D. Corbo v. Chester County, & D.A. D. Ryan in her Official Capacity

CourtCommonwealth Court of Pennsylvania
DecidedApril 10, 2025
Docket830 C.D. 2023
StatusPublished

This text of D. Corbo v. Chester County, & D.A. D. Ryan in her Official Capacity (D. Corbo v. Chester County, & D.A. D. Ryan in her Official Capacity) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
D. Corbo v. Chester County, & D.A. D. Ryan in her Official Capacity, (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Daniel Corbo, : Appellant : : v. : No. 830 C.D. 2023 : Argued: November 7, 2024 Chester County, and District Attorney : Deb Ryan in her Official Capacity :

BEFORE: HONORABLE PATRICIA A. McCULLOUGH, Judge HONORABLE STACY WALLACE, Judge HONORABLE MARY HANNAH LEAVITT, Senior Judge

OPINION BY JUDGE WALLACE FILED: April 10, 2025

Daniel Corbo (Corbo), a police officer for East Pikeland Township Police Department (Township), appeals the order of the Court of Common Pleas of Chester County (trial court), docketed July 5, 2023 (Order), which granted Chester County, and District Attorney Deb Ryan in her Official Capacity’s (collectively, the District Attorney) Motion for Judgment on the Pleadings (Motion) and dismissed Corbo’s Complaint. After review, we reverse and remand. BACKGROUND On October 28, 2020, Corbo initiated this action by filing a Writ of Summons with the trial court. Reproduced Record (R.R.) at 8a. On December 14, 2020, Corbo filed a Complaint against the District Attorney. Id. at 15a. In his Complaint, Corbo alleges the District Attorney placed Corbo on a list, which he asserts is “a ‘blacklist’ maintained by the [District Attorney] that results in anyone on the list never being called to testify in court and in fact being prevented by the [District Attorney] from testifying in any court in [Chester County].” Id. at 16a. Corbo’s placement on this “list” prevents Corbo from performing substantial portions of his job because police officers are often required to testify. Id. Township informed Corbo that if he remains on the “list,” he cannot perform his job, and thus Township will terminate his employment. Id. at 17a. In his Complaint, Corbo indicates the District Attorney’s decision to put him on the “list” was made without “due process of law, both substantive and procedural, in violation of the United States Constitution and the Pennsylvania Constitution.” Id. Corbo maintains the District Attorney failed to record any proceedings leading to her decision, failed to call any witnesses, failed to offer any witnesses for cross- examination, and failed to hold a hearing before making her decision to add Corbo to the “list.” Id. Additionally, Corbo contends the District Attorney acted “as both prosecutor and judge, improperly commingling prosecutorial and adjudicative functions.” Id. Corbo indicates the District Attorney’s decision to put him on her “list” deprived him of his right to engage in his occupation as a police officer. Id. Corbo requests the court “overturn the Decision made” by the District Attorney or, alternatively, “provide a de novo hearing.” Id. at 18a-19a. On January 15, 2021, the District Attorney filed preliminary objections to Corbo’s Complaint, which the trial court overruled on May 2, 2022. Id. at 25a, 118a. On May 22, 2022, the District Attorney filed an Answer and New Matter. Id. at 164a. In her Answer, the District Attorney denied “blacklisting” Corbo, and she asserted she “correctly determined that [Corbo] was unfit to testify as a witness due to his improper conduct in or about November 2015 as a police officer in [Township].” Id. at 166a. She alleged that in 2015, Corbo provided confidential

2 information about a criminal investigation to his ex-girlfriend whose ex-husband was the subject of that criminal investigation. Id. When county detectives later interviewed Corbo about the improper disclosure, the District Attorney contends Corbo “provided inaccurate and/or false statements to the [d]etectives.” Id. Further, in her Answer, the District Attorney asserted she provided Corbo adequate notice and an opportunity to present his position as to why he should be allowed to testify. Id. After Corbo presented his position, he and his attorney entered a Proffer Agreement. Id. Subsequently, Corbo and his attorney met with representatives of the District Attorney’s Office, Corbo’s counsel argued on his behalf, and Corbo submitted letters of recommendation. Id. After this meeting, the District Attorney’s Office notified Corbo, Corbo’s attorney, and Corbo’s supervisor of the District Attorney’s decision that Corbo would not be permitted to testify, but that he could apply for reinstatement in two years. Id. Corbo filed his Answer to the District Attorney’s New Matter on July 6, 2022. Id. at 232a. In his Answer, Corbo denied the District Attorney’s assertion that a “Do Not Use” list does not exist. Id. Corbo admitted that in November 2015, he received an email containing a bulletin from another police department (Bulletin) at his work email address. Id. The Bulletin identified a suspect in a burglary and requested officers not make contact with the suspect. Id. Corbo admitted he sent the email containing the Bulletin to an ex-girlfriend, who almost immediately forwarded the email to the named suspect. Id. County detectives interviewed Corbo about the disclosure of the email. Id. Corbo contends he told the county detectives he did not use his official police email account to communicate with his ex-girlfriend, and while he agrees this was inaccurate, he explains that at the time, his personal and work emails were tied together. Id. Additionally, Corbo admits to telling the county

3 detectives he sent the communication to his ex-girlfriend about the investigation approximately “a month” after receiving the Bulletin, and while he agrees this was inaccurate, he explains it had been several months after he sent the email before he estimated when he sent it. Id. On September 1, 2022, the District Attorney filed her Motion. The trial court issued its Order granting the District Attorney’s Motion and dismissing Corbo’s Complaint. In its Memorandum Opinion,1 the trial court found the following facts:

Corbo is a police officer in East Pikeland Township, Chester County, Pennsylvania. While on active duty, on or about November 2015, [Corbo] provided confidential information regarding a criminal investigation to his ex-girlfriend, whose ex-husband was the subject of the criminal investigation. The information was for law enforcement only. [Corbo’s] ex-girlfriend did provide the confidential information to her ex-husband. [Corbo] was ultimately interviewed by County Detectives regarding the improper disclosure by [Corbo]. During the interview, [Corbo] was inaccurate in his statements. On September 28, 2020, the District Attorney notified [Corbo] and his Attorney [that Corbo] would not be called to testify in any proceeding, unless exceptional, for two (2) years. It could be revisited after the two years. Thus, [Corbo] was placed on Giglio[2] “Do [N]ot [U]se” status, not a Giglio “Do [N]ot [U]se” list. Apparently, Corbo was not removed after two years and would stay on a “Do [N]ot [U]se” status approximately until September 28, 2024.

R.R. at 474a. Based on these facts, the trial court concluded the District Attorney “has the executive power to decide not to use [Corbo] in this case, and in fact has the power

1 The trial court incorporated and submitted this Opinion and Order in accordance with Pa.R.A.P. 1925(a) rather than file a new opinion. Trial Court’s Opinion, 12/5/23.

2 “Giglio” references the case of Giglio v. United States, 40 U.S. 150 (1972). See discussion infra pp. 12-13.

4 to use any witness in a criminal proceeding.” Id. at 474a. The trial court explained Corbo’s actions of providing confidential information regarding a criminal investigation to a friend “seem[] to be an egregious action,” and the “sanctions by the District Attorney give[ Corbo] the ability to get removed from a ‘Do [N]ot [U]se’ status and allow [Corbo] to obtain a ‘clean’ status. [Corbo] needs only to ‘toe the line’ and his sanctions would end.” Id. at 474a-75a. Further, the trial court reiterated that the District Attorney’s “sanctions are not lifetime ones.

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D. Corbo v. Chester County, & D.A. D. Ryan in her Official Capacity, Counsel Stack Legal Research, https://law.counselstack.com/opinion/d-corbo-v-chester-county-da-d-ryan-in-her-official-capacity-pacommwct-2025.