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HomeMy WebLinkAbout2016-6488KATTIERINE PRO O. Plaintiff V. RICHARD JORAY and CLYDIENE LIVERMAN FRANCIS, Defendants NO. 2016-6488 CIVIL TERM IN RE: OPINION PURSUANT TO PA. R.A.P. 1925 OLER, S.J., March 9, 2018. In this landlord/tenant case arising out of Defendants' failure to pay rent on a residential lease, Defendant Clydiene Liverman Francis has filed an appeal to the Pennsylvania Superior Court' from a corrective order relating to an attachment of her wages.2 She has also filed an appeal in a similar, companion case? The bases for the appeal have been expressed in a statement of errors complained of on appeal as follows: 1. The Court's ex parte grant of Plaintiffs motion to direct the Prothonotary of Cumberland County to issue an amended writ of attachment without providing Defendant an opportunity to be heard was in violation of Defendant's constitutional right to due process of law. 2. The Court erred as a matter of law by considering Defendant's gross income rather [than] her net income when it denied her claim for exemption pursuant to PA Rule of Civil Procedure 3312 and Section 8127(a)(3.1) of the Judicial Code. 1 Notice of Appeal at No. 2016-6488 Civil Term (Cumberland Co.), filed December 1, 2017. The instant case is docketed in the Superior Court at 1863 MDA 2017. Z See Order of Court, dated November 3, 2017. The order was issued by the Honorable M.L. Ebert, Jr., who has since retired from the Cumberland County bench to assume the duties of Cumberland County District Attorney. The case has been assigned to the undersigned senior judge. Order of Court, dated January 4, 2018. s Notice of Appeal at No_ 2016-5219 Civil Term (Cumberland Co.), filed December 1, 2017. This companion case is docketed in the Superior Court at 1864 MDA 2017. l 3. The Court erred as a matter of law by considering child support, Supplemental Nutrition Assistance Program ("SNAP") benefits (formerly known as "food stamps"), the Earned Income Tax Credit CFITC % and an anticipated federal income tax refund in calculating Defendant's income for purposes of determining her claim for exemption pursuant to PA Rule of Civil Procedure 3312 and Section 8127(a)(3.1) of the Judicial Code_a This opinion in support of the order appealed from is written pursuant to Pennsylvania Rule of Appellate Procedure 1925(a). STATEMENT OF FACTS As the result of a magisterial district judge's award of $7,416.65 in favor of Plaintiff and against Defendants, jointly and severally, for unpaid rent on a residential lease, on January 20, 2015, judgment was entered in this court on November 18, 2016.5 On November 30, 2016, Plaintiff filed a praecipe for notice of intent to attach wages of Defendant Francis paid by her employer, the Central York School District,6 for purposes of collection of the judgment.' The notice (a) was issued by the prothonotary on November 30, 2016, (b) advised of the institution of proceedings to attach 10% of Defendant's wages to collect the rental debt, and (c) indicated the availability of an exemption, or partial exemption, where the debtor's net income fell, or would fall, below poverty income guidelines provided by the federal Department of Health and Human Services! Defendant Francis filed a pro se 4 Defendant's Statement of Errors Complained of on Appeal, filed March 2, 2018. Although a motion for reconsideration of the order on appeal was timely filed by Defendant Francis, this court did not enter an order granting reconsideration within 30 days of its entry, as a consequence of which jurisdiction of the case resides in the Superior Court. See Pa. R.A.P. 1701(b)(3); Order of Court, dated February 14, 2018. 5 Notice of Judgment/Transcript, filed November 18, 2016; see PaJLC.P.M.D.J. No. 402A. 6 Praecipe for Notice of intent to Attach Wages, filed November 30, 2016; see Pa. R.C.P. 3302(a). See Certification by Judgment Creditor—Landlord, filed November 30, 2016. s Notice of Intent To Attach Wages, Salary or Commissions, filed November 30, 3016; see Pa. R.C.P. 3302(b). 2 claim for total exemption from wage attachment on December 12, 2016, asserting that her net income was already below the poverty income guidelines.9 A hearing on the exemption issue was held by the Honorable M.L. Ebert, Jr., of this court on February 24, 2017.10 The evidence did not, in the court's view, establish that Defendant's net income fell below, or would fall below, the applicable poverty income guidelines, and at the conclusion of the hearing the following order was issued: AND NOW, this 241h day of February, 2017, after hearing in the above -captioned matter on the Plaintiff's Motion to Direct the Prothonotary to issue a Writ for Attachment of the wages pursuant to Pa. R.C.P. 3303(c); IT IS HEREBY ORDERED AND DIRECTED that the Prothonotary shall issue a Writ of Attachment of Wages for 10 percent of the net wages of Clydiene Liverman Francis against the following employer. Central York School District, Attention: Payroll Department -Stacey Frey, 775 Marion Road, York, Pa. 17406. The total amount attached is $7,416.65 plus costs and the interest. IT IS FURTHER ORDERED AND DIRECTED that Central York School District shall take no punitive action against Clydiene Liverman Francis as a result of this attachment." Distributees of the order included Defendant Francis, who was in court when it was dictated, and her employer, the Central York School District. 12 No appeal was taken from the order. The writ of attachment subsequently issued by the prothonotary in response to Judge Ebert's order, unfortunately, was a generic one simply instructing the employer, inter alia, to "attach and deduct from the wages of the above employee a sum not to exceed ten (10%) of the net wages per pay period of said employee or a sum not to place employees [sic] net income below poverty income guidelines as provided annually by the Federal Office of Management and Budget, whichever is less."13 To the extent that this 9 Claim for Exemption from Wage Attachment, filed December 12, 2016. to See Order, dated December 27, 2016 (issued in response to Plaintiff s Motion To Direct Prothonotary To Issue a Writ for the Attachment of Wages Pursuant to Pa.R.C.P. 3303(c), which motion noted the need for a hearing on the exemption claim). " Order of Court, dated February 24, 2017. The order was entered on the docket on March 1, 2017. 12 Id 13 Writ of Attachment, filed March 1, 2017 3 writ, construed out of the context of the order that precipitated it, could be understood to leave a determination of the exemption issue already litigated to the employer, Judge Ebert issued the following corrective order on November 3, 2017, in response to a motion of Plaintiff:" AND NOW, this 3d day of November, 2017, upon consideration of Plaintiff's Motion to Direct Prothonotary to Issue Amended Writ of Atiacliment in Compliance with Pa.RCR 3313, said motion is granted. Following the hearing conducted on February 24, 2017, this Court rejected the claim of Defendant, Clydiene Francis, for excmption. It is therefore directed that the Prothonotary issue the attached Amended Writ of Attachment, which conforms to Pa. R.C.P. 3313, to Central York School District's payroll department along with a copy of the within Order. From this order, Defendant Francis has filed an appeal to the Superior Court. STATEMENT OF LAW "It is well settled in Pennsylvania that a trial court has the inherent, common-law authority to correct `clear clerical errors' in its orders." Commonwealth v. Borrin, 2011 PA Super 10, IL_, 12 A.3d 466, 471 (citations omitted), ajfd on other grounds, 622 Pa. 422, 80 A.3d 1219 (2013). Inherent in the court system is the court's power "to amend records, to correct mistakes of court officers or counsel's inadvertencies, or to supply defects or omissions in the record." Commonwealth v. Quinlan, 433 Pa. Super. 111, 118, 639 A.2d 1235, 1239 (1994); see also Manufacturers and Traders Trust Co. v. Greenville Gastroenterology, S.C., 2015 PA Super 15, 108 A.3d 913; Manak v. Sandlin, 2002 PA Super 328, 812 A.2d 676; Fish v. Gosnell, 316 Pa. Super. 565, 463 A.2d 1042 (1983). "The inherent power of the court to correct obvious and patent mistakes is not eliminated by the expiration of the thirty -day appeal period." Commonwealth v. Quinlan, 433 Pa. Super. 111, 118, 639 A.2d 1235, 1239 (1994). Furthermore, "[a] trial court maintains this authority even after the expiration of the 30 day time limitation set forth in 14 See Motion To Direct Prothonotary To Issue Amended Writ of Attachment in Compliance with Pa.RC.P. 3313, filed October 27, 2017. 4 42 Pa.C.S.A. §5505 for the modification of orders."15 The power may be exercised by the court sua sponte. 16 APPLICATION OF LAW TO FACTS In the present case, the writ of attachment issued by the prothonotary represented a clerical error to the extent that it could be interpreted as authorizing a determination of Defendant's exemption status by her employer inconsistent with the court's adjudicated directive on the issue. While the reasonableness of such an interpretation may be arguable in light of the clarity of the order that accompanied the writ, when the court became aware of the putative error it exercised its power to correct it --a power that could be exercised sua sponte, without regard to any party's preference to the contrary and without a requirement that the merits of the underlying order be reajudicated. BY THE COURT, /V (1-17al / I J Lesley Olei, r., SJ.. Mark F. Bayley, Esq. Bayley & Mangan 17 West South Street Carlisle, PA 17013 Attorney for Plaintiff George R. Studzinski, Esq. MidPenn Legal Services 29 North Queen Street York, PA 17403-1428 Attorney for Defendant Clydiene Liverman Francis Richard Joray 141 East Main Street Mechanicsburg, PA 17055 Defendant pro Se is Commonwealth v. Borrin, 2011 PA Super 10,t, 12 A.3d 466, 471, ard on other grounds, 622 Pa. 422, 80 A.3d 1219 (2013). 16 Commonwealth v. Quinlan, 433 Pa. Super. 111, 118, 639 A.2d 1235, 1239 (1994). 5