HomeMy WebLinkAbout93-1576 CivilWILLIAM F. KANE, Plaintiff
VS.
THOMAS GAUGHEN, THOMAS
GAUGHEN REALTY and
CHARLES GEROW,
Defendants
· IN THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
1576 CIVIL 1993
CIVIL ACTION -LAW
JURY TRIAL DEMANDED
IN RE: MOTION FOR SUMMARY JUDGMENT OF DEFENDANTS GAUGHEN
BEFORE BAYLEY AND HESS, JJ.
ORDER
AND NOW, this
day of September, 1998, the motion of the defendant
Thomas Gaughen and Thomas Gaughen' Realty for summary judgment is GRANTED.
Michael J. Navitsky, Esquire
For the Plaintiff
BY THE COURT,
,/
Douglas B. Marcello, Esquire
For Defendants Gaughen
Matthew Chabal, III, Esquire
For Defendant Gerow
:rim
WILLIAM F. KANE, Plaintiff
VS.
THOMAS GAUGHEN, THOMAS
GAUGHEN REALTY and
CHARLES GEROW,
Defendants
· ~ THE COURT OF COMMON PLEAS OF
· /CUMBERLAND COUNTY, PENNSYLVANIA
1576 CIVIL 1993
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
IN RE: MOTION FOR SUMMARY JUDGMENT OF DEFENDANTS GAUGHEN
BEFORE BAYLEY AND HESS, JJ.
OPINION AND ORDER
The events that give rise to the above captioned civil action occurred during the 1991
campaign for Cumberland County Commissioner. In that political race the plaintiff, William F.
Kane, was involved in a five-way primary contest that included defendant, Charles Gerow.
During the campaign, a mailing was produced and distributed that made allegedly disparaging
comments regarding the plaintiff. The letter stated at the bottom that its production and
distribution had been paid for by the "Conservative Republican Committee, a registered political
action committee," and that it was "[n]ot authorized by any Candidate or Candidate's
Committee." Subsequently, the letter became the subject of criminal charges against W. Gregory
Rothman, who is not a party to this action. The plaintiff contends that Mr. Rothman identified
defendant Thomas Gaughen and defendant Gerow as co-conspirators. The plaintiff asserts that
the letter was authored, produced, financed, and distributed by defendants Gerow, Gaughen, and
Thomas Gaughen Realty, as well as by Mr. Rothman. Following a discovery period that was
extended for the past year, defendants Gaughen and Thomas Gaughen Realty filed a motion for
1576 CIVIL 1993
summary judgment.
The current standard for summary judgment is set forth in Pennsylvania Rule of Civil
Procedure 1035.2, which states:
After the relevant pleadings are closed, but within such time as not
to unreasonably delay trial, any party may move for summary
judgment in whole or in part as a matter of law
(1) whenever there is no genuine issue of any material fact as to a
necessary element of the cause of action or defense which could be
established by additional discovery or expert report, or
(2) if, after the completion of discovery relevant to the motion,
including the production of.expert reports, an adverse party who
will bear the burden of proof at trial has failed to produce evidence
of facts essential to the cause of action or defense which in a jury
trial would require the issues to be submitted to a jury.
Pa.R.Civ. P. 1035.2.
The plain language of the rule makes it clear that the party who bears the burden of proof
at trial, in this case the plaintiff, must be. able to produce some evidence that it can in fact prove
the essential elements of its case at trial following the close of discovery. This standard was
adopted officially in 1996, however it was in use prior to the new rule. In 1991 the Pennsylvania
Superior Court stated .in essence the same standard:
It is clear that if a defendant is the moving party, he may make the
showing necessary to support the entrance of summary judgment
by pointing to materials which indicated that the plaintiff is unable
to satisfy an element of his cause of action.
Godlewski v. Pars Mfg. Co., 408 Pa. Super. 425, 431,597 A.2d 106, 109 (1991). In addition,
when considering whether summary judgment is proper, a court must examine the record in the
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1576 CIVIL 1993
light most favorable to the non-moving ~y, with all doubts resolved against the movir/g party,
Denlinger, Inc. v. Dendler, 415 Pa. Super. 164, 170, 608 A.2d 1061, 1064 (1992).
In the case at bar, defendants Gaughen and Thomas Gaughen Realty bring this motion for
summary judgment and assert that the plaintiff has failed to meet his burden. We agree. The
plaintiff has offered one deposition, a copy of the letter in issue, and three newspaper articles to
support his defamation action. The deposition of Mr. Rothman, who supposedly named the
defendants as co-conspirators, however, does not support the plaintiff's contentions. Mr.
Rothman asserted his Fifth Amendment privilege throughout and in doing so never named the
defendants as his co-conspirators. Ther~ is nothing in the offending letter which makes any
reference to the defendants. The newspaper articles, clearly inadmissible at the trial of this
matter, make reference to the existence of an affidavit signed by Mr. Rothman naming Gaughen
and Gerow as his co-conspirators. There is no evidence, whatsoever, in the record of this case
which supports that contention nor has discovery produced this alleged affidavit.
In the meantime, the defendant, Thomas Gaughen, has filed an affidavit in which he
states that he did not author, distribute, encourage or finance the document and, moreover, had no
knowledge of it nor was involved in its authoring, distribution or financing. We are mindful that
this affidavit, standing alone, is insufficient to grant summary judgment. It is well established
that summary judgment may not be gran. ted solely based upon the oral testimony of the moving
party. See Nanty-Glo v. American Surety_ Co., 309 Pa. 236, 163 A. 523 (1932); Penn Center
House, Inc. v. Hoffman, 520 Pa. 171,553 A.2d 900 (1989). When, however, the response of the
plaintiff contains no evidence of the facts essential to his cause of action, summary judgment is
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1576 CIVIL 1993
clearly warranted under the rules.
ORDER
AND NOW, this 2 ~ day of September, 1998, the motion of the defendant
Thomas Gaughen and Thomas Gaughen Realty for summary judgment is GRANTED.
Michael J. Navitsky, Esquire
For the Plaintiff
Douglas B. Marcello, Esquire
For Defendants Gaughen
Matthew Chabal, III, Esquire
For Defendant Gerow
:rim
BY THE COURT,
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