Ivy Hill Congregation of Jehovah’s Witnesses v. Dep’t of Human Servs., 2024 WL 561402 (Pa. Feb. 13, 2024)

Pennsylvania Supreme Court Rules that Procedural Posture of Case Is Irrelevant When Determining Whether a Court Decision Violated the Coordinate Jurisdiction Rule

The plaintiff filed a petition for declaratory judgment with the Commonwealth Court of Pennsylvania, seeking a declaration that its religious elders were entitled to protection under Section 6311.1(b) of the Child Protective Services Law. The Department of Human Services (DHS) filed preliminary objections to the petition, which the Commonwealth Court denied (the first decision). After DHS filed its answer and new matter to the petition, the parties engaged in discovery. The plaintiff then filed a motion for summary judgment. The Commonwealth Court denied the plaintiff’s motion and dismissed its petition (the second decision). The plaintiff subsequently appealed the second decision and argued that it violated the coordinate jurisdiction rule. 

In opposition to the appeal, in addition to other arguments, DHS contended that the second decision did not violate the coordinate jurisdiction rule as the two decisions addressed different motions and had different procedural postures. The Supreme Court rejected this argument and held that the procedural posture of a case is irrelevant in determining whether there was a violation of the rule. The Supreme Court ruled that “the coordinate jurisdiction rule applies unless there has been a change in the law; a change in the facts; or a conclusion that the initial ruling was clearly erroneous, and that following it would create a manifest of injustice.” The court further ruled that “[w]hile a ruling issued at a different stage of the proceedings may give rise to one of the limited exceptions to the coordinate jurisdiction rule – for example, a change in the facts – it is the demonstration of the exceptional circumstance, not the distinct procedural posture, which renders the coordinate jurisdiction rule inapplicable.” The Supreme Court found that DHS did not demonstrate any change in the law or facts or that the first decision was clearly erroneous. Thus, the court held that the second decision violated the coordinate jurisdiction rule. 

Given this ruling, defense attorneys should be mindful when filing early dispositive motions, such as preliminary objections, and should provide trial courts with potential language to include in court orders to preserve the right to later file dispositive motions, such as motions for summary judgment. 

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