43 Pennsylvania opinions name it 4 courts 1979–2026 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.
| Case | Followed | Cited |
|---|---|---|
Commonwealth v. Covilgreen2 sentences2018While the timing of such an instruction is discretionary, our Supreme Court has “emphasize[d] that it is better to give the limiting instruction at the time the evidence is admitted.” Covil, supra at 845 . 2014While the timing of such an instruction is discretionary, our Supreme Court has “emphasize[d] that it is better to give the limiting instruction at the time the evidence is admitted.” Overby, 809 A.2d at 315 n. 1, quoting Covil, 378 A.2d at 845 (ellipsis omitted). | 1 | 2 |
Commonwealth v. Peterkingreen2 sentences2018I § 14, concluding that the timing requirement represented a reasonable restriction.” Commonwealth v. Brown, 943 A.2d 264, 268 (Pa. 2008) (citing Peterkin, 722 A.2d at 642 ). 2008See Peterkin, 554 Pa. at 557-58 , 722 A.2d at 642 . | 1 | 2 |
Siegfried v. Borough of Wilsongreen1 sentence2026“The appellate court may sua sponte refuse to address an issue raised on appeal that was not raised and preserved below[.]” Siegfried v. Borough of Wilson, 695 A.2d 892, 894 (Pa. 22 Cmwlth. 1997) (citation omitted).9 Likewise, Dunkelberger did not preserve the issue of the ALJ’s failure to rule on his subpoena requests because he did not raise it with the ALJ. | 1 | 1 |
Blakely v. Washingtongreen1 sentence2025See Commonwealth v. Dixon, 255 A.3d 1258 , 1264 (Pa. 2021) (citing Alleyne, 570 U.S. at 114-15 (“When a finding of fact alters the legally prescribed punishment so as to aggravate it, the fact necessarily forms a constituent part of a new offense and must be submitted to the jury.”)); see also Ring v. Ariz., 536 U.S. 584, 600 (2002); Blakely v. Wash., 542 U.S. 296, 301 (2005); United States v. Booker, 543 U.S. 220, 231 (2005); Cunningham v. Cal., 549 U.S. 270, 282 (2007); Oregon v. Ice, 555 U.S. 160, 163 (2009); S. Union Co. v. United States, 567 U.S. 343, 346 (2012); United States v. Haymond, | 1 | 1 |
United States v. Bookergreen1 sentence2025See Commonwealth v. Dixon, 255 A.3d 1258 , 1264 (Pa. 2021) (citing Alleyne, 570 U.S. at 114-15 (“When a finding of fact alters the legally prescribed punishment so as to aggravate it, the fact necessarily forms a constituent part of a new offense and must be submitted to the jury.”)); see also Ring v. Ariz., 536 U.S. 584, 600 (2002); Blakely v. Wash., 542 U.S. 296, 301 (2005); United States v. Booker, 543 U.S. 220, 231 (2005); Cunningham v. Cal., 549 U.S. 270, 282 (2007); Oregon v. Ice, 555 U.S. 160, 163 (2009); S. Union Co. v. United States, 567 U.S. 343, 346 (2012); United States v. Haymond, | 1 | 1 |
Oregon v. Icegreen1 sentence2025See Commonwealth v. Dixon, 255 A.3d 1258 , 1264 (Pa. 2021) (citing Alleyne, 570 U.S. at 114-15 (“When a finding of fact alters the legally prescribed punishment so as to aggravate it, the fact necessarily forms a constituent part of a new offense and must be submitted to the jury.”)); see also Ring v. Ariz., 536 U.S. 584, 600 (2002); Blakely v. Wash., 542 U.S. 296, 301 (2005); United States v. Booker, 543 U.S. 220, 231 (2005); Cunningham v. Cal., 549 U.S. 270, 282 (2007); Oregon v. Ice, 555 U.S. 160, 163 (2009); S. Union Co. v. United States, 567 U.S. 343, 346 (2012); United States v. Haymond, | 1 | 1 |
Cunningham v. Californiagreen1 sentence2025See Commonwealth v. Dixon, 255 A.3d 1258 , 1264 (Pa. 2021) (citing Alleyne, 570 U.S. at 114-15 (“When a finding of fact alters the legally prescribed punishment so as to aggravate it, the fact necessarily forms a constituent part of a new offense and must be submitted to the jury.”)); see also Ring v. Ariz., 536 U.S. 584, 600 (2002); Blakely v. Wash., 542 U.S. 296, 301 (2005); United States v. Booker, 543 U.S. 220, 231 (2005); Cunningham v. Cal., 549 U.S. 270, 282 (2007); Oregon v. Ice, 555 U.S. 160, 163 (2009); S. Union Co. v. United States, 567 U.S. 343, 346 (2012); United States v. Haymond, | 1 | 1 |
Alleyne v. United Statesgreen1 sentence2025See Commonwealth v. Dixon, 255 A.3d 1258 , 1264 (Pa. 2021) (citing Alleyne, 570 U.S. at 114-15 (“When a finding of fact alters the legally prescribed punishment so as to aggravate it, the fact necessarily forms a constituent part of a new offense and must be submitted to the jury.”)); see also Ring v. Ariz., 536 U.S. 584, 600 (2002); Blakely v. Wash., 542 U.S. 296, 301 (2005); United States v. Booker, 543 U.S. 220, 231 (2005); Cunningham v. Cal., 549 U.S. 270, 282 (2007); Oregon v. Ice, 555 U.S. 160, 163 (2009); S. Union Co. v. United States, 567 U.S. 343, 346 (2012); United States v. Haymond, | 1 | 1 |
Ring v. Arizonagreen1 sentence2025See Commonwealth v. Dixon, 255 A.3d 1258 , 1264 (Pa. 2021) (citing Alleyne, 570 U.S. at 114-15 (“When a finding of fact alters the legally prescribed punishment so as to aggravate it, the fact necessarily forms a constituent part of a new offense and must be submitted to the jury.”)); see also Ring v. Ariz., 536 U.S. 584, 600 (2002); Blakely v. Wash., 542 U.S. 296, 301 (2005); United States v. Booker, 543 U.S. 220, 231 (2005); Cunningham v. Cal., 549 U.S. 270, 282 (2007); Oregon v. Ice, 555 U.S. 160, 163 (2009); S. Union Co. v. United States, 567 U.S. 343, 346 (2012); United States v. Haymond, | 1 | 1 |
Southern Union Co. v. United Statesgreen1 sentence2025See Commonwealth v. Dixon, 255 A.3d 1258 , 1264 (Pa. 2021) (citing Alleyne, 570 U.S. at 114-15 (“When a finding of fact alters the legally prescribed punishment so as to aggravate it, the fact necessarily forms a constituent part of a new offense and must be submitted to the jury.”)); see also Ring v. Ariz., 536 U.S. 584, 600 (2002); Blakely v. Wash., 542 U.S. 296, 301 (2005); United States v. Booker, 543 U.S. 220, 231 (2005); Cunningham v. Cal., 549 U.S. 270, 282 (2007); Oregon v. Ice, 555 U.S. 160, 163 (2009); S. Union Co. v. United States, 567 U.S. 343, 346 (2012); United States v. Haymond, | 1 | 1 |
DiFlorido v. DiFloridogreen2 sentences2024As Justice Ginsburg tirelessly articulated, equality demands “woman’s autonomy to determine her life’s course, and thus to enjoy equal citizenship stature.” 161 Being empowered under the law to determine the timing of presumption under the common law concept of coverture that presumed that a married woman, committing a crime in her husband’s presence, was an unwilling participant); DiFlorido v. DiFlorido, 331 A.2d 174, 180 (Pa. 1975) (holding that property acquired in anticipation of or during marriage and which has been possessed and used by both spouses will, in absence of contrary evidence, 2024As Justice Ginsburg tirelessly articulated, equality demands “woman’s autonomy to determine her life’s course, and thus to enjoy equal citizenship stature.” 161 Being empowered under the law to determine the timing of presumption under the common law concept of coverture that presumed that a married woman, committing a crime in her husband’s presence, was an unwilling participant); DiFlorido v. DiFlorido, 331 A.2d 174, 180 (Pa. 1975) (holding that property acquired in anticipation of or during marriage and which has been possessed and used by both spouses will, in absence of contrary evidence, | 1 | 1 |
Gonzales v. Carhartgreen1 sentence2024As Justice Ginsburg tirelessly articulated, equality demands “woman’s autonomy to determine her life’s course, and thus to enjoy equal citizenship stature.” 161 Being empowered under the law to determine the timing of presumption under the common law concept of coverture that presumed that a married woman, committing a crime in her husband’s presence, was an unwilling participant); DiFlorido v. DiFlorido, 331 A.2d 174, 180 (Pa. 1975) (holding that property acquired in anticipation of or during marriage and which has been possessed and used by both spouses will, in absence of contrary evidence, | 1 | 1 |
Commonwealth v. Butlergreen1 sentence2024As Justice Ginsburg tirelessly articulated, equality demands “woman’s autonomy to determine her life’s course, and thus to enjoy equal citizenship stature.” 161 Being empowered under the law to determine the timing of presumption under the common law concept of coverture that presumed that a married woman, committing a crime in her husband’s presence, was an unwilling participant); DiFlorido v. DiFlorido, 331 A.2d 174, 180 (Pa. 1975) (holding that property acquired in anticipation of or during marriage and which has been possessed and used by both spouses will, in absence of contrary evidence, | 1 | 1 |
Hartford Accident & Indemnity Co. v. Insurance Commissioner of Commonwealthgreen1 sentence2024As Justice Ginsburg tirelessly articulated, equality demands “woman’s autonomy to determine her life’s course, and thus to enjoy equal citizenship stature.” 161 Being empowered under the law to determine the timing of presumption under the common law concept of coverture that presumed that a married woman, committing a crime in her husband’s presence, was an unwilling participant); DiFlorido v. DiFlorido, 331 A.2d 174, 180 (Pa. 1975) (holding that property acquired in anticipation of or during marriage and which has been possessed and used by both spouses will, in absence of contrary evidence, | 1 | 1 |
Hopkins v. Blancogreen1 sentence2024As Justice Ginsburg tirelessly articulated, equality demands “woman’s autonomy to determine her life’s course, and thus to enjoy equal citizenship stature.” 161 Being empowered under the law to determine the timing of presumption under the common law concept of coverture that presumed that a married woman, committing a crime in her husband’s presence, was an unwilling participant); DiFlorido v. DiFlorido, 331 A.2d 174, 180 (Pa. 1975) (holding that property acquired in anticipation of or during marriage and which has been possessed and used by both spouses will, in absence of contrary evidence, | 1 | 1 |
Conway v. Danagreen1 sentence2024As Justice Ginsburg tirelessly articulated, equality demands “woman’s autonomy to determine her life’s course, and thus to enjoy equal citizenship stature.” 161 Being empowered under the law to determine the timing of presumption under the common law concept of coverture that presumed that a married woman, committing a crime in her husband’s presence, was an unwilling participant); DiFlorido v. DiFlorido, 331 A.2d 174, 180 (Pa. 1975) (holding that property acquired in anticipation of or during marriage and which has been possessed and used by both spouses will, in absence of contrary evidence, | 1 | 1 |
Commonwealth v. Spotz, M., Aplt.green1 sentence2022See Commonwealth v. Spotz, 171 A.3d 675, 729 (Pa. 2017). | 1 | 1 |
Commonwealth v. Burrellgreen1 sentence2021See e.g., Commonwealth v. Brown, 469 A.2d 1371, 1376 (Pa. 1983); Commonwealth v. Burrell, 441 A.2d 744, 746 (Pa. 1983). “[I]t is clear that there is no statutory restriction in this State that would prevent the court from holding a hearing where the alleged violation is the commission of an offense during the probationary period prior to the trial for the subsequent offense.” Commonwealth v. Kates, 305 A.2d 701, 706 (Pa. 1973). | 1 | 1 |
Commonwealth v. Katesgreen1 sentence2021See e.g., Commonwealth v. Brown, 469 A.2d 1371, 1376 (Pa. 1983); Commonwealth v. Burrell, 441 A.2d 744, 746 (Pa. 1983). “[I]t is clear that there is no statutory restriction in this State that would prevent the court from holding a hearing where the alleged violation is the commission of an offense during the probationary period prior to the trial for the subsequent offense.” Commonwealth v. Kates, 305 A.2d 701, 706 (Pa. 1973). | 1 | 1 |
Commonwealth v. Sanchezgreen1 sentence2021See Commonwealth v. Sanchez, 204 A.3d 524, 526 (Pa. Super. 2019). | 1 | 1 |
Commonwealth v. Browngreen1 sentence2021See e.g., Commonwealth v. Brown, 469 A.2d 1371, 1376 (Pa. 1983); Commonwealth v. Burrell, 441 A.2d 744, 746 (Pa. 1983). “[I]t is clear that there is no statutory restriction in this State that would prevent the court from holding a hearing where the alleged violation is the commission of an offense during the probationary period prior to the trial for the subsequent offense.” Commonwealth v. Kates, 305 A.2d 701, 706 (Pa. 1973). | 1 | 1 |
| Commonwealth v. Yohegreen | 1 | 1 |
| Commonwealth v. Albrechtgreen | 1 | 1 |
| Commonwealth v. Fahygreen | 1 | 1 |
| Commonwealth v. Browngreen | 1 | 1 |
| Feldman v. Hoffmangreen | 1 | 1 |
| People v. Browngreen | 1 | 1 |
| Commonwealth v. Felicianogreen | 1 | 1 |
| Commonwealth v. Fergusongreen | 1 | 1 |
| Commonwealth v. Harrisgreen | 1 | 1 |
| Commonwealth v. Abdul-Salaamgreen | 1 | 1 |
| Commonwealth v. Browngreen | 1 | 1 |
| Commonwealth v. Sullivangreen | 1 | 1 |
| Commonwealth v. Crewsgreen | 1 | 1 |
| Commonwealth v. Bondgreen | 1 | 1 |
| Albert Appealgreen | 1 | 1 |
| Commonwealth v. Morgangreen | 1 | 1 |
| Richardson v. Town Of Eastovergreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Salsman v. Brown
green
2 sentences2018The Majority cites Salsman v. Brown , 51 A.3d 892 (Pa. Super. 2012), 5 which relied on Nationwide Mutual Ins. 2018The Majority cites Salsman v. Brown, 51 A.3d 892 (Pa. Super. 2012),5 which relied on Nationwide Mutual Ins. | 2 | 2018–2018 |
M & P Management, L.P. v. Williams
green
1 sentence2025However, in 1996, the Rules of Civil Procedure related to confessed judgments were amended to “create[] an express time period for opening or striking off confessed judgments with the timing requirement triggered upon receipt of notice.” Id. at 401 . | 1 | 2025–2025 |
Williams v. F.L. Smithe MacHine Co.
green
1 sentence2025As noted supra, in Williams, 577 A.2d 907 , this Court for the first time construed § 5103(b) as imposing a timing requirement which compels a plaintiff to transfer a case to a Pennsylvania court once a federal court has dismissed a claim for lack of jurisdiction. | 1 | 2025–2025 |
United States v. Haymond
green
1 sentence2025See Commonwealth v. Dixon, 255 A.3d 1258 , 1264 (Pa. 2021) (citing Alleyne, 570 U.S. at 114-15 (“When a finding of fact alters the legally prescribed punishment so as to aggravate it, the fact necessarily forms a constituent part of a new offense and must be submitted to the jury.”)); see also Ring v. Ariz., 536 U.S. 584, 600 (2002); Blakely v. Wash., 542 U.S. 296, 301 (2005); United States v. Booker, 543 U.S. 220, 231 (2005); Cunningham v. Cal., 549 U.S. 270, 282 (2007); Oregon v. Ice, 555 U.S. 160, 163 (2009); S. Union Co. v. United States, 567 U.S. 343, 346 (2012); United States v. Haymond, | 1 | 2025–2025 |
Henderson v. Henderson
green
1 sentence2024As Justice Ginsburg tirelessly articulated, equality demands “woman’s autonomy to determine her life’s course, and thus to enjoy equal citizenship stature.” 161 Being empowered under the law to determine the timing of presumption under the common law concept of coverture that presumed that a married woman, committing a crime in her husband’s presence, was an unwilling participant); DiFlorido v. DiFlorido, 331 A.2d 174, 180 (Pa. 1975) (holding that property acquired in anticipation of or during marriage and which has been possessed and used by both spouses will, in absence of contrary evidence, | 1 | 2024–2024 |
Commonwealth Ex Rel. Spriggs v. Carson
green
1 sentence2024As Justice Ginsburg tirelessly articulated, equality demands “woman’s autonomy to determine her life’s course, and thus to enjoy equal citizenship stature.” 161 Being empowered under the law to determine the timing of presumption under the common law concept of coverture that presumed that a married woman, committing a crime in her husband’s presence, was an unwilling participant); DiFlorido v. DiFlorido, 331 A.2d 174, 180 (Pa. 1975) (holding that property acquired in anticipation of or during marriage and which has been possessed and used by both spouses will, in absence of contrary evidence, | 1 | 2024–2024 |
In re Estate of Easterday
green
2 sentences2023It next observed that in the decades after it promulgated Rule 1920.42(b), the General Assembly amended the Divorce Code on multiple times but never did so “in a manner that would either eliminate or in any respect alter this Court’s inclusion of a timing requirement for the signing of an affidavit of consent (i.e., within thirty days of filing) to effectuate a no-fault divorce under section 3301(c).” Id. 2023It next observed that in the decades after it promulgated Rule 1920.42(b), the General Assembly amended the Divorce Code on multiple times but never did so “in a manner that would either eliminate or in any respect alter this Court’s inclusion of a timing requirement for the signing of an affidavit of consent (i.e., within thirty days of filing) to effectuate a no-fault divorce under section 3301(c).” Id. | 1 | 2023–2023 |
Transportation Services, Inc. v. Underground Storage Tank Indemnification Board
green
1 sentence2023Servs., 67 A.3d at 155 ). | 1 | 2023–2023 |
| cluster 465432 green | 1 | 2021–2021 |
Commonwealth v. Smith
green
2 sentences2021Appellant alternatively argues that his ineffectiveness claim satisfies the newly discovered fact exception to the PCRA’s timing requirement set forth at ____________________________________________ 13 In Commonwealth v. Smith, 121 A.3d 1049 (Pa. Super. 2015), a panel of this Court held that the fact a petitioner was represented by the allegedly ineffective counsel at the time Rule 907 notice was provided did not excuse the petitioner’s obligation to “complain about PCRA counsel’s stewardship.” Id. at 1055 . 2021Appellant alternatively argues that his ineffectiveness claim satisfies the newly discovered fact exception to the PCRA’s timing requirement set forth at ____________________________________________ 13 In Commonwealth v. Smith, 121 A.3d 1049 (Pa. Super. 2015), a panel of this Court held that the fact a petitioner was represented by the allegedly ineffective counsel at the time Rule 907 notice was provided did not excuse the petitioner’s obligation to “complain about PCRA counsel’s stewardship.” Id. at 1055 . | 1 | 2021–2021 |
| Williams v. Madenspacher green | 1 | 2020–2020 |
| Com. v. Schirmer neutral | 1 | 2019–2019 |
| Creach v. Creach green | 1 | 2019–2019 |
| Lazaric v. Lazaric green | 1 | 2019–2019 |
| Com. v. BAHIY green | 1 | 2017–2017 |
| Eathorne v. State Ethics Commission green | 1 | 2017–2017 |
| Commonwealth v. Miller green | 1 | 2017–2017 |
| Commonwealth v. Spotz green | 1 | 2016–2016 |
| Missouri v. Frye green | 1 | 2015–2015 |
| Lafler v. Cooper green | 1 | 2015–2015 |
| Commonwealth v. Overby green | 1 | 2014–2014 |
| Dietrich v. Dietrich green | 1 | 2009–2009 |
| Commonwealth v. Demark green | 1 | 2008–2008 |
| Moody v. Daggett green | 1 | 2000–2000 |
| Commonwealth v. Wood green | 1 | 1996–1996 |
| Patterson v. Cronin green | 1 | 1991–1991 |
| Mathews v. Eldridge green | 1 | 1991–1991 |
| Wardius v. Oregon green | 1 | 1979–1979 |
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.
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.