need rule (Pennsylvania) · Go Syfert
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need rule in Pennsylvania

43 Pennsylvania opinions name it 5 courts 1951–2024 5 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 (23)

CaseFollowedCited
Miller v. Nelsongreen
pasuperct · 2001 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
1 sentence

2024(Trial Ct. Op. at 4; R.R at 116a.) The trial court concluded that this conduct justified an award of attorneys’ fees because it was a “relentless pursuit of a claim which plainly lacks legal merit.” Id. (citing Miller v. Nelson, 768 A.2d 858, 862 (Pa. Super. 2001)).

11
City of Phila v. Estate of T. Labrosciano ~ Appeal of: R. Labroscianogreen
pacommwct · 2018 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023See Labrosciano, 202 A.3d at 152-53 . 13 Despite these issues, we cannot grant relief to F.A.

11
Miller v. Alabamagreen
scotus · 2012 · cited in 1 Pennsylvania opinions naming this issue, 2022–2022
1 sentence

2022The trial court, however, stated that, “[t]he Commonwealth conceded [Appellant’s] position and the [o]rder granting relief under [g]round [o]ne was entered without the need for a hearing or argument.” Trial Court Opinion, 12/9/19, at ¶11; see also Appellant’s Reply to Commonwealth’s Answer to PCRA Petition, 3/28/16, at unnumbered page 1 (stating, “[t]he Commonwealth agree[d] at page 6 of its [answer to Appellant’s PCRA petition] that [Appellant] is entitled to be resentenced [pursuant to Miller, supra, and Montgomery, supra]”). -4- J-A25019-20 On April 12, 2018, the PCRA court denied Appellant

11
Montgomery v. Louisianagreen
· 2016 · cited in 1 Pennsylvania opinions naming this issue, 2022–2022
1 sentence

2022The trial court, however, stated that, “[t]he Commonwealth conceded [Appellant’s] position and the [o]rder granting relief under [g]round [o]ne was entered without the need for a hearing or argument.” Trial Court Opinion, 12/9/19, at ¶11; see also Appellant’s Reply to Commonwealth’s Answer to PCRA Petition, 3/28/16, at unnumbered page 1 (stating, “[t]he Commonwealth agree[d] at page 6 of its [answer to Appellant’s PCRA petition] that [Appellant] is entitled to be resentenced [pursuant to Miller, supra, and Montgomery, supra]”). -4- J-A25019-20 On April 12, 2018, the PCRA court denied Appellant

11
Terwilliger v. Kitchengreen
pasuperct · 2001 · cited in 1 Pennsylvania opinions naming this issue, 2018–2018
1 sentence

2018(See Trial Court Opinion, 3/09/17, at 2); see also 42 Pa.C.S.A. § 7102(a), Comparative Negligence; Terwilliger v. Kitchen, 781 A.2d 1201, 1209 (Pa. Super. 2001) (“Pennsylvania’s comparative negligence statute does not bar recovery by the ____________________________________________ 5We note that Pennsylvania Rule of Evidence 407, Subsequent Remedial Measures, provides: When measures are taken by a party that would have made an earlier injury or harm less likely to occur, evidence of the subsequent measures is not admissible against that party to prove: • negligence; • culpable conduct; • a def

11
Commonwealth v. Mooregreen
pa · 1975 · cited in 1 Pennsylvania opinions naming this issue, 2017–2017
2 sentences

2017As Mr. Justice (now Chief Justice) Eagen has stated: “In those instances where an involuntary manslaughter verdict would be supported by the evidence, the failure to so acquaint the jury prevents it from operating with full knowledge of the relevant law and precludes the defendant from having a fair trial.” Commonwealth v. Moore, 463 Pa. 317, 322 , 344 A.2d 850, 853 (1975) (plurality opinion). -8- J-A31004-16 The need for an instruction on involuntary manslaughter also follows from the Commonwealth's burden of proof.

2017As Mr. Justice (now Chief Justice) Eagen has stated: “In those instances where an involuntary manslaughter verdict would be supported by the evidence, the failure to so acquaint the jury prevents it from operating with full knowledge of the relevant law and precludes the defendant from having a fair trial.” Commonwealth v. Moore, 463 Pa. 317, 322 , 344 A.2d 850, 853 (1975) (plurality opinion). -8- J-A31004-16 The need for an instruction on involuntary manslaughter also follows from the Commonwealth's burden of proof.

11
Commonwealth v. Brazilgreen
pa · 1997 · cited in 1 Pennsylvania opinions naming this issue, 2006–2006
2 sentences

2006Trial, 11/15/04, at 5-11. [4] I would note that this Court in Wentz did not require a waiver colloquy in order to find the appellant "waived" his right to counsel. 421 A.2d at 434 . [5] Although I recognize that the appointment of standby counsel does not eliminate the need for a waiver colloquy when an appellant waives his right to counsel, Commonwealth v. Brazil, 549 Pa. 321, 326 , 701 A.2d 216, 219 (1997), such does not affect the analysis of whether Appellant forfeited his right to counsel.

2006Trial, 11/15/04, at 5-11. [4] I would note that this Court in Wentz did not require a waiver colloquy in order to find the appellant "waived" his right to counsel. 421 A.2d at 434 . [5] Although I recognize that the appointment of standby counsel does not eliminate the need for a waiver colloquy when an appellant waives his right to counsel, Commonwealth v. Brazil, 549 Pa. 321, 326 , 701 A.2d 216, 219 (1997), such does not affect the analysis of whether Appellant forfeited his right to counsel.

11
Commonwealth v. Eastongreen
pasuperct · 1985 · cited in 1 Pennsylvania opinions naming this issue, 2005–2005
1 sentence

2005Id. at 13-17, 28-29. ¶ 12 For example, the Court stated: Here we are assuming that the legislative findings set forth above, see supra note 14, are substantially valid.

11
Freightliner Corp. v. Myrickgreen
scotus · 1995 · cited in 1 Pennsylvania opinions naming this issue, 1996–1996
1 sentence

1996At best, Cipollone supports an inference that an express pre-emption analysis forecloses implied pre-emption; it does not establish a rule. *454 Freightliner Corp. v. Myrick, ___ U.S. at ___, 115 S.Ct. at 1488 , 131 L.Ed.2d at 393 (citations omitted).

11
Ex Parte Ruddergreen
ala · 1987 · cited in 1 Pennsylvania opinions naming this issue, 1987–1987
1 sentence

1987The need for such a privilege is widely recognized, see e.g., Ex Parte Rudder, 507 So.2d 411, 413 (Ala.1987); Bond v. District Court of the County of Denver, 682 P.2d 33, 38 (Colo.1984); State v. Miller, 300 Or. 203 , 709 P.2d 225, 232 (1985); State ex rel.

11
Bond v. DIST. CT., IN AND FOR DENVER CTY.green
colo · 1984 · cited in 1 Pennsylvania opinions naming this issue, 1987–1987
1 sentence

1987The need for such a privilege is widely recognized, see e.g., Ex Parte Rudder, 507 So.2d 411, 413 (Ala.1987); Bond v. District Court of the County of Denver, 682 P.2d 33, 38 (Colo.1984); State v. Miller, 300 Or. 203 , 709 P.2d 225, 232 (1985); State ex rel.

11
State v. Millergreen
or · 1985 · cited in 1 Pennsylvania opinions naming this issue, 1987–1987
2 sentences

1987The need for such a privilege is widely recognized, see e.g., Ex Parte Rudder, 507 So.2d 411, 413 (Ala.1987); Bond v. District Court of the County of Denver, 682 P.2d 33, 38 (Colo.1984); State v. Miller, 300 Or. 203 , 709 P.2d 225, 232 (1985); State ex rel.

1987The need for such a privilege is widely recognized, see e.g., Ex Parte Rudder, 507 So.2d 411, 413 (Ala.1987); Bond v. District Court of the County of Denver, 682 P.2d 33, 38 (Colo.1984); State v. Miller, 300 Or. 203 , 709 P.2d 225, 232 (1985); State ex rel.

11
Laudenberger v. Port Auth. of Alleghenygreen
pa · 1981 · cited in 1 Pennsylvania opinions naming this issue, 1986–1986
11
Auel v. Whitegreen
pa · 1957 · cited in 1 Pennsylvania opinions naming this issue, 1986–1986
11
Cribb v. United Health Clubs Inc.green
pa · 1984 · cited in 1 Pennsylvania opinions naming this issue, 1986–1986
11
Warden v. Zanellagreen
pasuperct · 1980 · cited in 1 Pennsylvania opinions naming this issue, 1981–1981
11
Axler v. First Newport Realty Investorsgreen
pasuperct · 1980 · cited in 1 Pennsylvania opinions naming this issue, 1981–1981
11
Commonwealth v. Johnstongreen
pa · 1970 · cited in 1 Pennsylvania opinions naming this issue, 1979–1979
11
Commonwealth v. Hubbardred
pa · 1977 · cited in 1 Pennsylvania opinions naming this issue, 1977–1977
11
Commonwealth v. Ricegreen
pa · 1974 · cited in 1 Pennsylvania opinions naming this issue, 1977–1977
11
Commonwealth v. Martingreen
pa · 1976 · cited in 1 Pennsylvania opinions naming this issue, 1977–1977
11
Commonwealth v. Brownmillergreen
pasuperct · 1940 · cited in 1 Pennsylvania opinions naming this issue, 1970–1970
11
Heisse v. Marklandgreen
pa · 1830 · cited in 1 Pennsylvania opinions naming this issue, 1951–1951
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 (38)

CaseCitedYears
District of Columbia v. Heller green
scotus · 2008
2 sentences

2024Id. at 628 .

2013The Supreme Court continued: “The prohibition extends, moreover, to the home, where the need for defense of self, family, and property is most acute.” Id.

22013–2024
Missouri v. McNeely green
scotus · 2013
2 sentences

2019Following McNeely , although the dissipation of BAC evidence "may support a finding of exigency in a specific case, as it did in Schmerber , it does not do so categorically." Id. at 156 , 133 S.Ct. 1552 . 1 Rather, "[w]hether a warrantless blood test of a drunk-driving suspect is reasonable must be determined case by case based on the totality of the circumstances." Id.

2019Following McNeely , although the dissipation of BAC evidence "may support a finding of exigency in a specific case, as it did in Schmerber , it does not do so categorically." Id. at 156 , 133 S.Ct. 1552 . 1 Rather, "[w]hether a warrantless blood test of a drunk-driving suspect is reasonable must be determined case by case based on the totality of the circumstances." Id.

22019–2019
Carlson v. Ciavarelli green
pacommwct · 2014
1 sentence

2024(Trial Ct. Op. at 4; R.R at 116a.) The trial court concluded that this conduct justified an award of attorneys’ fees because it was a “relentless pursuit of a claim which plainly lacks legal merit.” Id. (citing Miller v. Nelson, 768 A.2d 858, 862 (Pa. Super. 2001)).

12024–2024
Energy Conservation Council v. Public Utility Commission green
pacommwct · 2010
1 sentence

2022The ALJ noted the question of whether resolving “congestion,” 10 Additional evidence was taken, and findings of fact made, related to the other factors under Section 57.76(a) of the Regulations, such as environmental impacts and reasonable alternatives. 10 alone, is sufficient to meet the need requirement under the Code and the Regulations had not yet been answered and that this Court in Energy Conservation Council of Pennsylvania v. Public Utility Commission, 995 A.2d 465 (Pa. Cmwlth. 2010), did not resolve the issue, determining that reliability issues within the PJM Region supported the fin

12022–2022
Commonwealth v. Flor green
pa · 2010
1 sentence

2016Further, Mother maintains that the trial court “failed to weigh [her] due process rights against the need to hold a hearing at that time.” Id.

12016–2016
Clouser v. Shamokin Packing Co. green
pasuperct · 1976
1 sentence

2015Accordingly, the Court need not rule on outstanding preliminary objections, as they are being treated as motions for judgment on the pleadings, as "a preliminary objection in the nature of a demurrer is identical to a motion for judgment on the pleadings pursuant to Rule 1034, Pa.R.C.P., and is governed by identical standards." Clouser v. Shamokin Packing Co., 361 A.2d 836 , (Pa.Super. 1976).

12015–2015
Grant v. Pennsylvania Board of Probation & Parole green
pa · 2011
2 sentences

2013The court also “[found] it prudent to limit the reach of this NEED claim to preexisting relationships involving duties that obviously and objectively hold the potential of deep emotional harm in the event of breach.... [T]he special relationships must encompass an implied duty to care for the plaintiff’s emotional well-being.” Id.

2013While not defining each and every relationship that would qualify, the court stated, “[nonetheless, we would hold that some relationships, including some doctor-patient relationships, will involve an implied duty to care for the plaintiff’s emotional well-being that, if breached, has the potential to cause emotional distress resulting in physical harm.” Id.

12013–2013
Parham v. J. R. green
scotus · 1979
2 sentences

2010Rejecting the argument of the need for such a hearing, the Court opined that "the supposed protections of an adversary proceeding to determine the appropriateness of medical decisions for the commitment and treatment of mental and emotional illness may well be more illusory than real." Id. at 609 , 99 S.Ct. 2493 .

2010Rejecting the argument of the need for such a hearing, the Court opined that "the supposed protections of an adversary proceeding to determine the appropriateness of medical decisions for the commitment and treatment of mental and emotional illness may well be more illusory than real." Id. at 609 , 99 S.Ct. 2493 .

12010–2010
Gtech Corp. v. Commonwealth, Department of Revenue green
pacommwct · 2009
1 sentence

2009In that case, the Department of Revenue failed to take immediate action on the bid protest and failed to stay contract negotiations pursuant to Section 1711 (k) of the Procurement Code, 62 Pa.C.S. § 171 l.l(k), which requires a stay of the procurement proceeding upon filing of a protest "unless and until the head of the purchasing agency ... makes a written determination that the protest is clearly without merit or that award of the contract without delay is necessary to protect substantial interests of the Commonwealth.” The GTECH Court held that, "[a]n agency cannot invoke the exception when

12009–2009
Busik v. Levine green
nj · 1973
2 sentences

2006Indeed, the Explanatory Comments single out the New Jersey Supreme Court decision in Busik v. Levine, 63 N.J. 351 , 307 A.2d 571 (1973) which interpreted New Jersey’s rule that provided for an additional six percent to the award “[i]n tort actions, including products liability actions, ... from the date of the institution of the action or from a date six months after the date of the tort, whichever is later.” N.J.R. 4:42-11(b).

2006Indeed, the Explanatory Comments single out the New Jersey Supreme Court decision in Busik v. Levine, 63 N.J. 351 , 307 A.2d 571 (1973) which interpreted New Jersey’s rule that provided for an additional six percent to the award “[i]n tort actions, including products liability actions, ... from the date of the institution of the action or from a date six months after the date of the tort, whichever is later.” N.J.R. 4:42-11(b).

12006–2006
Commonwealth v. Wentz green
pasuperct · 1981
1 sentence

2006Trial, 11/15/04, at 5-11. [4] I would note that this Court in Wentz did not require a waiver colloquy in order to find the appellant "waived" his right to counsel. 421 A.2d at 434 . [5] Although I recognize that the appointment of standby counsel does not eliminate the need for a waiver colloquy when an appellant waives his right to counsel, Commonwealth v. Brazil, 549 Pa. 321, 326 , 701 A.2d 216, 219 (1997), such does not affect the analysis of whether Appellant forfeited his right to counsel.

12006–2006
Cleveland Board of Education v. Loudermill green
scotus · 1985
1 sentence

2001These are the private interests in retaining employment, the governmental interest in the expeditious removal of unsatisfactory employees and the avoidance of administrative burdens, and the risk of an erroneous termination.” Loudermill at 542-43 , 105 S.Ct. at 1493 .

12001–2001
Ayala v. Philadelphia Board of Public Education red
pa · 1973
2 sentences

1993In Ayala v. Philadelphia Board of Public Education, 453 Pa. 584 , 305 A.2d 877 (1973), with the abolition of common law governmental immunity, the need for such a test was vitiated.

1993In Ayala v. Philadelphia Board of Public Education, 453 Pa. 584 , 305 A.2d 877 (1973), with the abolition of common law governmental immunity, the need for such a test was vitiated.

11993–1993
Northampton County Area Community College v. Dow Chemical, U.S.A. green
pa · 1989
2 sentences

1993In describing this “function test,” the Superior Court in Northampton County Area Community College v. Dow Chemical, 389 Pa. Superior Ct. 11 , 566 A.2d 591 (1989), affirmed per curiam, 528 Pa. 502 , 598 A.2d 1288 (1991), states: The trial court applied a traditional test for whether a governmental entity can claim governmental immunity, whether the controversy arose by virtue of a governmental or by virtue of a proprietary action by the entity....

1993In describing this “function test,” the Superior Court in Northampton County Area Community College v. Dow Chemical, 389 Pa. Superior Ct. 11 , 566 A.2d 591 (1989), affirmed per curiam, 528 Pa. 502 , 598 A.2d 1288 (1991), states: The trial court applied a traditional test for whether a governmental entity can claim governmental immunity, whether the controversy arose by virtue of a governmental or by virtue of a proprietary action by the entity....

11993–1993
Northampton County Area Community College v. Dow Chemical, U.S.A. green
pa · 1991
2 sentences

1993In describing this “function test,” the Superior Court in Northampton County Area Community College v. Dow Chemical, 389 Pa. Superior Ct. 11 , 566 A.2d 591 (1989), affirmed per curiam, 528 Pa. 502 , 598 A.2d 1288 (1991), states: The trial court applied a traditional test for whether a governmental entity can claim governmental immunity, whether the controversy arose by virtue of a governmental or by virtue of a proprietary action by the entity....

1993In describing this “function test,” the Superior Court in Northampton County Area Community College v. Dow Chemical, 389 Pa. Superior Ct. 11 , 566 A.2d 591 (1989), affirmed per curiam, 528 Pa. 502 , 598 A.2d 1288 (1991), states: The trial court applied a traditional test for whether a governmental entity can claim governmental immunity, whether the controversy arose by virtue of a governmental or by virtue of a proprietary action by the entity....

11993–1993
Commonwealth v. Brady green
pa · 1986
2 sentences

1989Subsequently, in Commonwealth v. Brady, 510 Pa. 336 , 508 A.2d 286 (1986), the Court recognized the need for a rule to prevent the use of a frivolous double jeopardy claim as a tool to disrupt and to delay the functioning of the criminal trial process: The stay of a criminal trial pending appeal necessitates what may be lengthy delays in the prosecution of the defendant.

1989Subsequently, in Commonwealth v. Brady, 510 Pa. 336 , 508 A.2d 286 (1986), the Court recognized the need for a rule to prevent the use of a frivolous double jeopardy claim as a tool to disrupt and to delay the functioning of the criminal trial process: The stay of a criminal trial pending appeal necessitates what may be lengthy delays in the prosecution of the defendant.

11989–1989
CONSUMERS ED. & PROT. ASS'N v. Schwartz green
pa · 1981
2 sentences

1989Judge Johnson recognized the general principle that “repeals by implication are not favored and will not be permitted if there is any other reasonable construction, and that a law is not repealed by a later enactment if the two may be operative without repugnance to each other,” Consumers Education and Protective Association v. Schwartz, 495 Pa. 10 , 23 n. 17, 432 A.2d 173 , 180 n. 17 (1981), and concluded in his opinion: While the Financial Responsibility Law appears to advance the maximum restoration of individuals injured in connection with the use or maintenance of motor vehicles, the Poli

1989Judge Johnson recognized the general principle that “repeals by implication are not favored and will not be permitted if there is any other reasonable construction, and that a law is not repealed by a later enactment if the two may be operative without repugnance to each other,” Consumers Education and Protective Association v. Schwartz, 495 Pa. 10 , 23 n. 17, 432 A.2d 173 , 180 n. 17 (1981), and concluded in his opinion: While the Financial Responsibility Law appears to advance the maximum restoration of individuals injured in connection with the use or maintenance of motor vehicles, the Poli

11989–1989
STATE EX REL. JUVENILE DEPT., CLATSOP CTY v. Martin neutral
or · 1975
2 sentences

1987Juvenile Dept. of Clatsop County v. Martin, 271 Or. 603 , 606 nn. 2, 3, 533 P.2d 780 , 781 nn. 2, 3 (1975).

1987Juvenile Dept. of Clatsop County v. Martin, 271 Or. 603 , 606 nn. 2, 3, 533 P.2d 780 , 781 nn. 2, 3 (1975).

11987–1987
Rank v. Metropolitan Edison Co. green
pa · 1952
11986–1986
Brown v. Newkirk green
ga · 1977
11981–1981
Petition of Dwyer green
pa · 1979
11981–1981
Moreland v. Metrovich green
pasuperct · 1977
11981–1981
Commonwealth v. Roane green
pa · 1974
11980–1980
Commonwealth v. Goldsmith green
pa · 1970
11979–1979
Duggan v. 807 Liberty Ave., Inc. green
pa · 1972
11979–1979
Workmen's Compensation Appeal Board v. Philco Ford Corp. green
pacommwct · 1976
11979–1979
Black v. Wyalusing Area School District green
pacommwct · 1976
11978–1978
Commonwealth v. Haideman green
pa · 1972
11977–1977
Commonwealth v. Hilliard green
pa · 1977
11977–1977
Nissley v. Pennsylvania Railroad green
pa · 1969
11975–1975
Martorano Appeal green
pasuperct · 1973
11975–1975
Commonwealth v. Chapasco green
pa · 1969
11974–1974
Commonwealth v. Campana green
pa · 1973
11973–1973
Commonwealth v. Kilgallen green
pa · 1954
11970–1970
Commonwealth v. Kirk green
pasuperct · 1940
11970–1970
Commonwealth v. Kirk green
pa · 1940
11970–1970
Farmers & Miners National Bank v. Taylor green
pa · 1934
11951–1951
Austin's Estate green
pa · 1934
11951–1951

Statutes the citing opinions construe

PA § 42 Pa. Cons. Stat. § 8541 (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 128 (1919–2026) CA 103 (1953–2025) TX 87 (1978–2025) IL 67 (1955–2025) OH 50 (1988–2026) LA 49 (1956–2023) NJ 49 (1960–2026) FL 45 (1973–2019) PA 43 (1951–2024) CT 35 (1973–2024) MI 30 (1970–2025) DC 29 (1978–2024) MA 29 (1895–2025) IN 24 (1976–2020) OR 23 (1985–2025) WA 22 (1944–2025) MO 21 (1982–2024) CO 21 (1984–2025) MD 19 (1988–2024) IA 19 (1960–2025) WI 18 (1975–2023) TN 16 (1978–2024) NM 15 (1980–2023) NC 14 (1982–2025) DE 13 (1990–2025) AZ 13 (1968–2024) KS 12 (1980–2025) ID 11 (1972–2021) MS 9 (1980–2017) WV 9 (1975–2017) VA 9 (1967–2013) AK 9 (1982–2025) NH 9 (1979–2018) AL 9 (1994–2016) GA 9 (1925–2025) RI 8 (1979–2010) SC 8 (2007–2011) ME 8 (1978–2025) MN 7 (1966–2024) UT 7 (1995–2022) KY 7 (1985–2025) HI 6 (2000–2020) WY 6 (1966–2006) VT 5 (1991–2018) OK 5 (1988–2023) NE 4 (1998–2022) NV 4 (2016–2017) MT 4 (1989–2015) AR 4 (1982–2020) SD 2 (2005–2025) ND 2 (1979–1983)

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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