Pennsylvania State Ass'n of Jury Commissioners v. Commonwealth
621 Pa. 360
| Pa. | 2013Background
- Act 4 of 2013 amended The County Code to allow governing bodies of certain counties to adopt a resolution abolishing the elected office of jury commissioner, effective at the end of current terms.
- Plaintiffs (Pennsylvania State Association of Jury Commissioners and elected jury commissioners from multiple counties) sued in Commonwealth Court seeking declaratory and injunctive relief, alleging Act 4 violated: (1) the state separation of powers / unified judicial system (Art. V), (2) the nondelegation doctrine (Art. II), and (3) the First Amendment.
- The Commonwealth Court (three-judge panel) granted summary relief to defendants and dismissed plaintiffs’ challenges; plaintiffs appealed to the Pennsylvania Supreme Court.
- The Supreme Court considered whether jury commissioners are "judicial officers" subject to the Court’s supervisory authority or statutory county officers subject to legislative abolition; it also considered delegation and First Amendment claims.
- The Supreme Court affirmed the Commonwealth Court: (1) the two elected jury commissioners are county officers / "county staff," not judicial officers; (2) Act 4 does not unlawfully delegate legislative power because it does not eliminate the jury selection commission as a body or strip the commission’s statutory duties; and (3) candidates have no constitutionally protected right to hold the office such that Act 4 violates the First Amendment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the office of jury commissioner is a "judicial office" under Art. V (separation of powers) | The office has evolved into a judicial function via the Judicial Code and is integral to the unified judiciary, so legislature cannot abolish it | Jury commissioners are statutorily "county officers"/"county staff," not judicial officers; the Supreme Court lacks supervisory authority over them | Held: Not a judicial office; Act 4 does not violate separation of powers (statutory and constitutional text control) |
| Whether Act 4 impermissibly delegates legislative power to county governing bodies (Art. II) | Act 4 delegates control of a vital judicial function without standards; counties could create disparate jury-selection systems | Act 4 only abolishes the two elected positions, leaving the jury selection commission and president judge’s duties intact; Judicial Code standards remain binding | Held: No improper delegation; Act 4 does not eliminate the commission’s powers or permit opting out of Judicial Code requirements |
| Whether Act 4 violates First Amendment rights of candidates on the 2013 ballot | Candidates expended effort in primary and ballot access; abolishment abridges their rights | There is no constitutionally protected individual right to hold elective municipal office; prior authority rejects a property or First Amendment claim | Held: No First Amendment violation; candidates have no protected right to the office |
| Whether plaintiffs were entitled to injunctive/declaratory relief on these claims | (Combined above) | (Combined above) | Held: Summary relief properly denied to plaintiffs; Commonwealth Court affirmed |
Key Cases Cited
- Snyder v. Unemployment Compensation Bd. of Review, 509 Pa. 438, 502 A.2d 1232 (recognition of Supreme Court’s general supervisory authority over courts)
- Wajert v. State Ethics Comm’n, 491 Pa. 255, 420 A.2d 439 (separation-of-powers constraints on legislation affecting judicial functions)
- Beckert v. Warren, 497 Pa. 137, 439 A.2d 638 (distinguishing county staff from judicial officers; court supervisory authority excludes county staff)
- In re Administrative Order No. 1-MD-2003, 594 Pa. 346, 936 A.2d 1 (county clerks/prothonotaries perform ministerial, non-judicial functions)
- Pennsylvanians Against Gambling Expansion Fund v. Commonwealth, 583 Pa. 275, 877 A.2d 383 (nondelegation framework: basic policy by legislature and adequate standards required)
- Sweeney v. Tucker, 473 Pa. 493, 375 A.2d 698 (no constitutionally protected property interest in holding elected office)
- Lyons v. City of Pittsburgh, 137 Pa.Cmwlth. 330, 586 A.2d 469 (municipal officer has no right to continue in office absent constitutional or statutory protection)
- Commonwealth ex rel. Elkin v. Moir, 199 Pa. 534, 49 A. 351 (municipal offices not constitutionally protected as a private right)