Stackhouse v. Commonwealth

Summary

The Supreme Court of Pennsylvania considered whether the Commonwealth Court or the Dauphin County Court of Common Pleas had jurisdiction over claims arising from an internal Pennsylvania State Police investigation. The Court held that the complaint's substance was an action in the nature of trespass, despite one count seeking declaratory and injunctive relief, and therefore original jurisdiction lay in the court of common pleas. The case was remanded for further proceedings.

Holdings

1. Because the core of Stackhouse's complaint was an action in the nature of trespass, original jurisdiction lay in the court of common pleas under 42 Pa.C.S. § 761(a)(1)(v), notwithstanding that one count was labeled as seeking declaratory and injunctive relief.
2. The Commonwealth Court could not retain the action through ancillary jurisdiction when the claims at the core of the complaint were expressly excluded from its original jurisdiction by § 761(a)(1)(v).

Questions Presented

1. Whether the Commonwealth Court or the Dauphin County Court of Common Pleas had original jurisdiction over Stackhouse's complaint.
2. Whether the inclusion of declaratory and injunctive relief transformed a complaint otherwise sounding in trespass into a matter within the Commonwealth Court's original jurisdiction.
3. Whether the Commonwealth Court had ancillary jurisdiction over the tort claims because they arose from the same facts as the equitable claims.

Disposition

remanded