636 n.10 (Pa. 2021)). 10 Id. at 521 (collecting cases).

22
Commonwealth v. Kanegreen
pasuperct · 2019 · cited in 2 Pennsylvania opinions naming this issue, 2025–2025
2 sentences

2025The court explained that, “[b]y typing in his search query and pressing enter, [Kurtz] affirmatively turned over the contents of his search to Google, a third party, and voluntarily 6 Id. at 516, 536 . 7 Id. at 522 . 8 Id. at 520 (citing Commonwealth v. Kane, 210 A.3d 324, 330 (Pa. Super. 2019)). 9 Id. (citing Commonwealth v. Pacheco, 263 A.3d 626 , 636, 636 n.10 (Pa. 2021)). 10 Id. at 521 (collecting cases).

2025The court explained that, “[b]y typing in his search query and pressing enter, [Kurtz] affirmatively turned over the contents of his search to Google, a third party, and voluntarily 6 Id. at 516, 536 . 7 Id. at 522 . 8 Id. at 520 (citing Commonwealth v. Kane, 210 A.3d 324, 330 (Pa. Super. 2019)). 9 Id. (citing Commonwealth v. Pacheco, 263 A.3d 626 , 636, 636 n.10 (Pa. 2021)). 10 Id. at 521 (collecting cases).

22
Toy v. Metropolitan Life Insurancegreen
pa · 2007 · cited in 2 Pennsylvania opinions naming this issue, 2007–2014
2 sentences

2014Co., 928 A.2d 186, 199 (Pa. 2007). .

2007Co., 928 A.2d 186, 199 (Pa.2007).

22
Schweitzer v. Rockwell Internationalgreen
pasuperct · 1990 · cited in 2 Pennsylvania opinions naming this issue, 2002–2002
2 sentences

2002For example, in Schweitzer v. Rockwell International, 402 Pa.Super. 34 , 586 A.2d 383, 385 (1991), petition for allowance of appeal denied, 529 Pa. 635 , 600 A.2d 954 (1991), the Superior Court reversed a grant of summary judgment for the employer and held that, pursuant to Section 301(c)(1) of the Act, the employee was not required to pursue a remedy against her employer under the Workers' Compensation Act because the sexual harassment was personal in nature and not part of the proper employer/employee relationship.

2002For example, in Schweitzer v. Rockwell International, 402 Pa.Super. 34 , 586 A.2d 383, 385 (1991), petition for allowance of appeal denied, 529 Pa. 635 , 600 A.2d 954 (1991), the Superior Court reversed a grant of summary judgment for the employer and held that, pursuant to Section 301(c)(1) of the Act, the employee was not required to pursue a remedy against her employer under the Workers' Compensation Act because the sexual harassment was personal in nature and not part of the proper employer/employee relationship.

22
Commonwealth v. Duncangreen
pa · 2003 · cited in 3 Pennsylvania opinions naming this issue, 2023–2025
2 sentences

2023Commonwealth v. Duncan, - 10 - J-S10032-22 817 A.2d 455 , 462-63 (Pa. 2003); Commonwealth v. DeJohn, 403 A.2d 1283 , 1290-91 (Pa. 1979).8 The third-party doctrine has also been extended to computer files, electronic messages, and other digital records.

2023Commonwealth v. Duncan, - 10 - J-S10032-22 817 A.2d 455, 462-63 (Pa. 2003); Commonwealth v. DeJohn, 403 A.2d 1283, 1290-91 (Pa. 1979).8 The third-party doctrine has also been extended to computer files, electronic messages, and other digital records.

13
Cowden v. Aetna Casualty & Surety Co.green
pa · 1957 · cited in 2 Pennsylvania opinions naming this issue, 2001–2007
2 sentences

2007See, e.g., Cowden, 134 A.2d at 223 ; D’Ambrosio, 431 A.2d at 966.

2007See, e.g., Cowden, 134 A.2d at 223 ; D'Ambrosio, 431 A.2d at 966.

12
United States v. Alabigreen
nmd · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
1 sentence

2025The Fourth Amendment does not protect the information on cards, such as on Appellant’s EBT card or credit, debit, and gift cards that are “routinely read by private parties at gas stations, restaurants, and grocery stores.” U.S. v. Bah, 794 F.3d 617, 631 (6th Cir. 2015); see also United States v. Turner, 839 F.3d 429, 436 (5th Cir. 2016) (“[S]ociety does not recognize as reasonable an expectation of privacy in the information encoded in a gift card’s magnetic stripe.”); United States v. Briere de L’Isle, 825 F.3d 426, 432 (8th Cir. 2016) (“[T]he purpose of a credit, debit or gift card is to en

11
United States v. Courtland Turnergreen
ca5 · 2016 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
1 sentence

2025The Fourth Amendment does not protect the information on cards, such as on Appellant’s EBT card or credit, debit, and gift cards that are “routinely read by private parties at gas stations, restaurants, and grocery stores.” U.S. v. Bah, 794 F.3d 617, 631 (6th Cir. 2015); see also United States v. Turner, 839 F.3d 429, 436 (5th Cir. 2016) (“[S]ociety does not recognize as reasonable an expectation of privacy in the information encoded in a gift card’s magnetic stripe.”); United States v. Briere de L’Isle, 825 F.3d 426, 432 (8th Cir. 2016) (“[T]he purpose of a credit, debit or gift card is to en

11
United States v. Eric-Arnaud Briere DE L'Islegreen
ca8 · 2016 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
1 sentence

2025The Fourth Amendment does not protect the information on cards, such as on Appellant’s EBT card or credit, debit, and gift cards that are “routinely read by private parties at gas stations, restaurants, and grocery stores.” U.S. v. Bah, 794 F.3d 617, 631 (6th Cir. 2015); see also United States v. Turner, 839 F.3d 429, 436 (5th Cir. 2016) (“[S]ociety does not recognize as reasonable an expectation of privacy in the information encoded in a gift card’s magnetic stripe.”); United States v. Briere de L’Isle, 825 F.3d 426, 432 (8th Cir. 2016) (“[T]he purpose of a credit, debit or gift card is to en

11
United States v. Mamadou Bahgreen
ca6 · 2015 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
1 sentence

2025The Fourth Amendment does not protect the information on cards, such as on Appellant’s EBT card or credit, debit, and gift cards that are “routinely read by private parties at gas stations, restaurants, and grocery stores.” U.S. v. Bah, 794 F.3d 617, 631 (6th Cir. 2015); see also United States v. Turner, 839 F.3d 429, 436 (5th Cir. 2016) (“[S]ociety does not recognize as reasonable an expectation of privacy in the information encoded in a gift card’s magnetic stripe.”); United States v. Briere de L’Isle, 825 F.3d 426, 432 (8th Cir. 2016) (“[T]he purpose of a credit, debit or gift card is to en

11
United States v. Scott Joseph Tradergreen
ca11 · 2020 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
2 sentences

2023See Trader, 981 F.3d at 967-68; Morel, 922 F.3d at 9 . - 15 - J-S10032-22 Even if Appellant did have a constitutionally cognizable privacy interest in his searches of K.M.’s address, we would also find that the Google warrant was supported by probable cause.

2023See Trader, 981 F.3d at 967-68; Morel, 922 F.3d at 9 . - 15 - J-S10032-22 Even if Appellant did have a constitutionally cognizable privacy interest in his searches of K.M.’s address, we would also find that the Google warrant was supported by probable cause.

11
Commonwealth v. DeJohngreen
pa · 1979 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
2 sentences

2023Commonwealth v. Duncan, - 10 - J-S10032-22 817 A.2d 455 , 462-63 (Pa. 2003); Commonwealth v. DeJohn, 403 A.2d 1283 , 1290-91 (Pa. 1979).8 The third-party doctrine has also been extended to computer files, electronic messages, and other digital records.

2023Commonwealth v. Duncan, - 10 - J-S10032-22 817 A.2d 455, 462-63 (Pa. 2003); Commonwealth v. DeJohn, 403 A.2d 1283, 1290-91 (Pa. 1979).8 The third-party doctrine has also been extended to computer files, electronic messages, and other digital records.

11
Commonwealth v. Rushinggreen
pasuperct · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
1 sentence

2021Brief for Appellant at 23 (citing Commonwealth v. Rushing, 71 A.3d 939, 947, 963 (Pa. Super. 2013), rev’d on other grounds, 99 A.3d 416 (Pa. 2014) (holding that under Article I, Section 8, the defendant has a legitimate expectation of privacy that the government would not surreptitiously track his real-time CSLI; thus, police are required to obtain a warrant supported by probable cause to acquire real-time CSLI)).

11
Myers v. Commercial Union Assurance Companiesgreen
pa · 1984 · cited in 1 Pennsylvania opinions naming this issue, 2014–2014
11
Pressley v. Travelers Property Casualty Corp.green
pasuperct · 2003 · cited in 1 Pennsylvania opinions naming this issue, 2010–2010
11
Step-Saver Data Systems, Inc. v. Wyse Technology, the Software Link, Incgreen
ca3 · 1990 · cited in 1 Pennsylvania opinions naming this issue, 2010–2010
11
Unionamerica Ins. Co., Ltd. v. JB JOHNSONgreen
pasuperct · 2002 · cited in 1 Pennsylvania opinions naming this issue, 2010–2010
11
D'AMBROSIO v. Pa. Nat. Mut. Cas. Ins. Co.green
pa · 1981 · cited in 1 Pennsylvania opinions naming this issue, 2007–2007
11
Commonwealth v. Coongreen
pasuperct · 1997 · cited in 1 Pennsylvania opinions naming this issue, 2006–2006
11
Sheehan v. Cincinnati Shaper Co.green
pa · 1989 · cited in 1 Pennsylvania opinions naming this issue, 2005–2005
11
Main Line Health, Inc. v. Pennsylvania Medical Professional Liability Catastrophe Loss Fundgreen
pacommwct · 1999 · cited in 1 Pennsylvania opinions naming this issue, 2004–2004
11
Miller v. Allstate Insurance Co.green
pasuperct · 2000 · cited in 1 Pennsylvania opinions naming this issue, 2004–2004
11
O'NEIL v. Henry's Riverside Marketgreen
pa · 1989 · cited in 1 Pennsylvania opinions naming this issue, 2003–2003
11
Carlson v. Bubashgreen
pasuperct · 1994 · cited in 1 Pennsylvania opinions naming this issue, 2003–2003
11
Dunn v. Westbrookgreen
ark · 1998 · cited in 1 Pennsylvania opinions naming this issue, 2000–2000
11
Nichols v. Kellergreen
calctapp · 1993 · cited in 1 Pennsylvania opinions naming this issue, 2000–2000
11
Daugherty v. Runnergreen
kyctapp · 1978 · cited in 1 Pennsylvania opinions naming this issue, 2000–2000
11
Landis v. Huntgreen
ohioctapp · 1992 · cited in 1 Pennsylvania opinions naming this issue, 2000–2000
11
cluster 315655green
ca3 · 1973 · cited in 1 Pennsylvania opinions naming this issue, 1987–1987
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 (36)

CaseCitedYears
Commonwealth v. Melilli green
pa · 1989
2 sentences

2025That we chose not to follow the United States Supreme Court’s ruling in one circumstance—bank records—does not mean that we simultaneously and sub silentio eschewed the third-party doctrine in every conceivable circumstance. 101 Id. at 1290. 102 Burrows, 529 P.2d at 596 . 103 Melilli, 555 A.2d at 1258 (quoting Commonwealth v. Beauford, 475 A.2d 783, 790 (Pa. Super. 1984)). 104 Id. [J-36A-2024, J-36B-2024 and J-36C-2024] - 28 limited to “telephone communications,” which, as a matter of state constitutional law, “are regarded as private.” 105 DeJohn and Melilli are distinguishable from the insta

2025Not long after DeJohn, this Court, in Commonwealth v. Melilli, 555 A.2d 1254 (Pa. 1989), addressed the second in the duo of the High Court’s third-party doctrine cases, Smith v. Maryland, 442 U.S. 735, 749 (1979), where the High Court held that installation of a pen register—a device used to collect a record of telephone numbers dialed by a particular telephone number—was not a Fourth Amendment search because callers voluntarily convey numerical information to the telephone company and expose that information in the ordinary course of business.

42025–2025
Lochner v. New York red
scotus · 1905
2 sentences

2025REV. 561 (2009) (referring to the third-party doctrine as “the [Lochner v. New York, 198 U.S. 45 (1905)] of search and seizure law”).

2025REV. 561 (2009) (referring to the third-party doctrine as “the [Lochner v. New York, 198 U.S. 45 (1905)] of search and seizure law”).

22025–2025
Burrows v. Superior Court green
cal · 1974
2 sentences

2025That we chose not to follow the United States Supreme Court’s ruling in one circumstance—bank records—does not mean that we simultaneously and sub silentio eschewed the third-party doctrine in every conceivable circumstance. 101 Id. at 1290. 102 Burrows, 529 P.2d at 596 . 103 Melilli, 555 A.2d at 1258 (quoting Commonwealth v. Beauford, 475 A.2d 783, 790 (Pa. Super. 1984)). 104 Id. [J-36A-2024, J-36B-2024 and J-36C-2024] - 28 limited to “telephone communications,” which, as a matter of state constitutional law, “are regarded as private.” 105 DeJohn and Melilli are distinguishable from the insta

2025That we chose not to follow the United States Supreme Court’s ruling in one circumstance—bank records—does not mean that we simultaneously and sub silentio eschewed the third-party doctrine in every conceivable circumstance. 101 Id. at 1290. 102 Burrows, 529 P.2d at 596 . 103 Melilli, 555 A.2d at 1258 (quoting Commonwealth v. Beauford, 475 A.2d 783, 790 (Pa. Super. 1984)). 104 Id. [J-36A-2024, J-36B-2024 and J-36C-2024] - 28 limited to “telephone communications,” which, as a matter of state constitutional law, “are regarded as private.” 105 DeJohn and Melilli are distinguishable from the insta

22025–2025
United States v. New York Telephone Co. green
scotus · 1977
2 sentences

2025Co., 434 U.S. 159 , 161 n.1 (1977). 40 Smith, 442 U.S. at 737. 41 Id. at 742. 42 Id. at 743. 43 Id. 44 Id. at 743-44. [J-36A-2024, J-36B-2024 and J-36C-2024] - 12 First came United States v. Jones, in which the Court, relying upon trespass principles, held that attaching a GPS device to a vehicle and using satellite technology to track the operator’s movements in that vehicle constituted a “search” under the Fourth Amendment. 45 Justice Sotomayor joined the Court’s opinion, but authored a concurring opinion that planted the seeds for what the third-party doctrine has since become.

2025Co., 434 U.S. 159 , 161 n.1 (1977). 40 Smith, 442 U.S. at 737. 41 Id. at 742. 42 Id. at 743. 43 Id. 44 Id. at 743-44. [J-36A-2024, J-36B-2024 and J-36C-2024] - 12 First came United States v. Jones, in which the Court, relying upon trespass principles, held that attaching a GPS device to a vehicle and using satellite technology to track the operator’s movements in that vehicle constituted a “search” under the Fourth Amendment. 45 Justice Sotomayor joined the Court’s opinion, but authored a concurring opinion that planted the seeds for what the third-party doctrine has since become.

22025–2025
Gradwell v. Strausser green
pasuperct · 1992
2 sentences

1995See 42 Pa.C.S.A. § 6301 et seq.; Gradwell, supra, 416 Pa.Super. 118 , 610 A.2d 999 ; Helsel, supra, 359 Pa.Super. 487 , 519 A.2d 456 .

1993The court concluded that a grandparent is a third party and that the “appropriate manner for a third party to challenge child custody is through dependency proceedings, set forth in the Judicial Code.” Id.

21993–1995
Growth Horizons, Inc. v. Workers' Compensation Appeal Board green
pacommwct · 2001
1 sentence

2024In Growth Horizons, Inc., 767 A.2d 619 , our Court considered whether the Board erred when it directed the claimant to pay the employer only a portion of the subrogation lien owed, when the employer’s adjuster initially mistakenly calculated the amount of the lien, on which the claimant relied to settle a third-party claim.

12024–2024
Dittman, B., Aplt. v. UPMC green
pa · 2018
2 sentences

2023Franczyk derives from Dittman the more sweeping proposition that “an employer has a duty to protect and preserve the interests of its employees”—here, an employee’s interests in a third-party claim arising out of a workplace injury.39 36 See Franczyk’s Br. at 13-25. 37 In doing so, Franczyk appears to concede by implication that, if her claim arises from the workplace injury as such, then Defendants are protected by WCA exclusivity. 38 196 A.3d 1036 (Pa. 2018). 39 Franczyk’s Br. at 13.

2023Specifically, Franczyk argues: [T]his Honorable Court specifically held in Dittman that “[c]ommon law duties stated in general terms are framed in such fashion for the very reason that they have broad-scale application.” Dittman, 196 A.3d at 1046 . . . .

12023–2023
United States v. Morel green
ca1 · 2019
2 sentences

2023See Trader, 981 F.3d at 967-68; Morel, 922 F.3d at 9 . - 15 - J-S10032-22 Even if Appellant did have a constitutionally cognizable privacy interest in his searches of K.M.’s address, we would also find that the Google warrant was supported by probable cause.

2023See Trader, 981 F.3d at 967-68; Morel, 922 F.3d at 9 . - 15 - J-S10032-22 Even if Appellant did have a constitutionally cognizable privacy interest in his searches of K.M.’s address, we would also find that the Google warrant was supported by probable cause.

12023–2023
Harmon v. Unemployment Comp. Bd. of Review green
pa · 2019
1 sentence

2023Bd. of Rev., 207 A.3d 292 , 310 n.1 (Pa. 2019) (Wecht, J., concurring) (discussing Bryan Garner’s identification of the usage’s potential French origin in Bryan A. Garner, A DICTIONARY OF MODERN LEGAL USAGE (2d. ed. 1995)). [J-62-2022] - 3 indemnity shall be expressly provided for in a written contract entered into by the party alleged to be liable prior to the date of the occurrence which gave rise to the action.7 Defendants contended that, because Franczyk’s injury occurred in the course of her employment, Section 481 bars her claim notwithstanding Defendants’ failure, if any, to act more di

12023–2023
Moss Rehab v. White green
del · 1997
2 sentences

2022Just as the General Assembly oversees the licensure of drivers, "[t]he General Assembly is best able to address the competing public policy issues that must be reconciled with regard to recognizing a third-party claim for educational malpractice by a driving school" Moss Rehab, supra at 909 . 2.

2022Just as the General Assembly oversees the licensure of drivers, "[t]he General Assembly is best able to address the competing public policy issues that must be reconciled with regard to recognizing a third-party claim for educational malpractice by a driving school" Moss Rehab, supra at 909 . 2.

12022–2022
Commonwealth, Aplt. v. Rushing, R. green
pa · 2014
12021–2021
Terletsky v. Prudential Property & Casualty Insurance green
pasuperct · 1994
12019–2019
Cullen v. PA. PROPERTY AND CAS. INS. GUAR. ASS'N green
pacommwct · 2000
12019–2019
Zappile v. AMEX Assurance Co. green
pasuperct · 2007
12019–2019
Riley v. Cal. United States green
· 2014
12019–2019
Seebold v. Prison Health Services, Inc. green
pa · 2012
12014–2014
Emerich v. Philadelphia Center for Human Development, Inc. green
pa · 1998
12013–2013
Warner v. Continental/CNA Insurance Companies green
pasuperct · 1996
12011–2011
Frey v. Beaver County Tax Claim Bureau neutral
pacommwct · 1996
12011–2011
Gruenberg v. Aetna Insurance green
cal · 1973
12007–2007
Commonwealth v. Smith green
pasuperct · 2002
12006–2006
Berkebile v. Brantly Helicopter Corp. green
pa · 1975
12005–2005
Main Line Health, Inc. v. Pennsylvania Medical Professional Liability Catastrophe Loss Fund neutral
pa · 2001
12004–2004
Main Line Health, Inc. v. Pennsylvania Medical Professional Liability Catastrophe Loss Fund neutral
pa · 2001
12004–2004
Birth Center v. St. Paul Companies, Inc. green
pa · 2001
12004–2004
Bonenberger v. Nationwide Mutual Insurance green
pasuperct · 2002
12004–2004
Birth Center v. St. Paul Companies, Inc. green
pasuperct · 1999
12003–2003
Shearer v. Reed green
pasuperct · 1981
12002–2002
Hickman v. Taylor green
scotus · 1947
11999–1999
Helsel v. Blair County Children & Youth Services green
pa · 1986
11995–1995
MIN. & MISSION. BEN. BD. v. Goldsworthy red
pasuperct · 1978
11992–1992
New Home Federal Savings & Loan Ass'n v. Trunk green
pa · 1984
11992–1992
Zakian v. LILJESTRAND green
pa · 1970
11989–1989
United National Insurance v. M. London, Inc. green
pa · 1985
11989–1989
O'BARTO v. Glossers Stores, Inc. green
pasuperct · 1974
11989–1989
Cleland Simpson Co. v. Workmen's Compensation Appeal Board green
pacommwct · 1975
11975–1975

Statutes the citing opinions construe

USC § 18u.s.c.2703 (8) PA § 42 Pa. Cons. Stat. § 8371 (5) PA § 18 Pa. Cons. Stat. § 5773 (4) PA § 18 Pa. Cons. Stat. § 5743 (3) PA § 42 Pa. Cons. Stat. § 5524 (3) PA § 75 Pa. Cons. Stat. § 1720 (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

NY 269 (1900–2026) CA 232 (1921–2026) TX 175 (1972–2026) IL 137 (1907–2026) MD 68 (1962–2023) FL 59 (1965–2022) LA 53 (1959–2025) NJ 52 (1959–2025) PA 48 (1975–2025) MO 44 (1961–2022) OR 44 (1970–2024) MI 42 (1969–2025) MA 42 (1972–2026) AZ 36 (1957–2025) WA 36 (1928–2026) VA 34 (1946–2025) NM 31 (1968–2020) WI 31 (1942–2025) OH 30 (1983–2026) GA 29 (1917–2025) AL 28 (1915–2014) IA 27 (1961–2024) IN 26 (1979–2020) CO 24 (1973–2025) TN 21 (1975–2026) WV 21 (1986–2017) NE 20 (1919–2024) NC 20 (1977–2024) MT 20 (1943–2019) CT 20 (1990–2026) MN 19 (1933–2026) SC 18 (1984–2022) WY 16 (1985–2026) UT 16 (1976–2026) DE 15 (1968–2025) MS 14 (1963–2025) ND 14 (1973–2022) KY 13 (1978–2023) AR 13 (1919–2014) OK 12 (1955–2024) HI 12 (1972–2026) DC 12 (1983–2021) ME 11 (1982–2023) KS 9 (1980–2025) RI 8 (1997–2023) AK 7 (1979–2024) NV 7 (1950–2015) VT 5 (2000–2026) ID 5 (1936–2015) NH 5 (1974–2010) SD 3 (1958–2015) PR 2 (1964–1986) VI 2 (2017–2026)

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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