nexus principle in Pennsylvania

6 Pennsylvania opinions name it 4 courts 2000–2023 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.

Followed or applied (5)

Case	Followed	Cited
Commonwealth v. Robinsongreen pa · 2018 · cited in 2 Pennsylvania opinions naming this issue, 2023–2023 2 sentences 2023Compare Commonwealth v. Fears, 250 A.3d 1180 , 1189 (Pa. 2021) (Mundy, J., Opinion in Support of Affirmance (“OISA”)) (“While the law provides that Appellant need not provide a nexus between the newly discovered fact and his conviction, he still must provide a connection between the fact and his underlying claim.”), with id. at 1201 (Wecht, J., Opinion in Support of Reversal) (faulting the OISA for “effectively impos[ing] a heightened nexus requirement by engaging in a merits-based inquiry under the guise of a timeliness analysis”); see also Commonwealth v. Robinson, 204 A.3d 326 (Pa. 2018). 2023Compare Commonwealth v. Fears, 250 A.3d 1180 , 1189 (Pa. 2021) (Mundy, J., Opinion in Support of Affirmance (“OISA”)) (“While the law provides that Appellant need not provide a nexus between the newly discovered fact and his conviction, he still must provide a connection between the fact and his underlying claim.”), with id. at 1201 (Wecht, J., Opinion in Support of Reversal) (faulting the OISA for “effectively impos[ing] a heightened nexus requirement by engaging in a merits-based inquiry under the guise of a timeliness analysis”); see also Commonwealth v. Robinson, 204 A.3d 326 (Pa. 2018).	2	2
Commonwealth v. One 2001 Toyota Camrygreen pacommwct · 2006 · cited in 1 Pennsylvania opinions naming this issue, 2018–2018 1 sentence 2018See, e.g. , Estate of Peetros , 341 Pa. Super. at 563 , 492 A.2d at 9 (holding that a conviction is not required for forfeiture); 7 One 1990 Dodge Ram Van , 751 A.2d at 1236 (requiring a nexus between the unlawful act and the derivative contraband); see also One 2001 Toyota Camry , 894 A.2d at 211 (explaining that the nexus requirement mitigated "the potentially harsh result of permitting the Commonwealth to penalize a citizen by a civil action against his property rather than a criminal action against his person").	1	1
Estate of Peetros v. County Detectives & District Attorney's Officegreen pa · 1985 · cited in 1 Pennsylvania opinions naming this issue, 2018–2018 1 sentence 2018See, e.g. , Estate of Peetros , 341 Pa. Super. at 563 , 492 A.2d at 9 (holding that a conviction is not required for forfeiture); 7 One 1990 Dodge Ram Van , 751 A.2d at 1236 (requiring a nexus between the unlawful act and the derivative contraband); see also One 2001 Toyota Camry , 894 A.2d at 211 (explaining that the nexus requirement mitigated "the potentially harsh result of permitting the Commonwealth to penalize a citizen by a civil action against his property rather than a criminal action against his person").	1	1
Commonwealth v. One 1990 Dodge Ram Vangreen pacommwct · 2000 · cited in 1 Pennsylvania opinions naming this issue, 2018–2018 1 sentence 2018See, e.g. , Estate of Peetros , 341 Pa. Super. at 563 , 492 A.2d at 9 (holding that a conviction is not required for forfeiture); 7 One 1990 Dodge Ram Van , 751 A.2d at 1236 (requiring a nexus between the unlawful act and the derivative contraband); see also One 2001 Toyota Camry , 894 A.2d at 211 (explaining that the nexus requirement mitigated "the potentially harsh result of permitting the Commonwealth to penalize a citizen by a civil action against his property rather than a criminal action against his person").	1	1
Commonwealth v. Walkergreen pa · 1995 · cited in 1 Pennsylvania opinions naming this issue, 2008–2008 2 sentences 2008See for example, Commonwealth v. Walker, 540 Pa. 80 , 656 A.2d 90 (1995) (grave risk of death to another person found when defendant fired shots at victim sleeping on a couch while another person slept on a nearby couch); Commonwealth v. Jones, 539 Pa. 222 , 651 A.2d 1101 (1994) (grave risk of death to another person found when defendant bound, gagged and set on fire two women in the basement of a row home in the City of Philadelphia); Commonwealth v. Wilson, 538 Pa. 485 , 649 A.2d 435 (1994) (grave risk of death to another person found when defendant fired gunshots into a crowded bar, killing 2008See for example, Commonwealth v. Walker, 540 Pa. 80 , 656 A.2d 90 (1995) (grave risk of death to another person found when defendant fired shots at victim sleeping on a couch while another person slept on a nearby couch); Commonwealth v. Jones, 539 Pa. 222 , 651 A.2d 1101 (1994) (grave risk of death to another person found when defendant bound, gagged and set on fire two women in the basement of a row home in the City of Philadelphia); Commonwealth v. Wilson, 538 Pa. 485 , 649 A.2d 435 (1994) (grave risk of death to another person found when defendant fired gunshots into a crowded bar, killing	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway.

Also cited on this issue (16)

Case	Cited	Years
Commonwealth v. Edmunds green pa · 1991 2 sentences 2017Our Supreme Court reviewed that history in Commonwealth v. Edmunds, 526 Pa. 374 , 586 A.2d 887 (1991). 2017Our Supreme Court reviewed that history in Commonwealth v. Edmunds, 526 Pa. 374 , 586 A.2d 887 (1991).	1	2017–2017
Commonwealth v. Kline green pasuperct · 1975 2 sentences 2017Por guidance on the nexus requirement as it relates to home searches, we turn to this Court’s opinions in Commonwealth v. Kline, 234 Pa.Super. 12 , 335 A.2d 361 (1975), and Commonwealth v. Way, 342 Pa.Super. 341 , 492 A.2d 1151 (1985). 2017Por guidance on the nexus requirement as it relates to home searches, we turn to this Court’s opinions in Commonwealth v. Kline, 234 Pa.Super. 12 , 335 A.2d 361 (1975), and Commonwealth v. Way, 342 Pa.Super. 341 , 492 A.2d 1151 (1985).	1	2017–2017
Commonwealth v. Way green pa · 1985 2 sentences 2017Por guidance on the nexus requirement as it relates to home searches, we turn to this Court’s opinions in Commonwealth v. Kline, 234 Pa.Super. 12 , 335 A.2d 361 (1975), and Commonwealth v. Way, 342 Pa.Super. 341 , 492 A.2d 1151 (1985). 2017Por guidance on the nexus requirement as it relates to home searches, we turn to this Court’s opinions in Commonwealth v. Kline, 234 Pa.Super. 12 , 335 A.2d 361 (1975), and Commonwealth v. Way, 342 Pa.Super. 341 , 492 A.2d 1151 (1985).	1	2017–2017
HUTCHISON BY HUTCHISON v. Luddy green pa · 1994 1 sentence 2008See for example, Commonwealth v. Walker, 540 Pa. 80 , 656 A.2d 90 (1995) (grave risk of death to another person found when defendant fired shots at victim sleeping on a couch while another person slept on a nearby couch); Commonwealth v. Jones, 539 Pa. 222 , 651 A.2d 1101 (1994) (grave risk of death to another person found when defendant bound, gagged and set on fire two women in the basement of a row home in the City of Philadelphia); Commonwealth v. Wilson, 538 Pa. 485 , 649 A.2d 435 (1994) (grave risk of death to another person found when defendant fired gunshots into a crowded bar, killing	1	2008–2008
Commonwealth v. Wilson green pa · 1994 1 sentence 2008See for example, Commonwealth v. Walker, 540 Pa. 80 , 656 A.2d 90 (1995) (grave risk of death to another person found when defendant fired shots at victim sleeping on a couch while another person slept on a nearby couch); Commonwealth v. Jones, 539 Pa. 222 , 651 A.2d 1101 (1994) (grave risk of death to another person found when defendant bound, gagged and set on fire two women in the basement of a row home in the City of Philadelphia); Commonwealth v. Wilson, 538 Pa. 485 , 649 A.2d 435 (1994) (grave risk of death to another person found when defendant fired gunshots into a crowded bar, killing	1	2008–2008
Commonwealth v. Watson green pa · 1989 2 sentences 2008See for example, Commonwealth v. Walker, 540 Pa. 80 , 656 A.2d 90 (1995) (grave risk of death to another person found when defendant fired shots at victim sleeping on a couch while another person slept on a nearby couch); Commonwealth v. Jones, 539 Pa. 222 , 651 A.2d 1101 (1994) (grave risk of death to another person found when defendant bound, gagged and set on fire two women in the basement of a row home in the City of Philadelphia); Commonwealth v. Wilson, 538 Pa. 485 , 649 A.2d 435 (1994) (grave risk of death to another person found when defendant fired gunshots into a crowded bar, killing 2008See for example, Commonwealth v. Walker, 540 Pa. 80 , 656 A.2d 90 (1995) (grave risk of death to another person found when defendant fired shots at victim sleeping on a couch while another person slept on a nearby couch); Commonwealth v. Jones, 539 Pa. 222 , 651 A.2d 1101 (1994) (grave risk of death to another person found when defendant bound, gagged and set on fire two women in the basement of a row home in the City of Philadelphia); Commonwealth v. Wilson, 538 Pa. 485 , 649 A.2d 435 (1994) (grave risk of death to another person found when defendant fired gunshots into a crowded bar, killing	1	2008–2008
Commonwealth v. Logan green pa · 1988 2 sentences 2008See for example, Commonwealth v. Walker, 540 Pa. 80 , 656 A.2d 90 (1995) (grave risk of death to another person found when defendant fired shots at victim sleeping on a couch while another person slept on a nearby couch); Commonwealth v. Jones, 539 Pa. 222 , 651 A.2d 1101 (1994) (grave risk of death to another person found when defendant bound, gagged and set on fire two women in the basement of a row home in the City of Philadelphia); Commonwealth v. Wilson, 538 Pa. 485 , 649 A.2d 435 (1994) (grave risk of death to another person found when defendant fired gunshots into a crowded bar, killing 2008See for example, Commonwealth v. Walker, 540 Pa. 80 , 656 A.2d 90 (1995) (grave risk of death to another person found when defendant fired shots at victim sleeping on a couch while another person slept on a nearby couch); Commonwealth v. Jones, 539 Pa. 222 , 651 A.2d 1101 (1994) (grave risk of death to another person found when defendant bound, gagged and set on fire two women in the basement of a row home in the City of Philadelphia); Commonwealth v. Wilson, 538 Pa. 485 , 649 A.2d 435 (1994) (grave risk of death to another person found when defendant fired gunshots into a crowded bar, killing	1	2008–2008
Commonwealth v. Williams green pa · 1992 2 sentences 2008See for example, Commonwealth v. Walker, 540 Pa. 80 , 656 A.2d 90 (1995) (grave risk of death to another person found when defendant fired shots at victim sleeping on a couch while another person slept on a nearby couch); Commonwealth v. Jones, 539 Pa. 222 , 651 A.2d 1101 (1994) (grave risk of death to another person found when defendant bound, gagged and set on fire two women in the basement of a row home in the City of Philadelphia); Commonwealth v. Wilson, 538 Pa. 485 , 649 A.2d 435 (1994) (grave risk of death to another person found when defendant fired gunshots into a crowded bar, killing 2008See for example, Commonwealth v. Walker, 540 Pa. 80 , 656 A.2d 90 (1995) (grave risk of death to another person found when defendant fired shots at victim sleeping on a couch while another person slept on a nearby couch); Commonwealth v. Jones, 539 Pa. 222 , 651 A.2d 1101 (1994) (grave risk of death to another person found when defendant bound, gagged and set on fire two women in the basement of a row home in the City of Philadelphia); Commonwealth v. Wilson, 538 Pa. 485 , 649 A.2d 435 (1994) (grave risk of death to another person found when defendant fired gunshots into a crowded bar, killing	1	2008–2008
Commonwealth v. Bolden green pa · 2000 2 sentences 2008The Supreme Court applied the nexus principle from Paolello five years later in Commonwealth v. Bolden, 562 Pa. 94 , 753 A.2d 793 (2000), when it again reversed the trial court’s application of the (d)(7) aggravator. 2008The Supreme Court applied the nexus principle from Paolello five years later in Commonwealth v. Bolden, 562 Pa. 94 , 753 A.2d 793 (2000), when it again reversed the trial court’s application of the (d)(7) aggravator.	1	2008–2008
Commonwealth v. Moore green pa · 1993 2 sentences 2008See for example, Commonwealth v. Walker, 540 Pa. 80 , 656 A.2d 90 (1995) (grave risk of death to another person found when defendant fired shots at victim sleeping on a couch while another person slept on a nearby couch); Commonwealth v. Jones, 539 Pa. 222 , 651 A.2d 1101 (1994) (grave risk of death to another person found when defendant bound, gagged and set on fire two women in the basement of a row home in the City of Philadelphia); Commonwealth v. Wilson, 538 Pa. 485 , 649 A.2d 435 (1994) (grave risk of death to another person found when defendant fired gunshots into a crowded bar, killing 2008See for example, Commonwealth v. Walker, 540 Pa. 80 , 656 A.2d 90 (1995) (grave risk of death to another person found when defendant fired shots at victim sleeping on a couch while another person slept on a nearby couch); Commonwealth v. Jones, 539 Pa. 222 , 651 A.2d 1101 (1994) (grave risk of death to another person found when defendant bound, gagged and set on fire two women in the basement of a row home in the City of Philadelphia); Commonwealth v. Wilson, 538 Pa. 485 , 649 A.2d 435 (1994) (grave risk of death to another person found when defendant fired gunshots into a crowded bar, killing	1	2008–2008
Commonwealth v. Meadows green pa · 1993 2 sentences 2008See for example, Commonwealth v. Walker, 540 Pa. 80 , 656 A.2d 90 (1995) (grave risk of death to another person found when defendant fired shots at victim sleeping on a couch while another person slept on a nearby couch); Commonwealth v. Jones, 539 Pa. 222 , 651 A.2d 1101 (1994) (grave risk of death to another person found when defendant bound, gagged and set on fire two women in the basement of a row home in the City of Philadelphia); Commonwealth v. Wilson, 538 Pa. 485 , 649 A.2d 435 (1994) (grave risk of death to another person found when defendant fired gunshots into a crowded bar, killing 2008See for example, Commonwealth v. Walker, 540 Pa. 80 , 656 A.2d 90 (1995) (grave risk of death to another person found when defendant fired shots at victim sleeping on a couch while another person slept on a nearby couch); Commonwealth v. Jones, 539 Pa. 222 , 651 A.2d 1101 (1994) (grave risk of death to another person found when defendant bound, gagged and set on fire two women in the basement of a row home in the City of Philadelphia); Commonwealth v. Wilson, 538 Pa. 485 , 649 A.2d 435 (1994) (grave risk of death to another person found when defendant fired gunshots into a crowded bar, killing	1	2008–2008
Commonwealth v. Lambert green pa · 1992 2 sentences 2008See for example, Commonwealth v. Walker, 540 Pa. 80 , 656 A.2d 90 (1995) (grave risk of death to another person found when defendant fired shots at victim sleeping on a couch while another person slept on a nearby couch); Commonwealth v. Jones, 539 Pa. 222 , 651 A.2d 1101 (1994) (grave risk of death to another person found when defendant bound, gagged and set on fire two women in the basement of a row home in the City of Philadelphia); Commonwealth v. Wilson, 538 Pa. 485 , 649 A.2d 435 (1994) (grave risk of death to another person found when defendant fired gunshots into a crowded bar, killing 2008See for example, Commonwealth v. Walker, 540 Pa. 80 , 656 A.2d 90 (1995) (grave risk of death to another person found when defendant fired shots at victim sleeping on a couch while another person slept on a nearby couch); Commonwealth v. Jones, 539 Pa. 222 , 651 A.2d 1101 (1994) (grave risk of death to another person found when defendant bound, gagged and set on fire two women in the basement of a row home in the City of Philadelphia); Commonwealth v. Wilson, 538 Pa. 485 , 649 A.2d 435 (1994) (grave risk of death to another person found when defendant fired gunshots into a crowded bar, killing	1	2008–2008
Commonwealth v. Mitchell green pa · 1991 2 sentences 2008In Commonwealth v. Mitchell, 528 Pa. 546 , 599 A.2d 624 (1991), the defendant was convicted of the murder of a counselor at the Children’s Home of York. 2008In Commonwealth v. Mitchell, 528 Pa. 546 , 599 A.2d 624 (1991), the defendant was convicted of the murder of a counselor at the Children’s Home of York.	1	2008–2008
Commonwealth v. Jones green pa · 1994 2 sentences 2008See for example, Commonwealth v. Walker, 540 Pa. 80 , 656 A.2d 90 (1995) (grave risk of death to another person found when defendant fired shots at victim sleeping on a couch while another person slept on a nearby couch); Commonwealth v. Jones, 539 Pa. 222 , 651 A.2d 1101 (1994) (grave risk of death to another person found when defendant bound, gagged and set on fire two women in the basement of a row home in the City of Philadelphia); Commonwealth v. Wilson, 538 Pa. 485 , 649 A.2d 435 (1994) (grave risk of death to another person found when defendant fired gunshots into a crowded bar, killing 2008See for example, Commonwealth v. Walker, 540 Pa. 80 , 656 A.2d 90 (1995) (grave risk of death to another person found when defendant fired shots at victim sleeping on a couch while another person slept on a nearby couch); Commonwealth v. Jones, 539 Pa. 222 , 651 A.2d 1101 (1994) (grave risk of death to another person found when defendant bound, gagged and set on fire two women in the basement of a row home in the City of Philadelphia); Commonwealth v. Wilson, 538 Pa. 485 , 649 A.2d 435 (1994) (grave risk of death to another person found when defendant fired gunshots into a crowded bar, killing	1	2008–2008
Commonwealth v. Griffin green pa · 1986 2 sentences 2008See for example, Commonwealth v. Walker, 540 Pa. 80 , 656 A.2d 90 (1995) (grave risk of death to another person found when defendant fired shots at victim sleeping on a couch while another person slept on a nearby couch); Commonwealth v. Jones, 539 Pa. 222 , 651 A.2d 1101 (1994) (grave risk of death to another person found when defendant bound, gagged and set on fire two women in the basement of a row home in the City of Philadelphia); Commonwealth v. Wilson, 538 Pa. 485 , 649 A.2d 435 (1994) (grave risk of death to another person found when defendant fired gunshots into a crowded bar, killing 2008See for example, Commonwealth v. Walker, 540 Pa. 80 , 656 A.2d 90 (1995) (grave risk of death to another person found when defendant fired shots at victim sleeping on a couch while another person slept on a nearby couch); Commonwealth v. Jones, 539 Pa. 222 , 651 A.2d 1101 (1994) (grave risk of death to another person found when defendant bound, gagged and set on fire two women in the basement of a row home in the City of Philadelphia); Commonwealth v. Wilson, 538 Pa. 485 , 649 A.2d 435 (1994) (grave risk of death to another person found when defendant fired gunshots into a crowded bar, killing	1	2008–2008
Quill Corp. v. North Dakota Ex Rel. Heitkamp red scotus · 1992 2 sentences 2000Quill, 504 U.S. 298 , 112 S.Ct. 1904 , 119 L.Ed.2d 91 . 2000Quill, 504 U.S. 298 , 112 S.Ct. 1904 , 119 L.Ed.2d 91 .	1	2000–2000

Where else courts name it

WA 74 (1986–2025) TX 66 (1978–2026) IL 32 (1981–2024) CA 27 (1974–2025) FL 26 (1988–2024) NY 21 (1984–2026) NJ 20 (1970–2024) MT 18 (2008–2020) OR 14 (2002–2025) IA 14 (1986–2023) IN 13 (1994–2020) CO 13 (1997–2024) MD 12 (1998–2021) MN 10 (1986–2024) WI 10 (1963–2003) NM 9 (1986–2024) MA 9 (2009–2025) KS 8 (1996–2016) MI 8 (1980–2025) LA 8 (1989–2026) VA 7 (1994–2013) PA 6 (2000–2023) TN 6 (1999–2026) AZ 6 (2004–2024) GA 6 (2016–2025) WY 5 (1984–2006) DE 5 (1987–2026) OH 5 (1995–2025) OK 5 (2011–2026) UT 4 (1989–2006) WV 4 (2007–2026) KY 4 (2000–2024) AL 3 (1992–2013) VT 3 (1980–2004) NH 2 (1977–2003) MO 2 (1983–1987) RI 2 (1993–2007) DC 2 (1996–2000) HI 2 (1998–2012) MS 2 (1992–1995) SC 2 (2011–2013) NE 2 (1980–2024) ID 2 (1988–1996) NC 2 (2022–2022) CT 2 (1988–2008)

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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