The Commonwealth Court of Pennsylvania has affirmed the transfer of whistleblower claims filed by Jordan and Lauren Spallone against their employer, the Pennsylvania State Police (PSP). The court ruled that the trial court did not have jurisdiction over the claims, which are based on the Pennsylvania Whistleblower Law. This decision affects the Spallones and potentially other employees seeking to file similar claims against state entities.
The Spallones, who are husband and wife, both work for the PSP. They filed their complaints in August 2023, alleging that they faced retaliation for reporting wrongdoing within the agency. The trial court initially ruled that it lacked subject matter jurisdiction over their claims and transferred the cases to the Commonwealth Court. The Spallones appealed this decision, leading to the recent ruling.
Background
Jordan Spallone began his career with the PSP in 2003 and became a sergeant in 2016. In 2020, he reported that a superior officer had instructed him to drop charges against individuals involved in an incident and to alter investigative findings. After reporting his concerns, he faced what he believed was an improper internal investigation and was subjected to attempts to remove him from his command. He also claimed that he was denied promotions he had earned.
Lauren Spallone, who joined the PSP in 2009 and became a sergeant in 2019, alleged that she also faced retaliation. She claimed that she was denied promotions based on her husband’s whistleblowing actions, with a supervisor reportedly stating that it was because she was married to him. Both Spallones sought damages exceeding $30,000, along with promotions and restoration of lost pay.
The PSP responded to their claims by filing preliminary objections, arguing that whistleblower claims against state entities must be brought in the Commonwealth Court, not in trial-level courts. The trial court agreed and transferred the cases, leading to the Spallones' appeal.
The Ruling
The Commonwealth Court, led by Judge Christine Fizzano Cannon, upheld the trial court's decision. The court stated, "The trial court correctly sustained the PSP’s preliminary objections challenging the trial court’s subject matter jurisdiction over this dispute and transferred the Spallones’ cases to this Court’s original jurisdiction." The ruling emphasized that claims against the Commonwealth or its agencies for money damages based on tort theories must be directed to trial-level courts, while whistleblower claims against state entities fall within the exclusive jurisdiction of the Commonwealth Court.
The court referenced previous cases, such as Balshy v. Rank and Hill v. Department of Environmental Protection, to support its decision. It highlighted that the Whistleblower Law is primarily a remedial measure intended to protect employees who report wrongdoing, distinguishing it from traditional tort claims.
Impact
This ruling clarifies the jurisdictional boundaries for whistleblower claims against state entities in Pennsylvania. By affirming that such claims must be brought in the Commonwealth Court, it sets a precedent that could influence how similar cases are handled in the future. Employees seeking to file whistleblower claims against state agencies will need to navigate this jurisdictional landscape carefully.
The decision may also affect other state employees who are considering reporting wrongdoing, as it reinforces the legal framework surrounding whistleblower protections and the appropriate venues for pursuing claims. It underscores the importance of understanding the specific legal avenues available for different types of claims against government entities.
What's Next
The Spallones' case has been transferred to the Commonwealth Court, where it will be adjudicated under its original jurisdiction. It remains to be seen whether the Spallones will pursue further legal action or if they will seek to resolve their claims within the Commonwealth Court system. Details were not available in the court filing regarding any related cases or potential appeals.