Pennsylvania State Ass'n of Jury Commissioners v. Commonwealth
619 Pa. 369
| Pa. | 2013Background
- Act 108 of 2011 amended the County Code to (i) abolish the office of jury commissioner and (ii) authorize online auctions of surplus farm and personal property.
- HB 1644 originally amended Article XVIII, Section 1805 and, during Senate consideration, was amended to add Section 401(f) authorizing abolition of the jury commissioner by resolution.
- Act 108 was enacted after the Senate approved the amendments and the Governor signed it into law, becoming Act 108 of 2011.
- Jury commissioners and the Pennsylvania State Association of Jury Commissioners challenged Act 108 as unconstitutional under multiple provisions, with the County Commissioners Association of Pennsylvania intervening as appellee.
- Commonwealth Court en banc held that Act 108 satisfied the single subject rule, and dismissed the action; the Supreme Court reversed on the single subject issue, finding a constitutional violation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Act 108 violate Article III, Section 3 (single subject rule)? | PSAJC argues 'powers of county commissioners' is too broad and non-germane. | Appellee argues the two provisions share a unified theme within county governance. | Act 108 violates the single subject rule. |
| Does Act 108 violate the separation of powers by mixing executive and legislative functions? | Appellants contend the unaffiliated topics reflect separate powers (executive vs legislative). | Appellee contends germane integration under county governance. | Rationale not necessary to decide because single subject violation controls. |
| Does Act 108 violate due process via vagueness? | Appellants argue void-for-vagueness concerns. | Appellee defends Act 108 as sufficiently clear. | No need to resolve given single subject ruling. |
Key Cases Cited
- City of Philadelphia v. Commonwealth, 838 A.2d 566 (Pa. 2003) (set germaine standard for single-subject analysis and limits on omnibus bills)
- Pennsylvanians Against Gambling Expansion Fund, Inc. v. Commonwealth, 877 A.2d 383 (Pa. 2005) (germaneness limits of single-subject analysis; dangers of overbreadth)
- PAGE, 877 A.2d 383 (Pa. 2005) (gaming act as narrow subject example under single subject rule)
- Spahn v. Zoning Board of Adjustment of the City of Philadelphia, 977 A.2d 1132 (Pa. 2009) (upheld statute altering home rule provisions; compared breadth to omnibus bills)
- City of Phila. v. Schweiker, 817 A.2d 1217 (Pa. Cmwlth. 2003) (limitations on scope of acts when amending within a single article)
- Commonwealth ex rel. Woodruff v. Humphrey, 136 A.213 (Pa. 1927) (early germane analysis restricting multi-subject bills)
- Yardley Mills Co. v. Bogardus, 185 A.218 (Pa. 1936) (non-germane subjects invalidate omnibus provisions)
- DeWeese v. Weaver, 824 A.2d 364 (Pa. Cmwlth. 2003) (limits on broad themes in single-subject analysis)
- Pa. Ass’n of Rental Dealers v. Com., 554 A.2d 617 (Pa. Cmwlth. 1989) (caution against expansive ‘economic well-being’ themes)