Commonwealth ex rel. Kearney v. Rambler, 32 A.3d 658

Rambler pled guilty in 1996 to a federal felony—mailing threatening communications (18 U.S.C. § 876(d))—under a government agreement, receiving two years' probation and a $550 fine.
Approximately ten years later (Nov. 2005) Rambler was elected mayor of Wrightsville, Pennsylvania, assuming office January 2006.
In February 2006 the Commonwealth filed a quo warranto action under Article II, Section 7 to remove Rambler from office, arguing the federal felony constitutes an infamous crime.
The Superior Court held Rambler’s federal conviction was not infamous because the Pennsylvania analogue crime would be a misdemeanor, relying on a close Pennsylvanian offense’s grading.
This Court grants review to decide whether a foreign felony can be deemed infamous under Article II, Section 7 without automatic deferral to the foreign jurisdiction’s labeling; decision focuses on conduct and public trust rather than label alone.
The Court ultimately holds the federal crime here is infamous due to the conduct involving dishonesty and extortion through the mails, rejecting a bright-line rule tied to extraterritorial labeling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a federal felony extortion offense is an infamous crime under Article II, §7.	Commonwealth contends all felonies automatically disqualify.	Rambler argues the offense, graded as a misdemeanor in Pennsylvania, cannot be deemed infamous.	Federal felony deemed infamous; not barred by automatic labeling.
Whether Pennsylvania’s grading of a similar in-state offense should control infamy.	Commonwealth relies on closest Pennsylvania analogue as controlling.	Rambler argues external grading is irrelevant to infamy.	External grading cannot alone determine infamy; conduct analysis governs.
Whether due process and laches arguments affect disqualification.	Notions of timely action and due process support quo warranto.	Arguments not fully addressed below; raised later.	Remanded for consideration of due process and laches in the lower forum.

Griffin v. Commonwealth, 596 Pa. 558, 946 A.2d 674 (Pa. 2008) (felony broadly linked to infamy; distinctions between felonies and crimen falsi)
Commonwealth v. Baldwin, 561 Pa. 489, 751 A.2d 647 (Pa. 2000) (reaffirmed that crimen falsi concerns inform infamy)
Commonwealth v. Greenberg, 442 Pa. 411, 280 A.2d 370 (Pa. 1971) (federal offense involved in-office disqualification due to honesty concerns)
Hughes v. Pennsylvania, 516 Pa. 90, 532 A.2d 298 (Pa. 1987) (conduct akin to bribery supports disqualification)
State ex rel. Taborski v. Ill. Appellate Court, 50 Ill.2d 336, 278 N.E.2d 796 (Ill. 1972) (early common-law view linking infamous crimes to public trust)
Commonwealth ex rel. Desiderio v. Commonwealth, 698 A.2d 134 (Pa.Cmwlth. 1997) (ethics/public duty cases addressing Article II, §7 scope)