The Pennsylvania Supreme Court established a rule that a private person may use deadly force to effectuate an arrest only when certain enumerated felonies have been committed, and approved the rule that an arresting party will always be criminally responsible if deadly force is used against anyone but an escaping felon.
Commonwealth v. Chermansky, 430 Pa. 170, 242 A.2d 237 (1968).
David J. Brightbill,
Criminal Law - Arrests - Use of Deadly Force,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol7/iss2/8