Jordan Spallone v. Pennsylvania State Police; Lauren Spallone v. Pennsylvania State Police

Summary

The Pennsylvania Commonwealth Court held that it has exclusive original jurisdiction over Whistleblower Law claims against the Pennsylvania State Police, a Commonwealth agency. The court concluded that such claims are remedial and are not actions in the nature of trespass subject to the statutory exception in Section 761(a)(1)(v) of the Judicial Code. It affirmed the trial court’s orders sustaining preliminary objections and directed transfer of the consolidated cases to the Commonwealth Court’s original jurisdiction.

Holdings

1. The Commonwealth Court has exclusive original jurisdiction over Whistleblower Law claims against the Commonwealth or its agencies because such claims fall within Section 761(a)(1)'s general grant of jurisdiction over civil actions against the Commonwealth government.
2. Whistleblower Law claims are not actions in the nature of trespass within Section 761(a)(1)(v); therefore, the exception does not divest the Commonwealth Court of original jurisdiction over the Spallones' claims.

Questions Presented

1. Whether the Commonwealth Court has exclusive original jurisdiction under Section 761(a)(1) of the Judicial Code over Pennsylvania Whistleblower Law claims seeking damages against the Commonwealth or a Commonwealth agency.
2. Whether the Section 761(a)(1)(v) exception for actions in the nature of trespass removes Whistleblower Law claims from the Commonwealth Court's original jurisdiction and places them in the courts of common pleas.

Disposition

affirmed