M.A. Dillow v. Lawrence County Board of Elections

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Michael A. Dillow, :

:

Appellant :

:

v. : No. 20 C.D. 2026

: Submitted: January 26, 2026

Lawrence County Board of :

Elections, Hickory Township, :

Jason A. Medure, in his capacities :

as County Solicitor and Township :

Solicitor, and Randy Brown :

BEFORE: HONORABLE MICHAEL H. WOJCIK, Judge

HONORABLE STACY WALLACE, Judge

HONORABLE STELLA M. TSAI, Judge

OPINION NOT REPORTED

MEMORANDUM OPINION

BY JUDGE WOJCIK FILED: March 16, 2026

Michael A. Dillow appeals from the December 29, 2025 order of the

Lawrence County Court of Common Pleas (trial court) which denied Dillow’s

Application for Emergency/Expedited Relief (Application) in its entirety.1 Dillow

sought therein to enjoin the Lawrence County Board of Elections (Board) from

certifying Randy Brown2 as the winner of the November 4, 2025 election for Hickory

1

This election-related appeal, at least at first blush, seems unorthodox yet otherwise

uncomplicated. Indeed, we are not usually tasked with resolving election disputes filed by the

candidate who received the greatest number of votes in an election. But our review of the matter

sub judice indicates that this case is more complicated than the parties initially believed. In fact,

what has unfolded since the November 4, 2025 Election can only be described as a series of

unfortunate events.

2

Brown joined this action as an intervenor in the trial court below.

Township (the same or Township) Supervisor because Brown received fewer write-

in votes than Dillow himself. We reverse.

If nothing else, at least the facts underlying this appeal are

straightforward. On November 4, 2025, Dillow received 57 write-in votes for the

office of Hickory Township Supervisor – receiving the greatest number of votes in

the election. Trial Court Order, 12/29/25, ¶1. Brown received 55 write-in votes. Id.

Nevertheless, the Board indicated its intention to declare Brown as the winner of the

election because it determined that Dillow was registered as a voter in Scott

Township on Election Day and was therefore ineligible to serve as Hickory

Township Supervisor under Section 401 of The Second Class Township Code,3 53

P.S. §65401. Id. ¶¶2, 8. More particularly, the Board’s solicitor, also serving as the

Hickory Township solicitor, related the following in an email to the Hickory

Township Board of Supervisors:

Dillow is not registered to vote in Hickory Township. As

such, [] Dillow is not qualified to hold office in Hickory

Township until he changes his voter registration. The

County will not declare [] Dillow as the write-in winner of

the Supervisor’s race. Randy Brown will be declared

winner and given the opportunity to accept his election

victory.

Original Record (O.R.) at Item No. 7.

Upon learning of the Board’s intention, and prior to the Board’s

scheduled certification of the Election on November 21, 2025, Dillow filed the

Application in the trial court. In pertinent part, relying on Section 1407(a) of the

3

Act of May 1, 1933, P.L. 103, as amended, 53 P.S. §65401 (“No person is eligible for the

office of supervisor, auditor or tax collector in any township unless that person is an elector of the

township.”).

2

Election Code,4 Dillow requested that the trial court enjoin the Board from certifying

the Election and that it hold a hearing on the matter. See O.R. at Item No. 1. The

trial court stayed certification of the Election pending resolution of the Application

in an order dated November 20, 2025, while also directing the Board and Hickory

Township to file an answer thereto. Id. at Item Nos. 2-3.

Notably, in the Board’s Answer to the Application, the Board explained

that it

reviews the voter[] registration for all individuals who

received the highest amount of write-in votes as a matter

of administrative policy and practicality. If said individual

is not registered to vote in the municipality (or precinct in

the case of party committee representatives), said

individual’s votes are invalidated. Similar administrative

functions occur when an individual attempts to provide the

Elections office with a Petition for candidacy in a

municipality he/she is not registered or said Petition is

unsigned or unnotarized.

O.R. at Item No. 7.

At the hearing, the parties stipulated that Dillow was not registered to

vote in Hickory Township on Election Day – although he changed his registration

on November 5, 2025. See Trial Court’s Hearing, Notes of Testimony (N.T.) at 5-

4

Section 1407(a) of the Election Code provides in pertinent part:

(a) Any person aggrieved by any order or decision of any county

board regarding the computation or canvassing of the returns of any

primary or election, or regarding any recount or recanvass thereof

under sections 1701, 1702, and 1703 of this act, may appeal

therefrom within two days after such order or decision shall have

been made, whether then reduced to writing or not, to the court

specified in this subsection, setting forth why he feels that an

injustice has been done, and praying for such order as will give him

relief.

Act of June 3, 1937, P.L. 1333, as amended, 25 P.S. §3157(a) (emphasis added).

3

10, 15. But the Board and the Township did not contest Dillow’s residency.

Although the Board and Brown focused on Dillow’s failure to register as an elector

in Hickory Township at the time of the Election, neither contested that Dillow was

a longtime resident of the Township. Id., N.T. at 9-11. Still, the Board and Brown

viewed this as inconsequential. In their view, because Section 401 of The Second

Class Township Code mandates that a Supervisor must be “an elector of the

township,” his failure to register as an elector of Hickory Township by Election Day

barred him from holding the office. Id., N.T. at 14-22.

As indicated, the trial court largely accepted these arguments and

denied Dillow’s Application in its entirety in an order dated December 29, 2025.

The trial court believed that the single issue presented by this appeal was whether

Dillow was “qualified for the position of Supervisor in Hickory Township, a second

class township, as he was registered to vote in Scott Township.” Trial Court’s Order

¶7. Thus, relying on Sections 401 and 403(c)5 of The Second Class Township Code,

53 P.S. §§65401, 65403(c), the trial court determined that because Dillow was not a

registered elector of Hickory Township on Election Day, he was unqualified for

office. Id. ¶¶8-10 (“When he won the election, [Dillow] still was registered to vote

in Scott Township which demonstrates he was not an elector of Hickory Township.

Resultantly, [Dillow] was not qualified to assume the office of Supervisor under The

Second Class Township Code.”). The trial court likewise terminated its earlier stay

of the Board’s certification. Id. ¶12. According to the Board, it certified Brown as

the winner of the election for Hickory Township supervisor on January 5, 2026.

5

Section 403(c) of The Second Class Township Code provides: “Supervisors shall reside

in the township from which elected and shall have resided in that township continuously for at

least one year before their election.” 53 P.S. §65403(c). The trial court therefore construed The

Second Class Township Code as having elector and residency requirements. Trial Court’s Order

¶10.

4

Board’s Brief at 4. Dillow, however, filed a Notice of Appeal in this Court on

January 2, 2026.6

Before this Court, Dillow asserts a litany of issues,7 but each issue

raised and his subsequent argument can be distilled into the following: the Board

exceeded its authority by disqualifying Dillow as the victorious write-in candidate

in favor of the runner-up. Dillow’s Brief passim. Dillow therefore requests that this

Court reverse the trial court’s decision and order that Dillow be sworn in as

Township Supervisor.

For its part, the Board largely advances the arguments it raised before

the trial court. It also argues, however, that in invalidating the write-in votes cast

for Dillow and disqualifying him from the election, the Board was simply acting

within the authority conferred upon it by the Election Code to administer elections.

Board’s Brief at 4 (citing 25 P.S. §§2641, 2642). So too, the Board reiterates that

the actions it took are similar to those it might take when a candidate attempts to file

a nominating petition. Id. at 5. To the extent Brown’s own arguments depart from

the Board, he argues that Dillow’s disqualification means that he is the duly elected

supervisor of Hickory Township pursuant to Section 1417 of the Election Code, 25

P.S. §3167.

As we see it, and as discussed infra, the Board plainly exceeded its

authority under the Election Code to disqualify Dillow from holding public office

and the trial court then compounded this error by denying the Application in its

6

The trial court filed a Pa.R.A.P. 1925(a) opinion on January 21, 2026, largely reiterating

its December 29, 2025 order.

7

To the extent our restatement of the issues does not encompass every issue raised by

Dillow, we need not reach them given our disposition. See Dillow’s Brief at 6-8.

5

entirety and terminating its stay of the Board’s certification. For his part, Dillow

then failed to seek a stay of the certification pending his appeal in this Court, thereby

enabling the Board to wrongfully certify the election in Brown’s favor. The parties’

arguments, then, miss the greatest difficulty in now resolving this appeal: the Board

has already certified Brown as Hickory Township Supervisor thereby mooting this

dispute.

It is well settled that an actual case or controversy – one that is real

rather than hypothetical – must be extant at all stages of litigation, not merely at the

time of filing. Harris v. Rendell, 982 A.2d 1030, 1035 (Pa. Cmwlth. 2009).

However, a once extant case or controversy may become moot if a ‘change in

circumstances has eliminated the controversy so that the court lacks the ability to

issue a meaningful order, that is, an order that can have any practical effect.’” In re

General Election (2024), 328 A.3d 606, 611 (Pa. Cmwlth. 2024) (quoting Burke ex.

rel. Burke v. Independent Blue Cross, 103 A.3d 1267, 1271 (Pa. 2014)).

While an extant controversy exists here, namely, whether Dillow was

unduly disqualified from the election for Hickory Township Supervisor, we are

unaware of any authority which would permit this Court or the trial court to order

the Board to decertify the results of the Election. See, e.g., Ioannidis v. Wolf (Pa.

Cmwlth., No. 635 M.D. 2020, filed July 8, 2021), slip op. at 8-9 (discussing effect

of certification on continued viability of election challenges).8 This Court therefore

must determine what order we could issue that would have any practical effect, and,

upon review, we must deem this matter technically moot. Mistich v. Pennsylvania

8

See Pa. R.A.P. 126(b)(1)-(2) (“As used in this rule, ‘non-precedential decision’ refers to

. . . an unreported memorandum opinion of the Commonwealth Court filed after January 15, 2008.

[] Non-precedential decisions . . . may be cited for their persuasive value.”).

6

Board of Probation and Parole, 863 A.2d 116, 119 (Pa. Cmwlth. 2004) (“[C]ourts

will not enter judgments or decrees to which no effect can be given.”).

Still, even where a dispute is technically moot, we may nevertheless

reach the merits under certain circumstances, such as where a dispute involves an

issue of great public importance. Rendell v. Pennsylvania State Ethics Commission,

983 A.2d 708, 719 (Pa. 2009). We are inclined to apply that exception here. To wit,

this matter implicates the proper mechanisms, if any, for challenging the

qualifications of a victorious write-in candidate. See also In re Petitions to Open

Ballot Box Pursuant to 25 P.S. §3261(A), 295 A.3d 325, 332-33 (Pa. Cmwlth. 2023).

However, given that Dillow filed the Application pursuant to Section 1407 of the

Election Code, we will confine our review accordingly. That is, we will limit our

review in this election contest “to [an] examination of the record to determine

whether the trial court committed errors of law and whether the court’s findings were

supported by adequate evidence.” Dayhoff v. Weaver, 808 A.2d 1002, 1005 n.4 (Pa.

Cmwlth. 2002).

In the proceedings below, the Board and the trial court undertook an

unfamiliar and little-explored legal question when they inquired upon Dillow’s

qualifications for office. Indeed, notwithstanding the Board’s comparison to the

provisions of the Election Code relating to fatally defective nominating petitions or

papers, see, e.g., 25 P.S. §§2861-2960, the Election Code is silent on the matter as it

concerns write-in candidates.

Nevertheless, by way of a footnote, our Supreme Court has explained:

Unlike candidates who pursue general elections ballot

access by nomination petitions or papers, the Election

Code does not require write-in candidates to file anything

attesting to or substantiating their qualifications or

eligibility for office . . . . Nor does it provide a

7

mechanism for challenging the qualifications of

victorious write-in candidates after their nomination or

election. Except perhaps in the rare case in which quo

warranto might lie, a circumstance that we have no

occasion to explore today, once a write-in candidate is

certified as the winner the courts are effectively

powerless to interfere.

In re Jordan, 277 A.3d 519, 532 n. 18 (Pa. 2022) (emphasis added). Thus, the

dispositive error in the proceedings below lies not with the trial court’s or the

Board’s interpretation of The Second Class Township Code or even Dillow’s

qualifications for office – and we offer no opinion on those issues now. Rather, the

dispositive error lies with the Board’s authority to invalidate lawfully cast votes for

the purpose of denying a write-in candidate’s putative victory.

If that were not enough to underscore the Board’s error in this matter,

we note Section 1404(g)(3) of the Election Code, 25 P.S. §3154(g)(3) (emphasis

added), provides: “If any error or fraud is discovered, the county board shall

compute and certify the votes justly regardless of any fraudulent or erroneous

returns presented to it, and shall report the facts to the district attorney of the

proper county for action.” This principle is not novel with respect to our election

law jurisprudence – in fact, this principle predates the Election Code itself.

For example, in 1867, our Supreme Court observed: “The votes cast at

an election for a person who is disqualified from holding office are not nullities.

They cannot be rejected by the inspectors, or thrown out of the count by return

judges. The disqualified person is a person still, and every vote thrown for him is

formal.” Commonwealth v. Cluley, 56 Pa. 270, 273 (1867) (emphasis added). So

too, in Commonwealth ex. rel. Parker v. Emminger, 74 Pa. 479, 483 (1871), the

Supreme Court determined that an election return judge’s sole duty and

responsibility was to faithfully tabulate and report the returns. Therein, the return

8

judges refused to certify a senator-elect’s victory on suspicion of fraud and bribery.

Id. The Supreme Court opined:

So far from this being the certificate required by law, it

was a refusal to certify. The returns were plain and

intelligible, at least nothing to the contrary is alleged, and

the only duty of the return judges was to cast them up

and certify for whom the majority has been given. The

county returns were, as to them in the performance of this

duty, conclusive. They could not be disregarded in the

least, excepting perhaps for plain clerical errors, and could

not be set aside. They were to be the evidence upon which

the return judges alone should act.

Id. at 483 (emphasis).

Thus, while this principle has since been codified at Section 1404(g)(3)

of the Election Code, it has long been the law of this Commonwealth that a county

board of elections may not sua sponte invalidate the votes that it deems to have been

cast for an unqualified candidate – especially, so that it might certify the runner-up

as victorious.9 Rather, the county boards have a duty “to compute and certify the

votes justly regardless of any fraudulent or erroneous returns presented to it . . . .”

See 25 P.S. §3154(g)(3). Here, to the extent the Board had concerns regarding

Dillow’s qualifications to hold the office of Township Supervisor, the Board’s

recourse was limited to reporting those findings to the Lawrence County District

9

Indeed, while it is beyond the scope of this proceeding, we nevertheless find Brown’s

argument that he is the duly elected Township Supervisor under Section 1417 of the Election Code

perplexing. That provision provides: “Except as otherwise provided by law, the persons receiving

the highest number of votes for any office at any election shall be declared elected to such office,

up to the number required by law to be elected thereto.” 25 P.S. §3167. By Brown’s very own

stipulation, he did not receive the highest number of votes for the office of Township Supervisor.

See, e.g., Brown’s Brief at 2-3; Cluley, 56 Pa. at 273 (“But surely it cannot be maintained that in

any possible contingency the office can be given to [the runner-up] . . . . Under institutions such

as ours, there is even greater reason for holding that a minority candidate is not entitled to the

office if he who received the largest number of votes is disqualified.”).

9

Attorney’s Office under Section 1404(g)(3) of the Election Code, rather than

invalidating lawfully cast votes by fiat.10 Id. It would then be incumbent upon the

District Attorney’s Office to seek further relief, including an action in quo warranto

as suggested in In re Jordan. However, because appellate jurisdiction over a matter

involving the right to public office is vested exclusively in the Supreme Court, see

42 Pa. C.S. §722(2), we will end our analysis here.11

10

We also observe that the Board’s vague reliance on the provisions of the Election Code

which provide for the county boards of elections membership and jurisdiction, see 25 P.S. §2641,

and its powers and duties, see id. §2642, must also fail. Neither provision empowers the Board to

disqualify victorious candidates – write-in or otherwise. In fact, Section 302(i) of the Election

Code, id. §2642(i) (emphasis added), empowers the county boards of elections “[t]o investigate

election frauds, irregularities, and violations of this act, and to report all suspicious circumstances

to the district attorney.” But it confers no greater authority, such as adjudicating the fraud,

irregularity, violation, or suspicious act, upon the county boards.

11

We suppose, then, that the only viable avenue for continued judicial relief in this matter

would be a fresh action in quo warranto filed in the trial court. See In re Jordan, 277 A.3d at 532

n. 18. We caution, however, that

[o]nce a person has been duly elected, the right to exercise

the authority of office is not to be lightly disturbed. A complaint in

quo warranto is aimed at the right to exercise the powers of the

office, which is a public injury, rather than an attack upon the

propriety of the actions performed while in office, which would be

a private injury. Accordingly, standing to pursue quo warranto is

generally within a public entity such as, the Attorney General, or the

local district attorney. Spykerman v. Levy, 421 A.2d 641, 648 (Pa.

1980); Lehman v. Tucker, [368 A.2d 670, 672 (Pa.] 1977). A private

individual or entity is generally barred from bringing a quo warranto

action; but a private petitioner will be deemed to have standing

where that petitioner can show that it has been specially damaged or

has some special right or interest. Spykerman, 421 A.2d at 649; see

also In re One Hundred or More Qualified Electors of Clairton,

[683 A.2d 283, 286-87 (Pa.] 1996) (finding qualified electors lacked

standing to bring an action in quo warranto for failure to show an

interest beyond that shared in common by all citizens of

municipality).

(Footnote continued on next page…)

10

Accordingly, we reverse the trial court’s order.

MICHAEL H. WOJCIK, Judge

Commonwealth ex rel. Judicial Conduct Board v. Griffin, 918 A.2d 87, 93 (Pa. 2007) (footnotes

omitted); see also Spykerman, 421 A.2d at 648 (“Historically, Pennsylvania courts have held that

the quo warranto action is the sole and exclusive method to try title or right to public office.”).

11

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Michael A. Dillow, :

:

Appellant :

:

v. : No. 20 C.D. 2026

:

Lawrence County Board of :

Elections, Hickory Township, :

Jason A. Medure, in his capacities :

as County Solicitor and Township :

Solicitor, and Randy Brown :

ORDER

AND NOW, this 16th day of March, 2026, the December 29, 2025 order

of the Lawrence County Court of Common Pleas is REVERSED.

__________________________________

MICHAEL H. WOJCIK, Judge

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Michael A. Dillow, :

Appellant :

:

v. : No. 20 C.D. 2026

: Submitted: January 26, 2026

Lawrence County Board of Elections, :

Hickory Township, Jason A. Medure, in :

his capacities as County Solicitor and :

Township Solicitor, and Randy Brown :

BEFORE: HONORABLE MICHAEL H. WOJCIK, Judge

HONORABLE STACY WALLACE, Judge

HONORABLE STELLA M. TSAI, Judge

OPINION NOT REPORTED

CONCURRING AND DISSENTING OPINION

BY JUDGE WALLACE FILED: March 16, 2026

I agree with the conclusion reached by the Learned Majority. The Court of

Common Pleas of Lawrence County’s (trial court) decision in this matter should be

reversed because the Lawrence County Board of Elections (Board) lacked the

authority to refuse certification of elections. However, I write separately to note I

would have transferred this appeal, at least in part, to the Supreme Court, because

the central issue on appeal implicates a person’s right to hold public office.

Before addressing my disagreement, I want to emphasize the issue of private

standing in quo warranto actions. Although the Majority cautions a duly elected

person’s right to exercise the authority of office is not to be lightly disturbed, it

importantly and correctly notes a quo warranto action may be available to oust a

person from public office and to prevent continued exercise of authority unlawfully

asserted. In re Prospect Crozer LLC, 328 A.3d 37, 68 (Pa. 2024). Private persons

may have standing to bring a quo warranto action when they can demonstrate special

damage or some special right or interest. See Reed v. Harrisburg City Council, 995

A.2d 1137, 1140-41 (Pa. 2010) (holding “a private party with a special interest in

the matter[, such as Mayor Reed,] may institute a quo warranto action without first

notifying the Attorney General or the local district attorney.”).

Now, turning to my point of disagreement, the Majority frames the issue on

appeal as simply one involving the Board’s authority to refuse to certify the election

results for the office of supervisor of Hickory Township in favor of Michael A.

Dillow, the election winner. The issue, however, is more nuanced and mixed. The

rationale for the Board’s refusal rests on its interpretation of Section 401 of The

Second Class Township Code, 53 P.S. § 65401. Specifically, whether the term

“elector” means that a candidate is required to have registered as an elector of a

township by election day to qualify for the position of township supervisor.1 Maj.

Op. at 4. This issue undoubtedly involves a person’s right to hold public office.

Due to jurisdictional constraints, I refrain from offering an opinion on the

meaning of “elector.” This restraint is especially challenging because the Board and

1

Merriam-Webster Online Dictionary defines “elector” as “a person qualified to vote in an

election.” Elector, Merriam Webster, https://www.merriam-webster.com/dictionary/elector (last

visited Mar. 12, 2026) (emphasis added). Black’s Law Dictionary defines “elector” as “[a] voter”

or “qualified voter,” “a person who meets the voting requirements for age, residency, and

registration and who has the present right to vote in an election.” Black’s Law Dictionary (12th

ed. 2024) (emphasis added). The term “registered elector” denotes a person needs to be registered

to vote, whereas, as stated, the term “elector” holds no such meaning. See 25 Pa.C.S. § 1102

(defining “registered elector” as “[a] qualified elector who is registered to vote”).

SW - 2

the trial court did address the meaning of elector. In concluding that an elector of a

township must reside in and be registered to vote in that township, the trial court

principally relied on Aukamp v. Diehm, 8 A.2d 400 (Pa. 1939). Aukamp involved

who may sign petitions for local option referendums pursuant to the Liquor Control

Act and the Beverage License Act. Evaluating the issue under the voter qualification

provision of the Pennsylvania Constitution, and applying the Election Code’s

definition of “qualified elector,” our Supreme Court concluded “the legislature used

the word ‘elector’ . . . in the sense of one qualified to vote at the election and

therefore one who, at the time of signing the petition for referendum, was registered

to vote.” Id. at 401.

Aukamp, however, appears to be in tension with In re Sullivan, 160 A. 853

(Pa. 1932),2 where the Supreme Court explained:

We cannot agree with the contention which was earnestly advocated

before us, and which was also the opinion of the court below, that

registration is an essential qualification of an elector. The reference

which is made to registration in the first paragraph of the section of the

Constitution just quoted [i.e., the former Article 8, Section 1] does not

require such a narrow construction of the phrase ‘qualified elector.’

Registration may be and usually is prerequisite to voting; but it is not a

qualification for the exercise of the franchise. No attorney is permitted

to argue before the bar of this court without being formally admitted;

yet no one would contend that the mere motion for admission

constitutes a qualification for practice. The same reasoning applies to

registration for voting.

Id. at 854 (emphasis added). As indicated, this apparent conflict on the meaning of

the terms “elector” and “registered elector” is for our Supreme Court to resolve,

2

In re Nomination of Nader, 860 A.2d 1, 7 (Pa. 2004) (Saylor, J., dissenting statement) (noting

that Aukamp and Sullivan “are in tension” and that “[a]s between the two decisions, however,

Sullivan is . . . the better reasoned.”). Aukamp does not cite or overrule Sullivan.

SW - 3

because it implicates a question involving a right to public office. See

42 Pa.C.S. § 722(2).

Thus, this Court should have at least transferred the portion of the appeal

pertaining to Dillow’s qualification for public office to the Supreme Court. See, e.g.,

Commonwealth v. Spano, 701 A.2d 566 (Pa. 1997) (The Superior Court affirmed the

conviction, but transferred the portion of the appeal concerning defendant’s removal

from office to the Supreme Court).

If, in the future, after this Court reverses the trial court in this action, Dillow

were to file a new, separate, quo warranto action to seek Randy Brown’s removal

as Hickory Township Supervisor, the basis for relief may be identical to what is

presently before us. That is, whether the Board misapplied the meaning of the term

elector, as used in Section 401, to refuse to certify the election for Dillow.3 If that is

the case, Dillow would file a direct appeal with the Supreme Court. See Reed, 995

A.2d at 1139 (The Commonwealth Court, via a single-judge order, transferred the

quo warranto case to the Supreme Court under Section 722(2)). Because of this, we

would be dismissive of judicial resources and the parties’ and public interest in

resolving this dispute expeditiously, as one quarter of the year has already elapsed

since Brown took office.

Accordingly, I disagree with the Majority’s decision not to transfer this appeal

to the Supreme Court.

______________________________

STACY WALLACE, Judge

3

Because the trial court has already determined the meaning of the term “elector” in this case, it

is conceivable it may reapply that same meaning in subsequent cases. See Appeal of Coatesville

Area Sch. Dist., 244 A.3d 373, 378 (Pa. 2021) (res judicata “bars actions on a claim, or any part

of a claim, which was the subject of a prior action, or could have been raised in that action.”).

SW - 4