Scarnati, J.,et al, Aplts. v. Wolf, T., 3 MAP 2016

Governor Wolf attempted to return vetoed bills to the Pennsylvania House on July 10, 2014 and to invoke the "file-and-proclaim" procedure under Article IV, Section 15.
Appellants (Senate leaders: Scarnati, Corman, Costa) challenged the governor’s action, arguing the return was ineffective because of adjournment rules; the matter reached the Supreme Court of Pennsylvania on appeal from Commonwealth Court.
The Supreme Court majority held the governor’s veto attempt failed; Chief Justice Saylor concurred in that result but wrote separately on the interpretation of "General Assembly."
Saylor agreed the veto failed on the facts (both chambers were not in session that day), but disputed the majority’s broader holding that both chambers must be adjourned to prevent a gubernatorial return under Article IV, Section 15.
Saylor argued that only the adjournment of the originating chamber (the House, for bills originating there) can prevent return, noting other states’ decisions and practical governance concerns with requiring both chambers to be adjourned.
He suggested avoiding a definitive ruling on whether "General Assembly" in the last sentence of Section 15 means both chambers or just the originating house, preferring to defer that question until a case where the distinction is outcome-determinative.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the governor’s attempts to return vetoed bills and invoke file-and-proclaim failed on July 10, 2014	Appellants: Governor could not return bills because the General Assembly had adjourned; veto attempt failed	Governor: He validly returned the bills and could use file-and-proclaim if the General Assembly had adjourned	Court: Veto attempt failed on the facts (both chambers were not in session); concurring justice agreed on failure
Whether the term "General Assembly" in Article IV, Section 15 requires adjournment of both chambers or only the originating chamber to prevent return	Appellants: "General Assembly" should be read as the originating house is what matters; adjournment of that house prevents return	Governor/majority: Interpreted "General Assembly" as requiring adjournment of both chambers for file-and-proclaim to apply	Concurrence (Saylor): Disagreed with majority; argued only the originating chamber’s adjournment should prevent return, but would defer definitive ruling unless outcome depends on it

In re ‘An Act to Amend an Act Entitled ‘An Act Concerning Pub. Utils.’’, 84 A. 706 (N.J. 1912) (discusses adjournment of house of origin preventing executive return)
Opinion of the Justices, 175 A.2d 405 (Del. 1961) (treats adjournment of originating house as sufficient under similar constitutional text)
Commonwealth v. Novak, 150 A.2d 102 (Pa. 1959) (constitutional provisions should avoid impractical or unreasonable results)
Jubelirer v. Pa. Dep’t of State, 859 A.2d 874 (Pa. Cmwlth. 2004) (Pennsylvania Constitution interpreted to preserve checks and balances)
In re Fiori, 673 A.2d 905 (Pa. 1996) (courts should avoid unnecessary constitutional holdings)
Hunt v. Pa. State Police, 983 A.2d 627 (Pa. 2009) (courts have the final say on constitutional matters; legislatures can correct statutory interpretations)