It's kind of surprising that a senior priest in Christ's own church has, ". . . no duty to protect children." I guess the Catholic hierarchy has moved on from all of that "Sermon on the Mount" stuff, to a more profit-based model of operations?

The legal theory is Lynn KNEW of a priest's past record, since lynn told the bishop of that past record and advised the Bishop NOT to appoint the priest to a position where children may be present. The bishop over ruled him when another priest told the Bishop he will supervised the pedophile (and unknown to Lynn, the pedophile was permitted to hold mass in a nearby church with children present).

Since Lynn knew of the priest's past record, the prosecutors claim he had a legal duty to protect any child that priest came in contact with, even if Lynn did NOT know if the Priest was around Children. i.e. When the priest committed the crime, any and all of his supervisors were guilty of the same crime, no actual knowledge of the crime was required.

Superior Court had a HUGE problem with that legal theory. It basically amounted to, if someone you employ or supervise does an illegal act unknown to you, you are as GUILTY of that crime as if you did know of it. i.e A Strict Liability crime. Now, Superior Court did NOT have to address that issue for the law violated did not cover employers or supervisors till AFTER the incident in question. Thus the Philadelphia Prosecutor's position that such language was added to clarify liability not to extend it.

Superior Court rejected the position of the Prosecutors and said mere employment or supervision of someone who commits a crime does not make such employer or supervisor guilty of the crime under the pre-2007 version of the criminal act. Superior court then made huge hints it disliked the whole concept of strict liability of employers and supervisors for crimes of their employees when such employers and supervisors had no way to know the crime was occurring. Please note we are talking of a Criminal Case, the court would be happy to held such Supervisors and Employers liable in a civil litigation, for that is mere money, but given Criminal Charges include a lost of liberty, the court was willing to draw the line.

Actual Opinion:

http://www.pacourts.us/assets/opinions/Superior/out/J-A23005-13o%20-%201016613421853550.pdf?cb=1

Pages 1-17 are the facts in the case

Pages 18-21 is the prior procedures in this case

Pages 22-24:

It is undisputed that Appellant was tried under the pre-amended version of the EWOC statute. Prior to January 29, 2007, the statute read: “A parent, guardian or other person supervising the welfare of a child under 18 years of age commits an offense if he knowingly endangers the welfare of the child by violating a duty of care, protection or support.” 18 Pa.C.S. § 4304(a)(1). The 2007 amendment added language, inter alia, such that the statute now reads: “A parent, guardian or other person supervising the welfare of a child under 18 years of age, or a person that employs or supervises such a person, commits an offense if he knowingly endangers the welfare of the child by violating a duty of care, protection or support.”

18 Pa.C.S. § 4304(a) (current) (emphasis added).

It is undisputed that Avery was supervising D.G. when he sexually abused the boy. It is also undisputed that Appellant did not have any direct supervisory role over D.G. or any other child put at risk by Avery’s presence at St. Jerome’s. The Commonwealth’s contention at trial was that Appellant, in his capacity as the Archdiocese’s point-man on priests accused of sexual abuse, violated the pre-amended EWOC statute by placing Avery in an environment where he knew there was a significant risk that Avery would
sexually abuse minors (or by failing to remove him once there were indications that Avery might reoffend). Thus, independent of whether Appellant owed a duty of care to the children of St. Jerome’s, or to D.G. in
particular, the prohibited conduct of his alleged violation of the EWOC statute was his inadequate supervision of Avery.

Appellant claims the pre-amended EWOC statute did not encompass the conduct of a supervisor of a “person supervising the welfare of a child.” He contends that by the plain meaning of the terms of the pre-amended statute, it imposed criminal liability only upon those directly supervising children. He maintains that decisional law examining the pre-amended statute limited the class of persons subject to criminal liability to “parents and parental surrogates.” Appellant’s Brief, at 19. Appellant also directs our attention to the 2007 amendment language as a compelling indication that the prior version of the statute, the one under which Appellant’s conviction rests, did not encompass persons described by the additional language, i.e.,
those who employ or supervise the class of individuals that were within the purview of the pre-amended version. In essence, he argues that the legislature’s inclusion of the “or a person that employs or supervises such a person” language in the amended statute indicated an intent to add a class of persons not originally subject to liability under the pre-amended version.

Pages 34-35:


Thus, the plain language of the pre-amended EWOC statute requires proof, as an element of the offense, that the accused was a supervisor of an endangered child victim when the conduct or condition giving rise to the offense occurred.

In doing so, we reject the interpretation of the trial court, as endorsed by the Commonwealth, that inclusion of the terms “the welfare of” in 18 Pa.C.S. § 4304(a) implies that “the statute does not require that an individual be a ‘supervisor of a child’ to fall under EWOC’s umbrella of criminal liability.” TCO, at 183. The plain meaning of the terms of that clause does not support such a construction. And, despite the broad
purpose of the EWOC statute as outlined in Mack, “hen the words of a statute are clear and free from all ambiguity, the letter of it is not to be disregarded under the pretext of pursuing its spirit.” 1 Pa.C.S. § 1921(b). Accordingly, we conclude that the evidence was not sufficient to support
Appellant’s conviction for EWOC as a principal actor, because the Commonwealth failed to offer any evidence that Appellant was a supervisor of D.G. or any other child at St. Jerome’s.

Then Page 41 of the opinion:

Nevertheless, Avery was appointed to a chaplaincy so as to limit his contact with children. There was no evidence that Appellant explicitly or implicitly approved of Avery’s supervision of minors at St. Jerome’s. In fact, the Commonwealth’s own evidence demonstrated that upon Avery’s placement at St. Jerome’s rectory, that parish’s pastor, Father Graham, was told that Avery “was not to be around children and was to live in the parish, be around other priests, and minster to the local hospital.” N.T., 5/23/12, at 50. Even if these facts did not extinguish the risk that Avery presented to the parish, the Commonwealth’s evidence was not sufficient to support the notion that the natural and probable consequence of Appellant’s conduct was Avery’s intentional act of molestation (which was the only conduct that could have given rise to Avery’s EWOC violation). Such an inference was far too tenuous a proposition to satisfy the Commonwealth’s burden of proof, even viewing all the evidence in a light most favorable to the Commonwealth.

We conclude, therefore, that the theories of accomplice liability applied by the trial court in this case were not supported by sufficient evidence. There was no underlying EWOC offense committed by Avery when Appellant facilitated his appointment to the St. Jerome’s rectory, or when Avery was permitted to remain at St. Jerome’s after Appellant received the influx of negative information about Avery’s rehabilitation. When there was an underlying EWOC violation, Appellant’s accomplice liability to EWOC was unsupported by sufficient evidence. Appellant did not know or know of D.G., he was not sufficiently aware Avery’s supervision of D.G. or any other child at St. Jerome’s, nor did he have any specific information that Avery intended or was preparing to molest D.G. or any other child at St. Jerome’s. In sum, the evidence was insufficient to demonstrate that Appellant acted with the “intent of promoting or facilitating” an EWOC offense.

Having determined that the evidence was not sufficient to support Appellant’s conviction for EWOC either as a principal or as an accomplice, we are compelled to reverse Appellant’s judgment of sentence. And, as there are no other offenses for which he was convicted in this case, Appellant is
ordered discharged forthwith.

Judgment of sentence reversed. Appellant is discharged.
Judgment Entered.

Thank you for clarifying why the Superior Court Judge threw out the conviction, and, I believe, the prosecutor will lose in the State Supreme Court.

Thank you for detailing that legal wrangle so well, but it all seems to miss the main point: Another pedophile was shielded by high church officials and allowed to continue his (gag!) ministry instead of going to prison where he so richly deserved to be sent. The catholic hierarchy should have helped the authorities, not the pedophile priest.

That is Lynn's crime. He and the others involved should pay for their negligence and their conspiracy to subvert the laws concerning child abuse.

It could be used against battered women afraid to report their attacker for acts against other.

To me it is troubling, the effort to blame people for criminal acts of others. If Lynn really knew what the other guy was doing, he'd be a witness in a criminal case against him. This discourages witnesses from coming forward.

When the priest-pedophile hit Boston, Cardinal Bernie Law showed his meddle: he moved to the Vatican.

See my thread above for details.

Did you even bother to read the legal ruling?

And that person rapes a child, you should also go to jail? That is the logic behind this case. The person who did the crime, admitted it and was sentence to jail. No one is disputing that person's sentence. The issue is what CRIMINAL PUNISHMENT should the person who SUPERVISED or EMPLOYED another be held to when an EMPLOYEE of that person does a crime? AND such Supervisor or Employee did not know of the Crime till years later.

Remember, the Catholic Diocese is and was held civilly liable for the rapes and is paying what was awarded to the victims. Thus we are NOT talking about CIVIL punishment but actual CRIMINAL punishment of people who HIRED others but did NOT hire them to comment crimes. If you believe you yourself should go to jail, of the boy you hire to mow your lawn, later rapes someone, then Lynn is getting away. If on the other hand you do NOT believe you should go to jail for a crime done by someone your hire, then Lynn is NOT getting away with anything.

There are however plenty of other legal ways to discipline this pedophile protecting Criminal Cabal.

Legislatures, Judges and prosecutors however prefer to ignore creating and prosecuting the legal means to shut down these criminals, who consistently fleece the sheep, avoid taxes and protect child sodomites and rapists.

The charge against Lynn is that he failed to prevent the actual pedophile from having sex with the victim, not that Lynn, consented to the Sex or even knew of the Sex. In fact it is admitted that Lynn wanted to place the Priest in a position where he had no access to children.

As to the earlier incident of pedophilia by the priest in question (Hereafter referred to as the Pedophile), the Statute of Limitation had run out so NOT a factor in this case (it is also clear that Lynn advised the parent of that victim to file charges, but the parents never did).

It is also agreed that Lynn advised the Priest supervising the Pedophile that the Pedophile was NOT to be around any children. The Pedophile maneged to work around these restrictions and found a new Victim. The Pedophile was arrested AND just before trial accepted a plea bargain. Thus at trial was Lynn and his defense that he was NOT Supervising the Pedophile for the line of Command went elsewhere i.e. the Bishop, now dead.

Thus thus this decision which was based in a law that was an attempt to extend Criminal liability in such cases. See my previous posts on that point of law.

Now, you then go on about creating and prosecuting the legal means to shut down these criminals, who consistently fleece the sheep, avoid taxes and protect child sodomites and rapists.

What you mean by that I have no idea, for the law that applies also apply to everyone, i.e. you and I in addition to any Catholic Priest and any law HAS to cover EVERYONE not some institution you happen not to like. Thus what laws do you want to adopt that applies to everyone? And it has to cover everyone for if you restrict it to religious institutions you have First Amendment issues. On the other hand those issues disappear if the law applies to EVERYONE.

The problem with expanding the laws on pedophilia is you must remember most pedophile cases do NOT involve the Catholic Church. They are more in Public Schools, mostly do to more children being in public schools then Catholic Schools. The reason we do NOT hear of them is that when such cases come to court, the pedophile is convicted (just like a pedophile in a Catholic Church Case) but since that involves a Child the hearing in held behind closed doors (as are most cases involving criminal charges when a minor is involved). These are boring cases and no big head lines.

The headlines over the last 30 years when it comes to the Catholic Church involved the multi-million dollar lawsuits filed against the Catholic Church. Such cases are almost never filed in a Public School Case, for when it comes to trial, the Court generally rules even through the crime was done by a School Teacher, the School District is NOT liable under the concept of Sovereign Immunity. i.e. the King can do no wrong and thus that a Teacher raped a student even if done in school can NOT make the school liable for the act of the Teacher. You can get a judgment against the teacher, but NOT the School that employed and supervised that teacher.

As to the Catholic Church, since it is a "Private" institution, Sovereign immunity does not come into play. Under the rule that an employer is legally liable for the illegal acts of the Employer's employee (With certain legal exceptions) the Catholic Church has been held liable when one of its employees raped a child. Notice this is NOT Criminally liability, but financially liability. Thus you have heard of these cases involving the Catholic Church, for it was an easy target AND has assets to pay any Judgment.

The only defenses the Church could use was the act was outside its area of control (outside the church and School and thus outside the course of employment) OR the act did not occur. In most cases you have multiple plaintiffs so the defense that the act did not occur is cited, but is not the main defense In cases with many victims each victim confirms the story of the other victims, in cases with only one victim and no other evidence, the cases are generally dismissed, for it is then the word of the Victim against the Defendant, and the Burden of proof is on the VICTIM with only the victim's word the victim generally can NOT carry his burden of proof. Thus single accusations tend to be dismissed, but multiple accusation overcome this burden of proof for each victim accusation support the other victim accusations.

Thus in multiple victim cases (or where some other reliable evidence supports the accusation), the main defense is that the act was outside the employer-employee relationship and thus it is NOT liable. i.e. the rape occurred off church property and when the pedophile and the child were NOT doing anything to do with the Church. It is NOT much of a defense, but it has won some cases when it was clear NOTHING occurred on church property OR during a Church Sanctioned event AND all evidence points to consensual sex.

The biggest reason for lawsuits on the Catholic Church as oppose to other institution, is that Attorneys want to be paid, and that means winning a liability case and thus getting part of any judgment actually paid out. In most cases with NON-Catholic Church institutions, such institutions have limited assets and thus when they lose at trial, they just dissolve. Thus the plaintiff ends up with a empty church and the personal property tied in with that church (and most of such property mortgages, so what you get is a hall that costs the victim money to maintain and since it is NO longer a church taxable real property).

With the Catholic Church you have an institution that has assets to pay a judgment. Thus you hear of lawsuits against the Catholic Church (and some rich Protestant, Orthodox, Jewish and even Islamic groups) but not to many other groups for most do NOT have assets to pay off any judgments (and most have mortgages on their churches, so if you win the lawsuit you get the Church, but subject to any mortgages on the Church). This is also true of lawsuits against public school teachers, they rarely have assets big enough to pay a judgment (or if they do, it is exempt from attachment, such as retirement savings AND home owned with their spouse).

Thus, the Boy Scouts and other Religious Groups are coming under the same set of attacks as the Catholic Church, but most such groups are very small and has few assets (Thus the lawsuit is quickly drop, no money to collect). What this mean is that Attorneys are reluctant to sue such groups, for you may end up spend $50-100,000 dollars and win a Judgment of several Million, but then find out the Group's actual assets is less then $1,000, thus you do not even recover all of the Court fees and other cost incurred in taking the case to trial.

#1 rule in law, sue someone who has the assets to pay. Do NOT sue someone who has NO Assets. You have better things to do with your own money.

For every 2000 Catholics you have one Priest. Thus $100 from each one per year is $200,000 a year per Priest. Thus out of every 100 priests you can raise $2,000,000 Dollars per year. We can assume what the studies have shown that about 2% of all men (and studies of Catholic Priest record since the 1950s also shows a 2% number) commit pedophilia. If two priest out of 100 commits the crime, they would have raise $400,000 for that year. In a case held in Altoona Pa, it was reported the Catholic Church pays their priest about $24,000 a year. Thus these two hypothetical priests would have netted for the Catholic Church over $350,000 each year.

Thus the Catholic Church has the income to pay the damages awards against it and has done so (and has the money to defend against such lawsuits and has done so). In most cases the issue is less if the crime occurred, but how to compensate the victims. Thus most do NOT get to trial, an agreement is made first. Thus this is a problem for the Catholic Church, but it is NOT a insurmountable problem, if they just get around to following they own rules (a major problem with the Catholic Church is a tendency NOT to follow its own rules, if the rules lead to something they dislike, but that is true of almost every organization and thus why lawsuits are needed to remind people to follow they own rules).

I use to do CYS work, and what the Catholic Priests are accused of doing, is done more often by family members of the victim as oppose to someone who is NOT a family member (i.e. if you are a victim of Pedophilia, the perpetrator is more likely a male relative of yours then any outsider, including any Catholic Priest). It is easy to punish the Catholic Church, all you have to do is sue them and if you have the evidence they will pay up. As to other perpetrators, most do not have the assets to pay up AND their employers will NOT pay up, either because the employers have no assets OR their are Governmental units and thus protected by Sovereign Immunity.

Thus the problem is the same law has to apply to the Catholic Church as to local School Districts, but the States refuse to make their School liable for fear that it would lead to increase taxes. Instead the States extend the time period for someone to file a lawsuit (it use to be within four years of the Victim passing 18, but many states have increased it till ten years after the victim turns 18) or increased who can be charged criminally in such cases, even if that means someone who hired someone to do a legal job and while doing that legal job rapes someone. Neither law solves the problem, for most of these cases involved children between the ages of 12 and 14. For some reason most of these rapists want boys between 12 and 14 (Occasionally 11 and 10, but those are rare). This is also the age most boys are breaking out from the family their were born in and searching for Friends (and thinking about sex). How do you protect them? but also leave them free?

Under the Common Law, the rule was easy, it was legal to have sex with anyone over age 12. Thus none of these lawsuits would have occurred under the Common Law for the Defense that the victim did not object and it was consensual would have come into play. Most states disliked the common law rule, so in the 1800s, you saw the age of consent for sex increase. The problem with this was Police Officers who were instructed to enforce this law had the job of stopping things many teenagers still do (i.e. have sex). Thus for decades the various ages adopted for consent was ignored as unworkable and the Common Law Rule was enforced by local police instead.

In the 1960s the law as to consent to have sex changed once again, with most states wither adopting something like age 14 or keeping age 14 if that had been the law in that state since the 1800s. Other states adopted 16, 18 and even 21. A exception was made if you were married but at what age does a person have the capacity to consent to sex? Remember in most of these cases it is NOT forced sex, but the pedophilia prevails upon the victim to "Consent". How do you address that issue?

Thus the problem with your statement, how do you pass a law that punish pedophiles but NOT increase taxes? Do you order 12 to 14 years to be escorted by a parent? What parent has time for that today? I wrote the above to give you an idea of the problems the States have with these types of cases, how would you solve these problems?

My own thought is the present rules are working, even the Catholic Church has adopted rules that make it easier to report such crimes to the State. Yes, we have these lawsuits, but do you prefer that such cases just be covered up by the Courts? It is easy to demand that the Legislatures, Judges and prosecutors do something, but the problem is WHAT?

After reading your long analysis, I don't have an answer to solve this problem. My reply was sent as a shotgun approach and obviously you point out some interesting conflicts in fact and Law which prevent a wholesale solution. Each Diocese is different, Your facts show that in the past 2% of the Priests had sexual issues with children. Who knows about the future ? There are some obviously pissed off people who demand some sort of change in how this "Business" operates not only with children but with their tax exempt status and their campaign influences when it comes to that tax exempt status.

I am however very familiar with this case that dragged on for many many years.

Feeney ultimately was criminally convicted and served 5 years in prison for his crimes.

http://wcca.wicourts.gov/caseDetails.do;jsessionid=12FDA77BDA08C434B6578B5C5057035D.render6?caseNo=2002CF000779&countyNo=44&cacheId=825CCADDE12885311A4843615DF3AAD6&recordCount=6&offset=4

The Diocese was involved to the max in defending Feeney's criminal case. Feeney was helped with expensive A+ Martindale representation.

The the civil case was filed.

The 17 page complaint

http://www.bishop-accountability.org/news2008/01_02/U09558312.PDF

The jury of their religious peers awarded massive damages and the Diocese appealed.

The award was overturned on a technicality and a new jury trial ordered.

This Diocese eventually after spending several million on defense and several trips to the appellate courts eventually settled for $600,000.00. The cover up was massive. The church never admitted it did anything wrong. I am sure you are familiar with that type of settlement. Apparently they tried to help Feeney with his criminality and only succeeded in helping him spread his misguided sexuality to other victims. This Diocese continues to cover up and obfuscate, the Bishop even sent out a letter before the last election that amounted to a whole scale endorsement of the Repuke Party without naming them by name. I could go on but thank you for your reply.

I always pity Children and Youth (CYS) Judges, they have to make a punishment so severe that it hurts the perpetrator but the victim is NOT further harmed by the Punishment.

Now, my CYS involvement involved neglect more then abuse and placement of the Child as opposed to any criminal charges (Criminal Charges are handled by the Local District Attorneys and Public Defenders, I was neither, I worked for a Legal Aid program).

I generally represented parents involved with CYS on neglect issues, but occasionally an abuse issue would pop up. I never had to represent a parent accused of actual abuse, but ended up reading the material on such issued in case such issues show up in a Trial i was involved in (and every so often it did come up).

Something like 90% of all abuse cases involved male relatives of the victim, in most cases their father. Thus the great dilemma in such cases, do you jail the Father, providing him a warm place to sleep and three meals a day, while the Victim has to move, and may not be able to pay rent for a new place to live (Father in Jail, Father can NOT pay Child Support). Thus the victim has to move, to a new home, generally in a less expensive neighborhood, which includes a new school, new friends etc AND often in the middle of the School year not during the Summer between grades (which is the preferred way to to switch schools). Worse with the father in Jail, Child has to rely ONLY on Mother's income for school supplies, clothing, and even food in addition to housing. In such situations (more often the case then not) putting the Father behind bars will harm the victim more then the perpetrator.

Thus Judges try to work around these restrictions, for example order a perpetrator on World Release, so he can earn money to pay child support. Sentence the Perpetrator to probation for the same reason.

Now, people hear of these "light sentences" and demand stiffer sentences, but then do not look in how such stiffer sentences will affect the victim. The Courts point out this problem to the Legislature, who are often under pressure to do something, thus you get stupid laws like the one involved with Lynn. They had to pass something, but all the easy solutions are worse on the Victims then on the perpetrator.

I pity CYS Judges in such cases, how do you make sure the Victim in NOT punished when they sentence the perpetrator? It is they headache, and it is not new. A retired judge once told me of how his Father gave up being a lawyer during the Great Depression to be a Court Stenographer (it as the 1930s and the Court did NOT like the idea of Women hearing about what was being reported to the court in CYS cases, thus the need for a male Stenographer in the 1930s). I bring this up for such cases have been heard for centuries and will be heard in the coming centuries. We never have been able to solve the problem of such abuse, but maybe some day we will.

You point out a number problems that have no good solution.

The public wanting stiff sentences, often is oblivious to the complications of a child having the same father and grandfather, thanks to science and today's DNA tests.

And as you point out --What does a judge do?

Take care and thanks

"I am disgusted by the ruling of the Superior Court panel that was persuaded by the defense argument that Monsignor Lynn did not have a duty to protect children. I have no doubt that a misguided, wealthy benefactor will pay for his release."

Maybe they have lower standards in Philadelphia.

And it was a letter from the Attorney for the other side to his client? Every other bar when presented with that question said the attorney who received the letter should re seal it and send it back to the attorney who sent it. On no accounts should the attorney who received the letter read more then is needed to determined it was NOT a letter he was suppose to have access to.

Philadelphia had to be different, they said you not only could finish reading the letter, you should copy it for your own records and then send it back. Every other bar association in Pennsylvania rejected the Philadelphia ruling and accepted the nation position on that issue. A case actually came up out of Philadelphia and the State Supreme Court actually had to rule on the issue, and rejected the Philadelphia rule.

Philadelphia has its own rules and tries to make them state wide rule. Philadelphia being the largest city and bar in Pennsylvania tends to get its way. I am from Johnstown, which is occasional referred to as the "Country of Cambria" do to our tendency to adopt our own rules but we do try to follow national and state tendency even as to our own rules of Civil Procedures.

Side note: Pittsburgh and Philadelphia are the two largest city in Pennsylvania, but differ in many ways. For example, on a per thousand person basis, Philadelphia sentence more people to death row then does Pittsburgh. The General rule in Western Pennsylvania is you will NOT get a Death Sentence from a Judge or Jury unless you have some torture or other similar severe injury over and above the Murder. Philadelphia will sentence people to Death on any grounds the State permits. Another difference is "Pain and Suffering" in auto accidents. Almost always plead and part of the settlement in Philadelphia and its suburbs, but almost unheard of in Western Pennsylvania (and when plead just not found by judges or juries).

The main reason generally given for this difference is that Western Pennsylvania is the heart of the Coal Industry, while Philadelphia is far away from the Soft Coal mines. The hard coal mines are closer to Philadelphia then Pittsburgh, they tend to be in the Eastern half of the state but still far away from Philadelphia.


http://genpa.org/resources/statewide-resources/pennsylvania-mining-resources/pennsylvania-mining-resources

Thus Western Pennsylvania has a long history of Coal Mining and Steel Making and violent strikes in both industries. Given the tendency for Mine owners to revert to violence and coal miners responding to such violence, they are reluctant to give out death penalties except to those who go beyond killing someone. The same rationale goes for "Pain and Suffering" that is a given if working in the Coal Industry and the Steel Industry and thus they are reluctant to give money for pain and suffering.

Same law, but different practice between the two main cities and the areas around those cities.

To show you how much coal mining has affected Western Pennsylvania. Western Pennsylvania has one of the largest areas of a single dialect in the USA. Here is the map of such dialects in Pennsylvania, notice the "Upper Ohio Valley" dialect duplicates the area of Bituminous coal and it centers around Allegheny County, whose county seat is the City of Pittsburgh.


http://www.evolpub.com/Americandialects/PennaDialMap.html

i actually had that question on the ethics portion of the bar exam except the letter was faxed.