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Home My WebLink About97-07186 L.B. SMITH FORD/ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY / PENNSYLVANIA CIVIL ACTION - LAW v. MARK H. GIESELER, Defendant I I I NO. 97-7186 CIVIL TERM AND ORDER OF COURT IN RE: PETITION FOR LEAVE TO FILE APPEAL NUNC PRO TUNC FROM JUDGMENT OF DISTRICT JUSTICE CHARLES A. CLEMENT. JR. NOW, this 'l~y of January/ 1998/ upon consideration of the Petition for Leave To File Appeal Nunc pro Tunc from Judgment of District Justice CharleS A. Clement, Jr./ it is ordered and directed as fol10woI 1. A rule is issued upon Defendant to show cause why Plaintiff io not entitled to the relief requested; 2. The Defendant shall file an answer to this petition within 20 days of thio date; 3. The petition shall be decided upon Pa. R.C.P. 206.7; 4. Depositions shall be completed within 45 days of this date; 5. Argument shall be held on Thursday, Maroh 5/ 1998/ at 9:00 a.m./ in Courtroom No. 1/ Cumberland County Courthouse, Carlisle, PennflY 1 vania.' BY THE COURT, James A. Garver/ Esq. 2931 North Front Street Harrisburg, PA 17110 Attorney for Plaintiff . (J~jJ (~~ a.t If" . CJ<t , \., " PETERS a WASII..EFSKI An'1"NIV. ,..1>10 COUN.''''~' AT I.AW a831~~OI"T .T"IIlt" H...,.IMU"O, ~IlNN'Y"'Vt'NI'A "1'0 T.......DN.1711) U"7111111 .---~' D~C, 3 '1 lffJt/I', ,--.-- .. L.B, SMITH FORD, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Petitioner CV 19.??oo431-97 '77-7IH, e:..:( ft.-,., v, MARK H, GIESELER Respondent ORDER AND NOW, upon consideration of the Petition for L. B. Smith Ford for Leave to Appeal Nunc Pro Tunc from the November 26, 1997 Judgement of District Justice Charles A, Clement, Jr., it Is here by ORDERED that the time for tiling an Appeal inl this matter Is extended and Petitioner is permitted to Appeal Nunc Pro Tunc from the November 26, 1997 Judgment of District Justice Charles A. Clement, Jr., provided such appeal is tiled no later than 10 days from the entry of this Order, Ry the Court: J. PYS510 1997-07186 SMITH L Cumberland County Prothonotary's Civil Case Inguiry B FORD (VS) GIESELER MARK H Office Page 1 Referenc~ No..1 Filed........1 Calle 'l'ype..... I PETITION Time. 'I" " " I JUdgment '1' . . . I ,00 Exec;ut Qn Date Judge Ass gnedl OLER J WESLEY JR Sat/Dis/Gntd. . Jurn Trial.... Hi~ er Court 1 Hi er Court 2 **********************************~******************** *******************.**** General Index Attorney Info SMITH L B FORD PETITIONER GARVER JAMES A 12TH ~ MARKET STREETS LEMOYNE PA 17043 GIESELER MARK H 816 RIDGEWOOD DRIVE MECHANICSBURG PA 17055 1/02/1998 8~88~88~~ RESPONDANT .***..*.********************.*.*.*..***....**...........**..*.**..*.*..**..****. * Date Entries * ***..*******..***.*....*....*****.******************.****************.****..**** PETITION FOR LEAVE TO FILE APPEAL NUNC PRO TUNC FROM JUDGMENT OF DISTRICT JUSTICE CHARLES A CLEMENT JR ORDER OF COURT - DATED 1/12/98 - IN RE PETITION FOR LEAVE TO FILE APPEAL NUNC PRO TUNC FROM JUDGMENT OF DISTRICT JUSTICE CHARLES A CLEMENT JR - RULE IS ISSUED UPON DEFENDANT RETURNABLE 20 DAYS OF THIS DATE - ARGUMENT SHALL BE HELD 3/5198 9 AM CR 1 - BY J WESLEY OLER JR J - COPIES MAILED 1/14/98 *****.***.***.**..*****************.*******************************...**....***. * Escrow Information * · Fees & Debits Bea Bal Pvmts/Ad1 End Bal * *************.************.*****-*.****.*.******,.*****************..****...**** 12/31/97 01/14/98 35.00 35.00 .00 .50 ,50 '.88 5.00 5.00 5.00 5.00 .00 ------------------------ ------------ 45,50 45.50 .00 .***.******************.**.****************************************...***...*.** * End of Case Information .. ..........**....*.....**.****.......***************.*****.**.....**...***....... PETITION TAX ON PETITION SETTLEMENT JCP FEE PETERS l!c W ASILEFSKI I" ATTOJlllNIlV. AND COUNKI.OR. AT L.AW a~ ,..,.ON......,.,UIIlT HA""IHUftQ, flJIlNN.VI.VANlA '7"0 T....II~ON. (717) 23B"71S1US ~-'--' ~...... L.B. SMITH FORD, IN THE COURT OF COMMON PLEAS. CUMBERLAND COUNTY, PENNSYLVANIA Petitioner CV 19-0000431-97 1".7Ift.C,vd'rt- v, MARK H. GIESELER Respondenl RULE TO SHOW CAUSE WHY LEAVE SHOUL\) NOT BE GRANTED TO APPEAL NUNC PRO TUNC FROM JUDGMENT OF' DISTRICT JUSTICE CHARI,J:S A. CLEMENT. JR. AND NOW, upon consideration of the Petition of L.B. Smith Ford for Leave to Appeal Nunc Pro Tunc from the November 26, 1997 Judgement of District Justice Charles A. Clement, Jr.. a RULE is hereby entered Oil Mark H. Gieseler to show cause. why the time for filing an appeal in this mailer should not be extended. By the Court: DEC. a 11997fi> JAN 2 9 1998 1b. L,B. SMITH FORD, . Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. MARK H. GIESELER Respondent ~ESPONDENT'S BRIEF IN REPLY TO PETITIONER'S REOUE$T fOR LEAVE TO FILE APPEAL NUNC PRO TUNC FROM JUDGMENT CV 19-0000431-97 I. PROCEDURAL HISTORY AND STATEMENT OF FACTS Thie is ;;J. civil action brought by the Respondent, Mark H. Gieseler, (Gieseler) ;;J.rising out of work performed on his 1991 Ford Explorer by Petitioner, L.B. Smith Ford (Petitioner). On November 25, 1997, Gieseler, ;;J.cting as a Pro Se plaintiff, presented his case to District Justice Charles A. Clement, Jr. Judgment was entered in Gieseler's favor on November 26, 1997, and notice thereof was provided to both parties by mail. On December 29, 1997, thirty-three (33) days following service of the District Justice's judgment, Gieseler verified with the Prothonotary that no notice of appea.l had been filed by petitioner in the matter at hand. He then requested the Court enter in his favor a judgment on the award of the District Justice, A true and correct copy is attached as Exhibit "A". On or about January 7, 1997, Gieseler received an unverified copy of Petitioner's PETITION FOR LEAVE TO FILE APPEAL NUNC PRO TUNC in the mail. At no time had Petitioner, nor its attorneys, contacted Gieseler to express its intentions to file an appeal in this matter. II. STATEMENT OF OUEST ION PRESENTED: WHETHER PETITIONER'S FAILURE TO ANTICIPATE THE SPEED OF THE UNITED STATES POSTAL SERVICE OVER THE CHRISTMAS HOLIDAY CONSTITUTES 'GOOn CAUSE', WHICH EXCUSES IT FROM ITS FAILURE TO TIMELY FILE AN APPEAL PURSUANT TO THE PENNSYLVANIA RULES OF CIVIL PROCEDURE. (Suggested Answerl No.) I II, ARGUMENT: 'upon good cause shown, I.d.. In the matter at hand, the Prothonotary of Cumberland County properly refused to accept the appeal of the 2 Petitioner after it was received in the mail three days after the time for the filing of a proper appeal had expired. The trial court has discretion to determine whether there is good cause for reinstating the appeal. SlauGhter v. AllW HeatinG, 431Pa. Super. 348,636 A.2d 1121 (1993). No hard rule exists for what will constitute good cause shown; however, the Superior Court has found such good cause where the Petitioner has made a Good faith attemot to comply with the Rules, ~, 438 Pa. Super, 525, 652 A.2d 935 (1995), Voland v. In the case at hand, Petitioner has alleged no facts which constitute a g~od faith effort to comply with the Rules. Petitioner blames the failure to ti.mely file the appeal on the slow holiday mails. However, recent appellate authority in this INI-.,,, Commonwealth rejects the ~tion that a party can blame the mail ~ other' reasonable and relatively effortless actions ..l.illH would have effected the timely filing of the appeal. In Hanni v. Penn Warrantv Corooration, 442 Pa.super. 160, 658, A2d. 1349 (1995), Appellant failed to file proof of service of its notice of appeal within the ten days provided under Pa. R, Civ. p, D. J. 1005(8), and the Prothonotary appropriately struck the appeal. In denyi,ng Penn Warranty's petition to reinstate the appeal, the trial court noted that the Appellant "chose to trust the timeliness of the regular llIail during the holiday season, when it could have used an Express Mail service, or brought the proofs of service to the 3 Prothonotary by hand to be docketed within the ten-day limit." The Superior Court found that the trial court had not abused its discretion in denying the Appellant's petition, and affirmed the decision of the Trial Court. Like the defendant in fuUIlU" the Petitioner in this case failed to exercise even the most minimal effort to comply with the Rules, Petitioner not only disregarded the obvious delays in the mail which occur around the Christmas holiday, but also failed to undertake any number of otherwise reasonable and relatively effortlesll actions such as hand delivering the appeal to the Prothonotary's office, sending the appeal via courier (which can guarantee delivery dates), or, lastly and perhaps requiring the least amount of effort, simply calling the Prothonotary to confirm receipt and filing of the appeal. Petitione~'s efforts were unreasonable and clearly carried with them a high risk that the appeal would not reach the Prothonotary's office and be filed within the specified time, The lack of a reasonable effort by the Petitioner certainly cannot be attributed to a lack of knowledge of the applicable rules, as Petitioner was represented by a competent counsel at the time, or to any unforeseen intervening cause creating an untimely del~y, It would be simply unfair to allow Petitioner to succeed in failing to follow the very Rules by which even Gieseler, a Pro Se plaintiff, complied. 4 IV, CONCLUSION I For the reasons set forth above, Respondenr. Mark H. Gieseler respectfully submits that the Petitioner has failed to show good cause why, it should be allowed to file an appeal Nunc Pro Tunc in the matter at han~, and its Petition should therefore be denied. Dated: ,By 5 1Le, 'i'7'll.)r~r.v- NOTICE OF JUDGMENTITRANSCRIPT CIVIL CASE PLAINTIFf: NMAh"" ADDA..6 'GIBSELER, HARK II. -, 816 RIDGBWOOD DRIVE MBCllANICSBURG, PA 17055 L ~ V5. DEFENDANT: NAM..""AD""'.6 rtB flMITII PORD 12TII & MARKET 8TRBBTS LEMOYNB, PA 17043 L COMMONWEALTH OF PENNSYLVANIA COUNTY OF' CtlMBBRIJ\ND '-- - 09-1-01 M'\l 01". No-: OJ Narn.; 1l0f'j C1lARLBS A. CLEMENT, JR. hi'"'' 1106 CARLISLB ROAD CAMP IIILL, PA ""p"'" (717) 761.4940 17011 MARK II. GIBSBLER 016 RIDGBWOOD DRIVE KBCIlANICSDURG, PA 17055 Dockol No,: CV' 0000431- 97 Dolo Fllod: 9/30/97 ~ Ii THIS IS TO NOTIFY YOU THAT: J'Jugment: ~lLl'LAllm:~F Lx] Judgment was entered lor: (Name) -GIEARY,RR,-1!IAR1LH G-.:] Judgment was enterod against: (Name) T.R SMYTH PORD___,., In the amount of $ (Dalo of Judgmentl 11/2f\/Q'7 2,nnn f\" on: o Defendants are Jointly and sevorally liabla. D Damages will be assessed on: (Date & Time) . [J This case d1smlssoad without proJudlce, Amount 01 Judgment Judgment Costs Interesl on Judgment Attorney Fees TOlal [l Amounl 01 Judgment Subjeclto AttachmenVAct 5 011996 $ Post Judgment Credits Post Judgmllnl Costs D Levy Is stayed for days or D generally slayed, Certified Judgment ToI,al $ D ObJaction to lavy has been flied and hearing will be hold: Ir:= E--. '" Place: ~ .- -, _I - $ 1.948.65 $ 52.00 $ .09 $ .00 $ 2,000.65 $---- $ ------------ ------------ , ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WlTtl THE PAOTHONOTAAYICI.EAK OF THE COUAT OF COMMON PLEAS, CIVil DIVISION. YOU MUST INCLUDE A COpy OF nlls NOTICE OF JUD~ENT CRlPT F OUA NOTICE OF APPEAL. _J.1-2~J_ Date ~ Ui r trlet Justice I certify that this Is a trund 11-26-97 Date \..~ ( \ District Justice My commission expires first Monday 01 January, AOPr: 315-96 2002 SEAL EXHIBIT "A" '" " " " " , , i" I; JI " if " "", :2!, ~ .~ II !1 " ~hh': " .' " i,l'll ,.1 " , , , , .',j ',I " " if " , r" T,. , , ',' " , " , \" , ...t1 F.i:B, 18 '998 , , One day later, on Decemher 31, 1997, Petitioner t1Ied with this Ilonorable Court a Petition till' Leave 10 File an Appell I Nunc Pro Tunc from the Judgment of District Justice Charles A, Clemel1l, Jr. A veri lied copy of Petitioner's Petition was serviced upon Respondent. II. STATEMENT OF OUESTION 1'lmSENTlm WHETHER THIS HONORABLE COURT SHOULD ALLOW PETITIONER'S APPEAL NUNC PRO TUNC WHERE THE APPEAL IS UNTIMELY BECAUSE OF NON-NEGLIGENT BEllA VIOR ON THE PART OF PETITIONER'S COUNSEL, THE APPEAL IS FILED WITHIN A SHORT TIME AFTER PETITIONER'S COUNSEL LEARNS OF UNTIMELINESS, AND THE ELAPSED TIME PERIOD IS VERY SHORT. (Suggested Answer: Yes). III. ARGUMENT Although most Court paperwork is considered to he filed at the time of its postmark, Notices of Appelll arc unique in that they are not t1Ied until actually received by the Prothonotary. Here, the Prothonotary was correct in refusing to accept Petitioner's untimely Appeal. However, anappealll/lIle pro lime may he allowed when a delay in filing the Appeal is caused by extraordinary circumstances involving fraud or breakdown in the Court's operation through a default of its oflicers. Cook V, UllemDlovmelll COli/Delisa/loll Board Q,f Review, 543 Pa, 381, 671 A,2d 1130 (1996). These traditional grounds for allllwing an appeal /lllIle pro IUlle were extended by our Supreme Court in lla.tl: v. Bureau of Correctlolls, 485 Pa, 256,401 A.2d 1133 (1979). In that case, the delay in t1Iing the Appeal was due to counsel's secretary's illness. The lhm Court held that members of the public should not lose their day in 2 Dccember 31, 1997, merely livc days outside of lhc requircd lime pcrlod and merely one day following notice of the untimclincss of Ihc original Appc:11. Morcovcr, it is submiued that Rcspondclll has not hccn prejudiced hy Ihe minimal dclay. In addition, desplle Respondent's argumclll, the Pennsylvania Superior Court has hcld thai a dclay in the mall could hc suflicielllgrounds on which to allow an appealmlnc pro /lII/C, In McKeall COlli/IV Alllmal Hamlla' v. Illlrtiick, 700 A.2d 541 (POI. Super 1997), a Districl Justice's delimll judglllent was elllcred against the Appellant on January 29, 1996, The Appellant c1almcd lhal he intended 10 appeal to lhe Court of Common Picas and, in tilCt, Illalled his Noticc of AppcallO thc Prothonotary 10 days before thc 30 day appcal pcriod expired. However, the U.S. Postal Service fallcd to delivcr the Notlcc until 14 days aftcr it was mailed, thus cxceeding the appeal period by 4 days. The Appellant filed an appeal mll/c pro IIII1C, arguing that it should be allowed based on the faclthatthe Notlcc of Appeal was mailed wcll wilhin thc appeal period. The Superior Courl held that lhe rccord did not provide cnough information aboulthc circumstances causing the untimcly Appeal. Thc court stated that there was no sworn testimony of record, only argumcnt by counsel on the record cxplaining thc reason for the delay. However, ti,e Superior Court IIeld tllat tile ollegatlolls, if supported by facts believed by tile trial court, could be slifflclellt groullds to support to all appeal IIlIl/C pro tUIIC. Consequcntly, the Supcrior Courl remanded the case for the creation of the record. 4 ~ December 31, 1997, merely five days outside of the required time period and merely on, day following notice of the untimeliness of the original Appeal. Moreover, it is submitted that Respondent has not been prejudiced by the minimal delay, In addition, despite Respondent's argument, the Pennsylvania Superior Court has held that a delay in the mail could be sufticient grounds on which to allow an appeal nunc pro lunc. In McKean County Animal Hosoital v. Burdick, 700 A.2d 541 (Pa. Super 1997), a District Justice's default judgment was entered against the Appellant on January 29, 1996. The Appellant claimed that he intended to appeal to the Court of Common Pleas and, in fact, mailed his Notice of Appeal to the Prothonotary 10 days before the 30 day appeal period expired. However. the U.S. Postal Service failed to deliver the Notice until 14 days after it was mailed. thus exceeding the appeal period by 4 days. The Appellant filed an appeal nunc pro IUne, arguing that it should be allowed based on the fact that the Notice of Appeal was mailed well within the appeal period. . The Superior Court held that the record did not provide enough information about the circumstances causing the untimely Appeal. The court stated that there was no sworn testimony of record, only argument by counsel on the record explaining the reason for the delay. However, the Super/or Court held that the allegations, if supported by facts believed by the trial court, could be sufficient grounds to support to an appeal nunc pro tunc. Consequently, the Superior Court remanded the case for the creation of the record. 4 One day later, on December 31. 1997, Petitioner llIed with this Honorable Court a Petition for Leave to FUe an Appeal Nunc Pro Tunc from the Judgment of District Justice Charles A. Clement, Jr. A verified copy of Petitioner's Petition was serviced upon Respondent, II. STATEMENT OF OUEST ION PRJi;SENTED WHETHER THIS HONORABLE COURT SHOULD ALLOW PETITIONER'S APPEAL NUNC PRO TUNC WHERE THE APPEAL IS UNTIMELY BECAUSE OF NON-NEGLIGENT BEHAVIOR ON THE PART OF PETITIONER'S COUNSEL. THE APPEAL IS FILED WITHIN A SHORT TIME AFTER PETITIONER'S COUNSEL LEARNS OF UNTIMELINESS, AND THE ELAPSED TIME PERlOD IS VERY SHORT. (Suggested Answer: Yes). m. ARGUMENT Although most Court paperwork is considered to be l1Ied at the time of its postmark. Notices of Appeal are unique in that they are notl1led until actually received by the Prothonotary. Here, the Prothonotary w.u correct in refusing to accept Petitioner's untimely Appeal. However, an appeal nunc pro tunc may be allowed when a delay in filing the Appeal is caused by extraordinary circumstances involving fraud or breakdown in the Court's operation through a default of ilS officers. Cook v. Un,mDlovm,nt ComD.nration Board of R,vl.w, 543 Pa. 381. 671 A.2d 1130 (1996). These traditional grounds for allowing an appeal nunc pro tunc were extended by our Supreme Court In Barr v. Burtau ofCo",cdonr, 485 Pa. 256, 401 A.2d 1133 (1979). In that case, the delay In I1Ilng the Appeal was due to counsel's secretary's illness. The /1g1J. Court held that members of the public should not lose their day In 2 Court because of their counsel's non-negligent conduct and granted Bass leave to tile an appeal nunc pro tunc. Furthennore, in Cook v. UnemD[ovment Compensation Board of Review, supra, our Supreme Court, in granting an appeal f1une pro tunc, further extended the holding in /hIH.: Where an appeal is not timely because of non-negligent circumstances, either as they relate to Appellant or his counsel, and the appeal is tiled within a short time after the Appellant or his counsel learns of and had an opportUnity to address the untimeliness and the time period which elapses is of very short duration, and Appellee is not prejudiced by the delay, the Court may allow an appeal nunc pro tunc. lJl. at 384,671 A.2d at 1131. In this case, the Appeal was not timely because of non-negligent circumstances. The Appeal, due to be filed on Friday, December 26, 1997, was mailed from Harrisburg on the preceding Monday. The usual mailing time from Harrisburg to Carlisle is one day. Even given the Christmas holiday season, it is respectfully submitted that it is not negligent to fail to foresee that mail from Harrisburg to Carlisle would take one week to be delivered. Furthennore, in this case, Petitioner's counsel received notice from the Cumberland County Prothonotary on Declo'mber 30, 1997 that the Appeal was not accepted. The following day, December 31, 1997, Petitioner filed the instant Petition for Leave to File an Appeal Nunc Pro Tunc. Thus, the time period which elapsed was of very short duration, in that, while the Appeal was required to be tiled by December 26, 1997, the Petition for Leave to File an Appeal Nunc Pro Tunc was tiled on 3 December 31, 1997, merely t1ve days outside of the required time period and merely one day following notice of the untimeliness of the original Appeal. Moreover, it Is submitted that Respondent has not been prejudiced by the minimal delay, In addition, despite Respondent's argument, the Pennsylvania Superior Court has held that a delay in the mail could be sufficient grounds on which to allow an appeal nunc pro tunc. In McKean Coun(X Animal Hospital v. Bllrdick, 700 A.2d 541 (Pa. Super 1997), a District Justice's default judgment was entered against the Appellant on January 29, 1996. The Appellant claimed that he intended to appeal to the Court of Common Pleas and. in fact, mailed his Notice of Appeal to the Prothonotary 10 days before the 30 day appeal period expired. However, the U.S. Postal Service failed to deliver the Notice until 14 days after it was mailed, thus exceeding the appeal period by 4 days. The Appellant filed an appeal nunc pro tUIIC, arguing that it should be allowed based on the fact that the Notice of Appeal was mailed well within the appeal period. The Superior Court held that the record did not provide enough infonnation about the circumstances causing the untimely Appeal. The court stated that there was no sworn testimony of record, only argument by counsel on the record explaining the reason for the delay. Howev", the Superior Court held thai the a/legadons, if supported by facts believed by the trial court, could be sufficient groullds to support to an appeal nunc pro tunc. Consequently, the Superior Court remanded the case for the creation of the record. 4 '\1 , ',:i\;)', , , " i.i' , " " " , d,I::" ,t; I ~t~, ii~'i,', ,j 'I' ")I',', j 'ii~I'''-IIJ'h'(1 !\"'I'-' ! ' ~::;!t.. th"':' '.Ii" :! '11 ~1,d.L -'III ~., "I \, ;L~{:~~i~:I~}-':,: i~;~,~'~: :I)/;! ',; ;' '\ '~;\':i~~v;l;(~r.l~', t', 1/';--' ii' ";';, '; , f.?rfi ;:I~"'\' . ',jf 't ,I~, J 11, "J' ' . t. IU, " ~ , ; '; 'I.'!' I . r 1 . 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