Commonwealth of Pennsylvania, Appellant v. Terrell Laron Walker, Damaire Wallace, Quashaad Rodney James and Maurice…

Summary

The Supreme Court of Pennsylvania reversed the Superior Court's order quashing the Commonwealth's single notice of appeal from a suppression order that resolved four codefendants' motions to suppress at four separate docket numbers. The Court agreed that the Official Note to Pa.R.A.P. 341 imposes a bright-line duty to file separate notices of appeal whenever a single order resolves issues arising on more than one docket, but held that the 2013 amendment announcing that duty operates prospectively only, because it contradicted decades of case law in which such appeals were disfavored yet seldom quashed. The case was remanded for the Superior Court to reach the merits, and the Court directed the Appellate Procedural Rules Committee to amend the Official Note, or Rule 341 itself, accordingly. Justice Mundy concurred in the result but dissented from the prospective bright-line holding, favoring continued case-by-case application of the General Electric three-part test.