The Supreme Court of Pennsylvania

Caldwell v. Jaurigue

 This case clarified who is legally responsible for child support in Pennsylvania when someone who is not a biological or adoptive parent has acted like one.

In this case, a woman began dating her boyfriend while she was pregnant. The boyfriend lived with the woman and her child for more than six years and helped raise the child, but he never legally adopted her. When the woman passed away in 2019, the child went to live with her biological father.

After the mother’s death, the boyfriend asked the court for partial custody of the child, saying he had acted “in loco parentis,” meaning he had been like a parent for the child’s entire life. The court agreed and gave him partial custody, but the biological father disagreed and appealed that decision.

While that custody appeal was still in progress, the father filed another case asking the boyfriend to pay child support. The boyfriend objected, and the trial court ruled that he didn’t have to pay. The father then appealed to the Pennsylvania Superior Court, which reversed the decision and said the boyfriend did owe child support. The boyfriend took the case to the Pennsylvania Supreme Court, which agreed to hear it and ultimately ruled that the boyfriend did not owe child support to the father.

This ruling is important because it clearly separates emotional or caregiving roles from legal parental responsibilities. Before this case, it wasn’t clear whether someone who stood “in loco parentis” could be required to pay child support. The Pennsylvania Supreme Court decided for the first time that a person who only has partial custody and no legal parental status is not responsible for paying support. 

This ruling protects people who are helping to raise children, but who aren’t their legal parents, from being forced to pay child support. At the same time, it shows that anyone who wants full parental rights must take legal steps like adoption. 

Read the decision here, 

Socko v. Mid-Atlantic Systems of CPA, Inc.

In Pennsylvania, for a contract to be valid, both sides must give something of value, such as money, benefits, or a new job. This principle is known as Consideration. 

In this case, the plaintiff, David Socko, worked for Mid-Atlantic Systems, a company that sells basement waterproofing services. When he was first hired, he signed a noncompete agreement stating that after leaving the company, he wouldn’t work for a competitor for two years.  

Later, while still employed, the company asked him to sign a new noncompete agreement, but he received no additional benefit, other than keeping his job. 

When Socko eventually left the company and took a job with a competitor, Mid-Atlantic sued him, claiming he had violated the non-compete agreement. Socko argued that the agreement was invalid because he didn’t receive any consideration when he signed it. 

The Pennsylvania Supreme Court agreed with Socko. The Court ruled that a noncompete agreement signed during existing employment is not enforceable unless the employee receives new consideration. 

This ruling is important because it protects Pennsylvania employees from unfair noncompete agreements that offer them nothing in return. It made clear that employers cannot require workers to sign new restrictions unless they provide additional benefits or compensation.

Read the decision here. 

Schmidt v. Schmidt, Kirifides & Rassias, PC

In this case, Mark Schmidt, an attorney, injured his back at work in 2017. His doctor prescribed CBD oil to help manage his pain and reduce his need for opioids. Schmidt bought the CBD products himself and asked his employer to reimburse him under the Pennsylvania Workers’ Compensation Act. The employer refused, arguing that CBD oil isn’t an approved “medicine or supply” because it’s sold over the counter and not regulated by the FDA.  

A workers’ compensation judge originally sided with Schmidt, ordering the employer to reimburse him for the cost of the CBD oil. However, the employer appealed, and the Workers’ Compensation Appeal Board reversed that decision. Schmidt then took the case to the Pennsylvania Commonwealth Court, which ruled in his favor. The employer appealed again, and the Pennsylvania Supreme Court ultimately agreed with the Commonwealth Court, deciding that Schmidt was entitled to reimbursement. 

The Supreme Court decided that “medicines and supplies” under the Workers’ Compensation Act included any items prescribed by a healthcare provider as part of a treatment plan for a work-related injury, even if those items aren’t FDA-approved or purchased from a pharmacy.  

This ruling is important because it expands what counts as reimbursable medical treatment under Pennsylvania workers’ compensation law and established that employers may have to cover alternative treatments, like CBD oil, if prescribed by a doctor for a work-related injury. 

Read the decision here.