exception to sovereign immunity (Pennsylvania) · Go Syfert
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exception to sovereign immunity in Pennsylvania

45 Pennsylvania opinions name it 8 courts 1985–2026 8 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 (16)

CaseFollowedCited
Snyder v. Harmongreen
pa · 1989 · cited in 8 Pennsylvania opinions naming this issue, 1990–2021
2 sentences

2021See, e.g., Cagey, 179 A.3d at 464 (“We begin with the first requirement that their injuries resulted from a ‘dangerous condition.’”); Dean, 751 A.2d at 1132 (“[W]e must first examine the exception to sovereign immunity which Appellee contends her claims falls under.”); Snyder, 562 A.2d at 311 (“In order to ascertain that duty, it is necessary to first examine Section 8522(b)(4).”). 9 Cagey, 179 A.3d at 463 ; Maj.

1997They note that the Supreme Court in Snyder stated that the language in Section 8522(b)(4), 42 Pa.C.S. § 8522(b)(4), governing the exception to sovereign immunity for a dangerous condition of Commonwealth agency real estate and sidewalks, indicated that the dangerous condition must “derive, originate from or have as its source the Commonwealth realty.” Snyder, 522 Pa. at 433 , 562 A.2d at 311 .

28
Commonwealth v. Robertsongreen
pa · 2013 · cited in 3 Pennsylvania opinions naming this issue, 2013–2021
2 sentences

2021See also id. at 755 (“In other words … the exception to sovereign immunity pertaining to Board–of–Claims jurisdiction defines the extent of the Commonwealth's statutory exception from sovereign immunity for claims arising from contract.”).

2016This matter is undoubtedly premised upon two agreements between Petitioner and the Commission, and our Supreme Court has made clear that “the exception to sovereign immunity pertaining to Board-of-Claims jurisdiction defines the extent of the Commonwealth’s statutory exception from sovereign immunity for claims arising from contract.” Scientific Games International, Inc. v. Commonwealth, 66 A.3d 740 , 755 (Pa. 2005); see also Employers Insurance of Wausau v. Department of Transportation, 865 A.2d 825, 831-34 (Pa. 2005); Armenti v. Pennsylvania State System of Higher Education, 100 A.3d 772, 77

23
Williams v. Stickmangreen
pacommwct · 2007 · cited in 2 Pennsylvania opinions naming this issue, 2016–2023
2 sentences

2023Williams v. Stickman, 917 A.2d 915, 918 (Pa. Cmwlth. 2007).

2016Williams, 917 A.2d at 917 ; La Frankie v. Miklich, 618 A.2d 1145, 1149 (Pa. Cmwlth. 1992) (en banc); see also Roman v. Swartz, (Pa. Cmwlth., No. 1243 C.D. 2012, filed May 15, 2013), slip op. at 4-5, 2013 WL 3982813 at *2-*3.

12
Gielarowski v. Port Authoritygreen
pacommwct · 1993 · cited in 2 Pennsylvania opinions naming this issue, 1995–2003
2 sentences

2003“We conclude that under the case law cited above, the accident which occurred here must fall within an exception to sovereign immunity in order for Gielarowski to recover.” Dunham, supra at 274 , quoting Gielarowski, supra at 218 , 632 A.2d at 1056-57 .

1995Gielarowski, 632 A.2d at 1056-57 (footnotes omitted).

12
Cagey, J., Aplt. v. PennDOTgreen
pa · 2018 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
2 sentences

2021See, e.g., Cagey, 179 A.3d at 464 (“We begin with the first requirement that their injuries resulted from a ‘dangerous condition.’”); Dean, 751 A.2d at 1132 (“[W]e must first examine the exception to sovereign immunity which Appellee contends her claims falls under.”); Snyder, 562 A.2d at 311 (“In order to ascertain that duty, it is necessary to first examine Section 8522(b)(4).”). 9 Cagey, 179 A.3d at 463 ; Maj.

2021See, e.g., Cagey, 179 A.3d at 464 (“We begin with the first requirement that their injuries resulted from a ‘dangerous condition.’”); Dean, 751 A.2d at 1132 (“[W]e must first examine the exception to sovereign immunity which Appellee contends her claims falls under.”); Snyder, 562 A.2d at 311 (“In order to ascertain that duty, it is necessary to first examine Section 8522(b)(4).”). 9 Cagey, 179 A.3d at 463 ; Maj.

11
Dean v. Com., Dept. of Transp.green
pa · 2000 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
1 sentence

2021See, e.g., Cagey, 179 A.3d at 464 (“We begin with the first requirement that their injuries resulted from a ‘dangerous condition.’”); Dean, 751 A.2d at 1132 (“[W]e must first examine the exception to sovereign immunity which Appellee contends her claims falls under.”); Snyder, 562 A.2d at 311 (“In order to ascertain that duty, it is necessary to first examine Section 8522(b)(4).”). 9 Cagey, 179 A.3d at 463 ; Maj.

11
Central Transport, LLC v. Atlas Towing, Inc.green
paed · 2012 · cited in 1 Pennsylvania opinions naming this issue, 2020–2020
1 sentence

2020Central Transport, LLC v. Atlas Towing, Inc., 884 F. Supp. 2d 207, 218-19 (E.D.

11
Meier v. Maleskigreen
pacommwct · 1994 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
1 sentence

2019Accepting the allegations in the complaint as true, as this Court must, see Meier v. Maleski, 648 A.2d 595, 600 (Pa. Cmwlth. 1994), Garcia has pled a prima facie cause of action for medical malpractice on a substantive level, and his claim falls within the exception to sovereign immunity in section 8522(b)(2) of the Judicial Code, 42 Pa.C.S. §8522(b)(2).2 No one, not even the Majority or the trial court, disputes (or has disputed) these conclusions and, in his appellate brief, Steinhart merely claims that Garcia did not plead his claim with sufficient specificity.

11
Evans v. Southeastern Pennsylvania Transportation Authoritygreen
pacommwct · 1992 · cited in 1 Pennsylvania opinions naming this issue, 2018–2018
1 sentence

2018Auth., 613 A.2d 137, 138 (Pa. Cmwlth. 1992) (“A plaintiff seeking to impose liability on a Commonwealth party, such as SEPTA, must establish that a common-law or statutory cause of action exists as a result of a negligent act of the Commonwealth party and that the Commonwealth party’s negligent act falls within an exception to sovereign immunity.”) Adams’s complaint fails to assert a claim that SEPTA was liable for failing to protect against the acts of a third party.

11
Employers Ins. v. Com., Dept. of Transp.green
pa · 2005 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
2 sentences

2016This matter is undoubtedly premised upon two agreements between Petitioner and the Commission, and our Supreme Court has made clear that “the exception to sovereign immunity pertaining to Board-of-Claims jurisdiction defines the extent of the Commonwealth’s statutory exception from sovereign immunity for claims arising from contract.” Scientific Games International, Inc. v. Commonwealth, 66 A.3d 740 , 755 (Pa. 2005); see also Employers Insurance of Wausau v. Department of Transportation, 865 A.2d 825, 831-34 (Pa. 2005); Armenti v. Pennsylvania State System of Higher Education, 100 A.3d 772, 77

2016This matter is undoubtedly premised upon two agreements between Petitioner and the Commission, and our Supreme Court has made clear that “the exception to sovereign immunity pertaining to Board-of-Claims jurisdiction defines the extent of the Commonwealth’s statutory exception from sovereign immunity for claims arising from contract.” Scientific Games International, Inc. v. Commonwealth, 620 Pa. 175 , 66 A.3d 740, 755 (2013); see also Employers Insurance of Wausau v. Department of Transportation, 581 Pa. 381 , 865 A.2d 825, 831-34 (2005); Armenti v. Pennsylvania State System of Higher Educatio

11
La Frankie v. Miklichgreen
pacommwct · 1992 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
1 sentence

2016Williams, 917 A.2d at 917 ; La Frankie v. Miklich, 618 A.2d 1145, 1149 (Pa. Cmwlth. 1992) (en banc); see also Roman v. Swartz, (Pa. Cmwlth., No. 1243 C.D. 2012, filed May 15, 2013), slip op. at 4-5, 2013 WL 3982813 at *2-*3.

11
Dubaskas v. Commonwealthgreen
pacommwct · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
2 sentences

2016This matter is undoubtedly premised upon two agreements between Petitioner and the Commission, and our Supreme Court has made clear that “the exception to sovereign immunity pertaining to Board-of-Claims jurisdiction defines the extent of the Commonwealth’s statutory exception from sovereign immunity for claims arising from contract.” Scientific Games International, Inc. v. Commonwealth, 66 A.3d 740 , 755 (Pa. 2005); see also Employers Insurance of Wausau v. Department of Transportation, 865 A.2d 825, 831-34 (Pa. 2005); Armenti v. Pennsylvania State System of Higher Education, 100 A.3d 772, 77

2016This matter is undoubtedly premised upon two agreements between Petitioner and the Commission, and our Supreme Court has made clear that “the exception to sovereign immunity pertaining to Board-of-Claims jurisdiction defines the extent of the Commonwealth’s statutory exception from sovereign immunity for claims arising from contract.” Scientific Games International, Inc. v. Commonwealth, 620 Pa. 175 , 66 A.3d 740, 755 (2013); see also Employers Insurance of Wausau v. Department of Transportation, 581 Pa. 381 , 865 A.2d 825, 831-34 (2005); Armenti v. Pennsylvania State System of Higher Educatio

11
Armenti v. Pennsylvania State System of Higher Educationgreen
pacommwct · 2014 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
2 sentences

2016This matter is undoubtedly premised upon two agreements between Petitioner and the Commission, and our Supreme Court has made clear that “the exception to sovereign immunity pertaining to Board-of-Claims jurisdiction defines the extent of the Commonwealth’s statutory exception from sovereign immunity for claims arising from contract.” Scientific Games International, Inc. v. Commonwealth, 66 A.3d 740 , 755 (Pa. 2005); see also Employers Insurance of Wausau v. Department of Transportation, 865 A.2d 825, 831-34 (Pa. 2005); Armenti v. Pennsylvania State System of Higher Education, 100 A.3d 772, 77

2016This matter is undoubtedly premised upon two agreements between Petitioner and the Commission, and our Supreme Court has made clear that “the exception to sovereign immunity pertaining to Board-of-Claims jurisdiction defines the extent of the Commonwealth’s statutory exception from sovereign immunity for claims arising from contract.” Scientific Games International, Inc. v. Commonwealth, 620 Pa. 175 , 66 A.3d 740, 755 (2013); see also Employers Insurance of Wausau v. Department of Transportation, 581 Pa. 381 , 865 A.2d 825, 831-34 (2005); Armenti v. Pennsylvania State System of Higher Educatio

11
Long v. Thomasgreen
pacommwct · 1992 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
1 sentence

2015Long v. Thomas, 619 A.2d 394, 396 (Pa. Cmwlth. 1992), appeal denied, 631 A.2d 1012 (Pa. 1993).

11
Ling v. Commonwealth, Department of Transportationgreen
pacommwct · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2014–2014
1 sentence

2014See Ling v. Department of Transportation, 79 A.3d 1, 5 (Pa.Cmwlth.2013) (“Given our holding that the Driveway Immunity Provision specifically confers DOT with statutory immunity, we need not determine whether an exception to sovereign immunity is applicable.... [I]t would be anomalous for our legislature to grant immunity in one statute and simultaneously abrogate that immunity in another statute.”).

11
Fawber v. Cohengreen
pa · 1987 · cited in 1 Pennsylvania opinions naming this issue, 2013–2013
2 sentences

2013See Fawber, 516 Pa. at 359-60 , 532 A.2d at 433-34 .

2013See Fawber, 516 Pa. at 359-60 , 532 A.2d at 433-34 .

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 (34)

CaseCitedYears
Commonwealth v. Johnson green
pa · 2014
2 sentences

2024First, we determined that under the common law at the time of the UTPCPL’s adoption, sovereign immunity would have generally applied to suits that involved depriving the Commonwealth of property, and that it was unlikely that the General [J-50A-2023 and J-50B-2023] - 37 Assembly intended to make an exception to sovereign immunity through language as general and vague as “other legal entities.” Id.

2024First, we determined that under the common law at the time of the UTPCPL’s adoption, sovereign immunity would have generally applied to suits that involved depriving the Commonwealth of property, and that it was unlikely that the General [J-50A-2023 and J-50B-2023] - 37 Assembly intended to make an exception to sovereign immunity through language as general and vague as “other legal entities.” Id.

22024–2024
Love v. City of Philadelphia red
pa · 1988
2 sentences

2010Id.

1993In *219 Love v. City of Philadelphia, 518 Pa. 370 , 543 A.2d 531 (1988), our Supreme Court held that, where a woman was injured while alighting from local agency's van, the case did not fall under the vehicle liability exception of 42 Pa.C.S. § 8542(b)(1) because the injury did not occur during the operation of the vehicle.

21993–2010
Zuppo v. Commonwealth, Department of Transportation green
pacommwct · 1999
1 sentence

2026The Estate also relies on Zuppo, 739 A.2d 1148 , in which this Court applied Section 1933 of the Statutory Construction Act to conclude that Section 7704(a) of the Emergency Management Services Code (Emergency Code), 35 Pa.C.S. § 7704(a),16 created an exception to sovereign immunity for willful misconduct during declared disaster emergencies in addition to the nine exceptions to immunity listed in Section 8522(b) of the Judicial Code, 42 Pa.C.S. § 8522(b).

12026–2026
Virginia Office for Protection and Advocacy v. Stewart green
scotus · 2011
2 sentences

2024Petitioner relies on Virginia Office for Protection and Advocacy v. Stewart, 563 U.S. 247 (2011) (VOPA), in which the United States Supreme Court held that an exception to sovereign immunity permitted a lawsuit brought by an independent state agency against state officials, which alleged violations of federal law.

2024Sovereign immunity protects a state from “being hauled into court without its consent.” VOPA, 563 U.S. at 258 .

12024–2024
S. Wise v. Huntingdon County Housing Development Corp. green
pacommwct · 2019
1 sentence

2021Id. at 1165 .

12021–2021
Sherk v. County of Dauphin green
pa · 1992
1 sentence

2019Id.

12019–2019
Lichtman v. Glazer green
pacommwct · 2015
1 sentence

2019The real estate exception is contained in Section 8522(b)(4) of the Act, which provides an exception to sovereign immunity for damages claims arising from: 2 In its November 21, 2018 order, the trial court also denied Malles’ in forma pauperis motion. 3 “Our scope of review is limited to determining whether constitutional rights have been violated, whether the trial court abused its discretion, or whether the trial court committed an error of law.” Lichtman v. Glazer, 111 A.3d 1225 , 1227 n.4 (Pa. Cmwlth. 2015). 2 Commonwealth real estate, highways and sidewalks.--A dangerous condition of Comm

12019–2019
O'ROURKE v. Commonwealth green
pa · 2001
1 sentence

2018Bailets responds "PTC's mischaracterization of the Law as a waiver of sovereign *331 immunity requiring a narrow interpretation[,]" is contrary to binding precedent set forth by this Court, which ruled the Law is "chiefly a remedial measure intended to 'enhance openness in government and compel the government's compliance with the [L]aw by protecting those who inform authorities of wrongdoing.' " Bailets's Brief at 41-42, quoting O'Rourke , 778 A.2d at 1202 .

12018–2018
Commonwealth Department of Corrections v. Tate green
pacommwct · 2016
1 sentence

2017Gentilquore does not assert that any of the Department’s employees involved were acting outside the scope of their employment, and the exception to sovereign immunity set forth in Section 8522(b)(3) (related to damage to personal property in the care, custody, or control of a Commonwealth party), does not apply to intentional damage or takings, Tate, 133 A.3d at 359-60 .

12017–2017
Scientific Games International, Inc. v. Commonwealth green
pa · 2013
1 sentence

2016This matter is undoubtedly premised upon two agreements between Petitioner and the Commission, and our Supreme Court has made clear that “the exception to sovereign immunity pertaining to Board-of-Claims jurisdiction defines the extent of the Commonwealth’s statutory exception from sovereign immunity for claims arising from contract.” Scientific Games International, Inc. v. Commonwealth, 620 Pa. 175 , 66 A.3d 740, 755 (2013); see also Employers Insurance of Wausau v. Department of Transportation, 581 Pa. 381 , 865 A.2d 825, 831-34 (2005); Armenti v. Pennsylvania State System of Higher Educatio

12016–2016
Telwell, Inc. v. Public School Employees' Retirement System green
pacommwct · 2014
1 sentence

2016This matter is undoubtedly premised upon two agreements between Petitioner and the Commission, and our Supreme Court has made clear that “the exception to sovereign immunity pertaining to Board-of-Claims jurisdiction defines the extent of the Commonwealth’s statutory exception from sovereign immunity for claims arising from contract.” Scientific Games International, Inc. v. Commonwealth, 620 Pa. 175 , 66 A.3d 740, 755 (2013); see also Employers Insurance of Wausau v. Department of Transportation, 581 Pa. 381 , 865 A.2d 825, 831-34 (2005); Armenti v. Pennsylvania State System of Higher Educatio

12016–2016
Deibert v. Pennsylvania Turnpike Commission neutral
pactcompllehigh · 2010
1 sentence

2015The common pleas court ultimately held that LMT was subject to liability under the SWMA, finding as fact that the SWMA “creates a statutory cause of action” and that “[t]he Sovereign Immunity Act creates an exception to sovereign immunity where damages are recoverable in a statute creating a cause of action.” Id. at 174 .

12015–2015
Stevens v. Commonwealth, Department of Transportation green
pacommwct · 1985
1 sentence

2015Id.

12015–2015
Bendas v. Township of White Deer green
pa · 1992
2 sentences

2014Citing Snyder v. Harmon, 522 Pa. 424 , 562 A.2d 307 (1989), the Court held that PennDOT owed a duty of care. 5 Turning to the relevant immunity exception at 42 Pa.C.S. § 8522(b)(4), the Supreme Court held that the question of what is or is not a “dangerous condition” of a highway is one of fact that “must be answered by the jury.” Bendas, 531 Pa. at 185 , 611 A.2d at 1187 .

2014Citing Snyder v. Harmon, 522 Pa. 424 , 562 A.2d 307 (1989), the Court held that PennDOT owed a duty of care. 5 Turning to the relevant immunity exception at 42 Pa.C.S. § 8522(b)(4), the Supreme Court held that the question of what is or is not a “dangerous condition” of a highway is one of fact that “must be answered by the jury.” Bendas, 531 Pa. at 185 , 611 A.2d at 1187 .

12014–2014
Hill v. Port Authority Transit System neutral
pa · 1990
12006–2006
City of Philadelphia v. Nationwide Insurance green
pacommwct · 1985
12006–2006
Hill v. PORT AUTH. T. SYS., ALLEG. CTY. neutral
pacommwct · 1989
12006–2006
Fleetwood Area School District v. Berks County Board of Assessment Appeals green
· 2003
12004–2004
Southeastern Pennsylvania Transportation Authority v. Dunham green
pacommwct · 1995
12003–2003
Grieff v. Reisinger green
pa · 1997
12001–2001
Finn v. City of Philadelphia green
pacommwct · 1994
11997–1997
Finn v. City of Philadelphia green
pa · 1995
11997–1997
CSX Transportation, Inc. v. Franty Construction green
pacommwct · 1993
11994–1994
Crosby v. Kotch green
pacommwct · 1990
11993–1993
Commonwealth v. Bendas neutral
pacommwct · 1990
11992–1992
Ambacher v. Penrose green
pacommwct · 1985
11992–1992
WURTH BY WURTH v. City of Philadelphia green
pacommwct · 1990
11992–1992
Mascaro v. Youth Study Center green
pa · 1987
11992–1992
Hall v. Southeastern Pennsylvania Transportation Authority green
pacommwct · 1991
11992–1992
Mistecka v. Commonwealth green
pacommwct · 1979
11989–1989
Gore v. Bethlehem Area School District green
pacommwct · 1988
11989–1989
Walters v. Commonwealth, Department of Transportation green
pacommwct · 1984
11988–1988
Lehnig v. Felton red
pasuperct · 1980
11985–1985
Merling v. Commonwealth green
pacommwct · 1983
11985–1985

Statutes the citing opinions construe

PA § 42 Pa. Cons. Stat. § 8522 (35) PA § 42 Pa. Cons. Stat. § 8542 (12) PA § 42 Pa. Cons. Stat. § 8521 (10) PA § 42 Pa. Cons. Stat. § 8541 (10) PA § 42 Pa. Cons. Stat. § 8501 (6) PA § 62 Pa. Cons. Stat. § 1702 (6) PA § 62 Pa. Cons. Stat. § 1724 (5) PA § 75 Pa. Cons. Stat. § 6122 (5) PA § 42 Pa. Cons. Stat. § 761 (4) PA § 42 Pa. Cons. Stat. § 5522 (3) PA § 62 Pa. Cons. Stat. § 103 (3) PA § 62 Pa. Cons. Stat. § 1712.1 (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

PA 45 (1985–2026) TX 39 (1994–2025) AR 21 (2013–2026) MO 17 (1994–2025) IL 12 (1996–2025) GA 11 (1993–2021) CT 10 (1994–2022) AL 8 (1995–2017) WI 6 (1967–2024) HI 5 (1996–2024) OH 5 (2002–2013) NM 4 (2003–2019) CA 3 (2018–2021) ME 2 (2007–2022)

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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