Ivy Hill Congregation of Jehovah’s Witnesses v. Commonwealth, Dep’t of Hum. Servs., 2024 Pa. LEXIS 198 (S. Ct. February 13, 2024) (Todd, C.J.).
Justice Todd, writing for the Supreme Court, held that the Commonwealth Court, in dismissing a petition filed by the Jehovah’s Witnesses, under the Declaratory Judgments Act, violated the Coordinate Jurisdiction Rule. Hence, Commonwealth Court’s order was vacated and the matter remanded to that court for further proceedings consistent with the opinion.
The declaratory judgment action indicated that elder receive confessions which may involve child abuse, which would implicate mandatory reporting requirements of Child Protective Services Law. The individuals may be deemed to be mandatory reporters under 23 Pa. C.S. § 6311(a). Mandatory reporters include clergymen or other religious organizations. Otherwise privileged communications between a mandated reporter and a patient or client are not privileged if they involve child abuse. However, no clergyman who, during the course of his duties, acquired information secretly and in confidence shall be compelled to disclose that information in any legal proceeding, trial or investigation. Here, the Jehovah’s Witnesses sought a declaration and its elders were protected under § 6311.1(b) and did not need to report. In a complicated procedural history, the Commonwealth Court ordered that appellant’s petition for review and motion for summary judgment were dismissed for lack of jurisdiction. In the present appeal, appellant argued that the Commonwealth Court erred in holding it did not have jurisdiction. The court said that appellant is not entitled to relief on the lack of jurisdiction claim. However, it was claimed that the court violated the coordinate jurisdiction rule and law of the case doctrine. The Supreme Court vacated the lower court’s order dismissing the petition and its motion for summary relief. The court’s determinations that appellant did not have standing and that a grant of declaratory relief would not terminate the controversy, violated the Coordinate Jurisdiction Rule.
