HomeMy WebLinkAbout98-6915 civilTERENCE S. HEVNER and
FAYE J. HEVNER,
Plaintiffs
Ve
BLUE RIDGE HAVEN WEST, INC.,
WEST SHORE HEALTH REHAB
CENTER, BEVERLY HEALTH AND
REHABILITATION, INC.,
BEVERLY ENTERPRISES, INC., and
BEVERLY ENTERPRISES OF
PENNSYLVANIA, INC.,
Defendants
· IN THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
o
· NO. 98-6915
·
·
· CIVIL ACTION-LAW
· JURY TRIAL DEMANDED
IN RE: PLAINTIFFS' PRELIMINARY OBJECTIONS TO DEFENDANTS' ANSWER
WITH NEW MATTER
BEFORE BAYLEY AND HESS, JJ.
ORDER
AND NOW, this ~'"day of July, 1999, the plaintiffs' preliminary objections to
defendants' answer with new matter are OVERRULED.
BY THE COURT,
Arthur K Hoffman, Esquire
Douglas M. Wolfberg, Esquire
Attorneys for Defendants
Leah B.Graff, Esquire
Attorney for Plaintiffs
Key~' A. Hess, J.
TERENCE S. HEVNER and
FAYE J. HEVNER,
Plaintiffs
Vo
BLUE RIDGE HAVEN WEST, INC.,
WEST SHORE HEALTH REHAB
CENTER, BEVERLY HEALTH AND
REHABILITATION, INC.,
BEVERLY ENTERPRISES, INC., and
BEVERLY ENTERPRISES OF
PENNSYLVANIA, INC.,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 98-6915
CIVIL ACTION-LAW
JURY TRIAL DEMANDED
IN RE: PLAINTIFFS' PRELIMINARY OBJECTIONS TO DEFENDANTS' ANSWER
WITH NEW MATTER
BEFORE BAYLEY AND HESS, JJ.
OPINION AND ORDER
This action was instituted by the plaintiffs, Terrence S. Hevner and Faye J.
Hevner, by the filing of a complaint on or about December 8, 1998. Plaintiffs alleged in
their complaint that Mr. Hevner, as a business invitee, fell on ice "which had
accumulated on the parking lot" at the West Shore Health and Rehabilitation Center,
owned and operated by Beverly Enterprises-Pennsylvania, Inc. Plaintiff alleged that the
fall occurred on December 20, 1996. Defendants filed an answer and new matter to
plaintiff's complaint on January 29, 1999. Defendants' new matter asserted affirmative
defenses of assumption of risk and contributory/comparative negligence.
Plaintiffs on February 23, 1999 filed preliminary objections to defendants'
Paragraph 25 (f), alleging that it was insufficiently specific to allow them to prepare a
response. Paragraphs 25 (a)-(e) lay out five specific bases for defendants' assertion of
the affirmative defense of contributory negligence and Paragraph 25 (f) states' in such
other manner as may be revealed during the course of discovery in this case.
Ever since Connor v. Allegheny General Hospital, 501 Pa. 306, 461 A.2d 600
(1983), the courts have been increasingly called upon to determine whether pleadings
comply with Pa.R.C.P. 1019 (a). The Connor court observed in a footnote, that the
defendant could have moved to strike an averment in the complaint alleging it was
negligent "in otherwise failing to use due care and caution under the circumstances" or at
least to have sought a more specific pleading. Fitzgerald v. Kaguyutan, 18 Pa. D. & C.4th
1, 5 (1993).
Case law in Pennsylvania is limited regarding situations where preliminary
objections have been filed to general averments raising affirmative defenses in new
matter. However, in Gotwalt v. York Hospital, 102 York L.R. 151 (1988), the Honorable
Richard H. Horn denied motions to strike or for more specific pleading because 1) of the
disparity in time available to plaintiffs and defendants in preparing their initial pleadings,
2) Pa.R.C.P. 126 allows courts to liberally construe the pleading roles, and 3) plaintiff
had ample opportunity to examine the hospital's pertinent medical records, so most facts
are within the knowledge of both parties thereby making the defenses raised predictable.
Fitzgerald v. Kaguyutan, 18 Pa. D. & C.4th 1, 5-6 (1993).
In a situation almost identical to the one at bar, Judge Michael A. Georgelis stated
in Latshaw v. Valeriano, et al:
I believe that the discovery process is the
appropriate way to uncover the viability of the
affirmative defenses which have been pled by the
defendants in their new matter. If that process
produces evidence which supports one or more of
those defenses, then the defendants may continue
to pursue them. On the other hand, if that process
failS to produce supporting evidence for one or
more of the defenses, and, in the event the
defendants refuse to abandon any such defense,
recourse will be available to the plaintiff. For all
of these reasons, I conclude that the Plaintiffs
preliminary objections to the defendant's new
matter are not the appropriate way to attack the
asserted affirmative defenses and must,
consequently be overruled.
Latshaw v. Valeriano, et al., No. CI-97-12452 (1998) (Lancaster C.P. 1998).
The foregoing conclusions follow all the more logically given the amendments
made in 1994 to the Rules of Civil Procedure, specifically Rule 1030, dealing with new
matter, which provided that:
(b) The affirmative defenses of assumption of the
risk, comparative negligence, and contributory
negligence need not be pleaded.
In this case, the plaintiff would have us require the defendant to more specifically plead
defenses which need not have been pled at all. Such an argument is not logical.
ORDER
AND NOW, this
day of July, 1999, the plaintiffs' preliminary
objections to defendants' answer with new matter are OVERRULED.
BY THE COURT,
Hess, J.
Arthur K Hoffman, Esquire
Douglas M. Wolfberg, Esquire
Attorneys for Defendants
Leah B.Graff, Esquire
Attorney for Plaintiffs