J. Patterson and A. Ash v. The Commonwealth of PA and L. Krasner, in his official capacity as the D.A. of Phila., 284 M.D. 2023

Jamar Patterson and Abron Ash were denied or terminated from employment as private security officers due to prior felony convictions, pursuant to Section 13 of the Private Detective Act of 1953.
Section 13 of the Act prohibits security companies from hiring individuals with certain criminal convictions and requires employees to attest to no such convictions.
Patterson’s job offer was rescinded, and Ash was terminated from his job, with both attributing this to the statutory employment ban.
Petitioners filed a facial and as-applied constitutional challenge to the statute under Article I, Section 1 of the Pennsylvania Constitution, seeking declaratory and injunctive relief.
The named respondents were the Commonwealth of Pennsylvania and Larry Krasner, in his official capacity as the District Attorney of Philadelphia.
Both Respondents filed preliminary objections, arguing they were not proper parties.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the Commonwealth an indispensable/responding party?	Commonwealth’s participation is necessary to challenge the statute.	The Commonwealth is not involved in enforcement or direct administration.	Commonwealth is not indispensable; dismissed from case.
Is DA Krasner a proper respondent?	DA Krasner is responsible for enforcing the statute in Philadelphia.	Only responsible if the violation occurs where the license is held (Montgomery County).	Issue not reached due to lack of jurisdiction.
Does the Commonwealth Court have jurisdiction?	Jurisdiction is proper based on claims against Commonwealth and DA Krasner.	Without the Commonwealth as a party, jurisdiction does not exist over remaining claims.	Lacks jurisdiction; case transferred to Common Pleas.
Can relief be obtained against named respondents?	Relief sought requires enjoining these entities from enforcing the statute.	Neither can provide the requested relief under the Act.	Relief cannot be afforded against named respondents.

Phantom Fireworks Showrooms, LLC v. Wolf, 198 A.3d 1205 (Pa. 2018) (Commonwealth not indispensable merely because a statute may be declared unconstitutional)
Stedman v. Lancaster County Board of Commissioners, 221 A.3d 747 (Pa. Cmwlth. 2019) (Indispensable party determination requires a direct interest in enforcement or administration by the Commonwealth)