Background - In July 2014 the General Assembly presented the General Appropriations Act (GAA) and Fiscal Code Amendments (FCA) to Governor Corbett; the House adjourned the day before the Governor acted. - On July 10, 2014 the Governor signed both bills but used the line‑item veto to disapprove portions of the GAA and corresponding provisions of the FCA. - The Governor’s office filed the bills and veto objections with the Secretary of the Commonwealth and issued a press release listing vetoed items; the House did not record objections or reconvene to reconsider. - A group of state senators filed for review in Commonwealth Court arguing (1) the Governor failed to follow Article IV §15’s return/proclamation requirements because the House adjournment prevented a proper return and the press release was not the required public proclamation, and (2) the FCA is not a “bill making appropriations” subject to a line‑item veto. - Commonwealth Court denied summary relief; the Pennsylvania Supreme Court granted review and reversed as to Count I, holding the Governor’s partial vetoes were ineffective because he did not comply with Article IV §15. - The Supreme Court held (a) an adjournment that prevents return must be an adjournment of the General Assembly (both chambers), and (b) the July 10 press release did not satisfy the Constitution’s filing‑and‑public‑proclamation requirement because it failed to state that the bills and objections had been filed with the Secretary and lacked required formality. ### Issues | Issue | Plaintiff's Argument | Defendant's Argument | Held | |---|---:|---:|---| | Whether an adjournment prevented the Governor’s return under Art. IV §15 | An adjournment of the originating chamber (House) prevented return and triggers the file‑and‑proclaim rule | Governor: return to a House agent (e.g., Parliamentarian) is valid; adjournment question is fact‑dependent | The adjournment referenced is an adjournment of the General Assembly (both chambers); here both chambers were adjourned, so the Governor could not constitutionally return the bills. | | Whether the Governor’s July 10 press release satisfied the §15 public proclamation requirement | Senators: proclamation must notify that the bill and objections were filed with the Secretary and be formal | Governor: form is discretionary; press release gave public notice so it suffices | Press release failed: it omitted notice that filings were made with the Secretary and lacked required formality; thus §15’s proclamation requirement was not met. | | Whether the Fiscal Code Amendments (FCA) are subject to the line‑item veto under Art. IV §16 | Senators: FCA does not "make appropriations of money" so it is not subject to line‑item veto | Governor: §16 applies to any statutory directions that spend specific sums, including companion fiscal code provisions | Court did not decide this issue because the vetoes were invalid under §15; left for future resolution. | ### Key Cases Cited Jubelirer v. Rendell, 598 Pa. 16, 953 A.2d 514 (Pa. 2008) (construed the scope of items subject to gubernatorial line‑item veto) The Pocket Veto Case, 279 U.S. 655 (U.S. 1929) (held delivery to an agent during a congressional adjournment does not satisfy presentment/return rules because it defeats public notice) Wright v. United States, 302 U.S. 583 (U.S. 1938) (distinguished mid‑session recess from an adjournment preventing return and approved return to an agent when Congress had not adjourned) Commonwealth ex rel. Attorney Gen. v. Barnett, 199 Pa. 161, 48 A. 976 (Pa. 1901) (discussed the Governor’s role in the lawmaking/presentment process)