Commonwealth v. Homka

1 Pa. D. & C.2d 685, 1954 Pa. Dist. & Cnty. Dec. LEXIS 256
CourtPhiladelphia County Court of Quarter Sessions
DecidedAugust 20, 1954
StatusPublished

This text of 1 Pa. D. & C.2d 685 (Commonwealth v. Homka) is published on Counsel Stack Legal Research, covering Philadelphia County Court of Quarter Sessions primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Homka, 1 Pa. D. & C.2d 685, 1954 Pa. Dist. & Cnty. Dec. LEXIS 256 (Pa. Super. Ct. 1954).

Opinion

Crumlish, J.,

The very narrow question here for determination is the following: Does a court of quarter sessions of the peace have the authority and jurisdiction to issue a writ of prohibition against a magistrate?

Mr. Chief (then) Justice Horace Stern has recently-supplied this excellent definition of the writ under consideration :

“Prohibition is a common law writ of extremely ancient origin, — so ancient, indeed, that several forms for its use are set forth in Glanville, the earliest known treatise on English law (1187); in the following century it was recognized by Bracton as an established part of the common law. Being a prerogative writ of the king it was originally employed exclusively by the Court of King’s Bench, but subsequently issued out of the Courts of Chancery, Common Pleas and Exchequer as well. Its principal purpose is to prevent an inferior judicial tribunal from assuming a jurisdiction with which it is not legally vested in cases where damage and injustice would otherwise be likely to follow from such action. It does not seek relief from any alleged wrong threatened by an adverse party; indeed it is not a proceeding between private litigants at all but solely between two-courts, a superior and an in[686]*686ferior, being the means by which the former exercises superintendence over the latter and keeps it within the limits of its rightful powers and jurisdiction”: Carpentertown Coal & Coke Company v. Laird, 360 Pa. 94, 97-98 (1948).

Writ of prohibition is also defined as “that process by which a superior court prevents inferior courts, tribunals, officers, or persons from usurping or exercising a jurisdiction with which they have not been vested by law”: 50 C. J. 654, §1.

Defendant, Angelina Homka, has applied to this court for such a writ against Magistrate E. David Reiser, and the district attorney’s office has challenged, preliminarily, defendant’s right to proceed with such a writ in this court. There is no specific Commonwealth constitutional provision concerning the nature and scope of this writ, nor any legislative clarification regarding it, and there is no express statutory provision for its use.

It is defendant’s contention that the quarter sessions court of the peace has inherent power to issue writs of prohibition to a magistrate. This proposition, her learned counsel says, “is based upon an analysis of the express language of article V of the Constitution of Pennsylvania, the schemata of the judiciary system as therein set forth, the Pennsylvania statutory enactments relative to their jurisdiction and powers of the various courts of superior and inferior jurisdiction; the enactments of the colonial assembly antedating the Constitution of 1790 and, in turn, the necessary reference of all of the aforesaid to the common law of England, which is part of the law of Pennsylvania: Act of January 28, 1777, 1 Sm. L. 429”.

Our Supreme Court has made it crystal clear that there is no doubt of its power to issue such a writ, a power derived from the Act of May 22,1722, sec. XIII, 1 Sm. L. 131, 140, which vested in the Supreme Court [687]*687all the jurisdictions and powers of the three superior courts at Westminster, namely,- the King’s Bench, the Common Pleas and. the Exchequer. Inherent in the court of the King’s Bench was the power of general superintendency over inferior tribunals, a power which was of ancient inception and recognized by the common law from its very beginning: Carpentertown Coal & Coke Co. v. Laird, supra, p. 99; First Congressional District Election, 295 Pa. 1; McNair’s Petition, 324 Pa. 48; Park’s Petition, 329 Pa. 60; Philadelphia County Grand Jury Investigation Case, 347 Pa. 316; cf. Dauphin County Grand Jury Investigation Proceedings (No. 1), 332 Pa. 289.

Defendant, contends, as we understand her argument, that (a) at no time has the Supreme Court declared the writ to be one exclusively within its jurisdiction and that, (b) the quarter sessions court also historically has jurisdiction to issue the writ of prohibition.

This raises two questions: (1) Did the ancient quarter sessions court of the peace have express or inherent authority to issue writs of prohibition and if so, have the courts of quarter sessions in Pennsylvania inherited such authority?; (2) If question no. 1 is answered in the negative, have the courts of quarter sessions of the peace in Pennsylvania been vested with such authority by reason of Colonial Assembly enactments or constitutional provisions?

The jurisdiction of the ancient quarter sessions courts was never on a parity with that of the King’s Bench. See Chitty’s Criminal Law, vol. I, 3rd Am. ed., 133, where it was said:

“It is not, however, proposed to consider every tribunal before which criminal matters may possibly arise, but only those courts which are more frequently resorted to for the trial and punishment of the offenders. Of the inferior kind, are the general and quarter [688]*688sessions of the peace. Of the superior order, the assizes, including the commissions of oyer and terminer, general gaol delivery, assize and Nisi Prius — courts under special commissions — the Admiralty sessions — and the court of King’s Bench.”

See also Stephen’s History of the Criminal Law of England, vol. I, p. Ill, et seq.; Holdsworth’s A History of English Law, 3rd ed., vol. I, p. 292, et seq.

The court of quarter sessions originally received its jurisdiction to hear and determine indictments from the statutes 18 Edw. 3. st. 2, c. 2, and 34 Edw. 3. c. 1. Eventually, the court assumed jurisdiction in “ ‘all felonies, poisonings, enchantments, sorceries, arts magic, trespasses, forestallings, regratings, engrossing, and extortions, and all other crimes and offences of which such justices may or ought lawfully to inquire’, subject to this caution, ‘that if a case of difficulty shall arise they shall not proceed to give judgment except in the presence of some justice of one of the benches or of assize,’ ”: Stephen, supra, 114. The courts of quarter sessions of the peace could not exercise general criminal jurisdiction, but were confined by specific statutes and by authority granted by superior commissions to the trial of only certain offenses. Nowhere does it appear that this court had power over any inferior tribunals or law enforcement officers such as power to issue a writ of prohibition.

Since the quarter sessions courts were inferior courts it seems proper to postulate that they were without jurisdiction to issue writs of prohibition. However, Holdsworth tells us that “A prohibition is a writ issuing properly only out of the court of King’s Bench, being the king’s prerogative writ; but, for the furtherance of justice, it may now also be had in some cases out of the court of Chancery, Common Pleas, or Exchequer; directed to the judge and parties of a suit in any inferior court, commanding them to cease from [689]*689the prosecution thereof, upon a suggestion that either the cause originally, or some collateral matter arising therein, does not belong to that jurisdiction”: Holds-worth’s A History of English Law, 3rd ed., vol. I, 228. (Italics supplied.)

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Related

Park's Petition
196 A. 495 (Supreme Court of Pennsylvania, 1938)
McNair's Petition
187 A. 498 (Supreme Court of Pennsylvania, 1936)
Philadelphia County Grand Jury Investigation Case
32 A.2d 199 (Supreme Court of Pennsylvania, 1943)
Carpentertown Coal & Coke Co. v. Laird
61 A.2d 426 (Supreme Court of Pennsylvania, 1948)
First Congressional District Election
144 A. 735 (Supreme Court of Pennsylvania, 1928)
Dauphin County Grand Jury Investigation Proceedings
2 A.2d 783 (Supreme Court of Pennsylvania, 1938)

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Bluebook (online)
1 Pa. D. & C.2d 685, 1954 Pa. Dist. & Cnty. Dec. LEXIS 256, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-homka-paqtrsessphilad-1954.