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6 Pennsylvania opinions name it 4 courts 1986–2026 2 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. Blackgreen1 sentence2026On direct appeal, this Court vacated and remanded, instructing the trial court to hold an in-camera hearing and apply the three-prong balancing test outlined in Commonwealth v. Black, 487 A.2d 396, 401 (Pa. Super. 1985), after which the trial court could grant a new trial or reinstate the judgment of sentence. | 1 | 1 |
Commonwealth v. Palmoregreen1 sentence2026See Palmore, supra (“If the proffered evidence is not speculation or conjecture, the trial court must conduct an in[-]camera hearing.”) (emphasis added). - 21 - J-A22011-25 message is relevant and admissible, after which the trial court may grant a new trial or reinstate the judgment of sentence. 19 See Commonwealth v. Ruggiano, 26 A.3d 473, 473 (Pa. 2011) (per curiam). | 1 | 1 |
Commonwealth v. Largaespadagreen1 sentence2026See Largaespada, supra; Commonwealth v. Holder, 815 A.2d 1115 , 1119 n.1 (Pa. Super. 2003) (“[T]he Rape Shield Law may not be used to exclude relevant evidence showing witness[] bias or attacking [a witness’] credibility.”). | 1 | 1 |
Commonwealth v. Ruggianogreen1 sentence2026See Palmore, supra (“If the proffered evidence is not speculation or conjecture, the trial court must conduct an in[-]camera hearing.”) (emphasis added). - 21 - J-A22011-25 message is relevant and admissible, after which the trial court may grant a new trial or reinstate the judgment of sentence. 19 See Commonwealth v. Ruggiano, 26 A.3d 473, 473 (Pa. 2011) (per curiam). | 1 | 1 |
Commonwealth v. Holdergreen1 sentence2026See Largaespada, supra; Commonwealth v. Holder, 815 A.2d 1115 , 1119 n.1 (Pa. Super. 2003) (“[T]he Rape Shield Law may not be used to exclude relevant evidence showing witness[] bias or attacking [a witness’] credibility.”). | 1 | 1 |
Commonwealth v. K.S.F.green2 sentences2026Here, both the trial court and Marchini rely on Commonwealth v. K.S.F., 102 A.3d 480 (Pa. Super. 2014), to support their argument as to why the in-camera hearing was or was not required. 2026Thus, Marchini’s proffer was sufficient on its face and requires an in-camera hearing to determine its admissibility.18 See K.S.F., 102 A.3d at 485 (“The purpose of [an in[- ]camera] hearing required by the Rape Shield Law is to enable a trial court to determine whether tendered defense evidence of the victim’s prior sexual activity is relevant and admissible.”) (quotation marks and citation omitted). | 1 | 1 |
Commonwealth v. Palogreen1 sentence2024See Commonwealth v. Palo, 24 A.3d 1050, 1058 (Pa.Super. 2011) (finding that Palo “cannot reasonably maintain that he lacked a fair opportunity to contest the use of [crimen falsi] evidence in what was a fairly straightforward case, particularly where the record establishes that the trial court conducted an in-camera hearing in which defense counsel gave thorough argument as to why such evidence should be excluded”). -8- J-A11001-22 nature of the charges[.]” N.T. | 1 | 1 |
United States v. Lester Sloman (89-4056), Paul Bauer (89-4057)green1 sentence2011See, e.g., U.S. v. Sloman, 909 F.2d 176, 180 (C.A.6 (Ohio) 1990) (upholding use of stale conviction despite government’s failure to give notice under identical F.R.E. 609 until after witness took stand; written notice not required because counsel was not unfairly surprised). | 1 | 1 |
Crawford v. Dominicgreen1 sentence1986As noted by Judge Pollack in Crawford v. Dominic, 469 F.Supp. 260, 264 (E.D., Pa. — 1979). “. . . [T]he public has the strongest interest in maintaining the confidentiality of [matters] . .' . concerning] an ongoing criminal investigation.” While courts should opt for in-camera hearings only for the most compelling reasons both because of constitutional requirements and to enhance public confidence in the judicial process, Buehl, supra, and Waller v. Georgia, 467 U.S. 39 , 81 L.Ed. 2d 31 , 104 S.Ct. _ (1984), we are convinced that the need to protect ongoing criminal investigations is appropri | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Commonwealth v. Selenski
green
1 sentence2011Pa.R.A.P. 2119; Commonwealth v. Selenski, 18 A.3d 1229 (Pa.Super.2011) In the alternative, we find that Appellant cannot reasonably maintain that he lacked a fair opportunity to contest the use of such evidence in what was a fairly straightforward case, particularly where the record establishes that the trial court conducted an in-camera hearing in which defense counsel gave thorough argument as to why such evidence should be excluded. | 1 | 2011–2011 |
Commonwealth v. Slaughter
green
2 sentences1989The trial court allowed Appellant’s counsel to inspect Rideout’s juvenile record but, following an in-camera hearing, denied his request to interrogate the witness on that record on the theory that the two pending charges against Rideout were only arrests and, citing our decision in Commonwealth v. Slaughter, 482 Pa. 538 , 394 A.2d 453 (1978), determined that the record could only be used as to actual adjudications and not merely arrests. 1989The trial court allowed Appellant’s counsel to inspect Rideout’s juvenile record but, following an in-camera hearing, denied his request to interrogate the witness on that record on the theory that the two pending charges against Rideout were only arrests and, citing our decision in Commonwealth v. Slaughter, 482 Pa. 538 , 394 A.2d 453 (1978), determined that the record could only be used as to actual adjudications and not merely arrests. | 1 | 1989–1989 |
Commonwealth v. Strube
green
2 sentences1989The necessity for such legislation was discussed by our Superior Court in the case of Commonwealth v. Strube, 274 Pa. Super. 199 , 418 A.2d 365 (1979), as follows: “The raison d’etre of 18 Pa.C.S. §3104 and similar rape shield laws in other jurisdictions, is to partially correct the manner in which our criminal justice system has approached the victim of a sexual assault. 1989The necessity for such legislation was discussed by our Superior Court in the case of Commonwealth v. Strube, 274 Pa. Super. 199 , 418 A.2d 365 (1979), as follows: “The raison d’etre of 18 Pa.C.S. §3104 and similar rape shield laws in other jurisdictions, is to partially correct the manner in which our criminal justice system has approached the victim of a sexual assault. | 1 | 1989–1989 |
Commonwealth v. Fenstermaker
green
2 sentences1986While recognizing that a First Amendment right of access to court proceedings is involved in our decision to permit an in camera hearing, see Commonwealth v. Buehl, 316 Pa. Super; 215, 462 A.2d 1316 (1983) and Commonwealth v. Fenstermaker, 348 Pa. Super. 230 , 502 A.2d 181 (1985), the existence of the right under the First Amendment is not per se dispositive. 1986While recognizing that a First Amendment right of access to court proceedings is involved in our decision to permit an in camera hearing, see Commonwealth v. Buehl, 316 Pa. Super; 215, 462 A.2d 1316 (1983) and Commonwealth v. Fenstermaker, 348 Pa. Super. 230 , 502 A.2d 181 (1985), the existence of the right under the First Amendment is not per se dispositive. | 1 | 1986–1986 |
Commonwealth v. Buehl
green
1 sentence1986While recognizing that a First Amendment right of access to court proceedings is involved in our decision to permit an in camera hearing, see Commonwealth v. Buehl, 316 Pa. Super; 215, 462 A.2d 1316 (1983) and Commonwealth v. Fenstermaker, 348 Pa. Super. 230 , 502 A.2d 181 (1985), the existence of the right under the First Amendment is not per se dispositive. | 1 | 1986–1986 |
Waller v. Georgia
green
2 sentences1986As noted by Judge Pollack in Crawford v. Dominic, 469 F.Supp. 260, 264 (E.D., Pa. — 1979). “. . . [T]he public has the strongest interest in maintaining the confidentiality of [matters] . .' . concerning] an ongoing criminal investigation.” While courts should opt for in-camera hearings only for the most compelling reasons both because of constitutional requirements and to enhance public confidence in the judicial process, Buehl, supra, and Waller v. Georgia, 467 U.S. 39 , 81 L.Ed. 2d 31 , 104 S.Ct. _ (1984), we are convinced that the need to protect ongoing criminal investigations is appropri 1986As noted by Judge Pollack in Crawford v. Dominic, 469 F.Supp. 260, 264 (E.D., Pa. — 1979). “. . . [T]he public has the strongest interest in maintaining the confidentiality of [matters] . .' . concerning] an ongoing criminal investigation.” While courts should opt for in-camera hearings only for the most compelling reasons both because of constitutional requirements and to enhance public confidence in the judicial process, Buehl, supra, and Waller v. Georgia, 467 U.S. 39 , 81 L.Ed. 2d 31 , 104 S.Ct. _ (1984), we are convinced that the need to protect ongoing criminal investigations is appropri | 1 | 1986–1986 |
Press-Enterprise Co. v. Superior Court of Cal., Riverside Cty.
green
2 sentences1986Press Enterprise Co. v. Superior Court, 464 U.S. 501 78 L.Ed. 2d 629 , 104 S.Ct. 819 (1984). 1986Press Enterprise Co. v. Superior Court, 464 U.S. 501 78 L.Ed. 2d 629 , 104 S.Ct. 819 (1984). | 1 | 1986–1986 |
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.