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HomeMy WebLinkAbout93-1973 Civil VINCE LOOSE and RUTH H. : IN THE COURT OF COMMON PLEAS OF LOOSE, Husband and Wife, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs : : V. : CIVIL ACTION - LAW : JEFFREY TAYLOR HOMES, INC. : and JEFFREY TAYLOR, : Defendants : NO. 1973 CIVIL 1993 IN RE: DEFENDANTS, PETITION TO OPEN DEFAULT JUDGMENT BEFORE HOFFER, BAYLEY* and OLER, Jj. ORDER OF COURT AND NOW, this~day of May, 1994, upon careful consideration of Defendants, Petition To Open Default Judgment, for the reasons stated in the accompanying Opinion, the Petition is DEEMED WITHDRAWN, and the Rule heretofore issued is DISCHARGED, as to Defendant Jeffrey Taylor Homes, Inc., and the Petition is GRANTED, and the Rule heretofore issued is MADE ABSOLUTE, as to Defendant Jeffrey Taylor. BY THE COURT, J. Jay Cooper, Esq. 320 Market Street Strawberry Square P.O. Box 1268 Harrisburg, PA 17108-1268 Attorney for Plaintiffs John D. Briggs, Esq. 3464 Trindle Road Camp Hill, PA 17011 Attorney for Defendants : rc * Bayley, j., did not participate in the consideration or decision of this matter. VINCE LOOSE and RUTH H. : IN THE COURT OF COMMON PLEAS OF LOOSE, Husband and Wife, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs : · : v. : CIVIL ACTION - LAW JEFFREY TAYLOR HOMES, INC. : and JEFFREY TAYLOR, : Defendants : NO. 1973 CIVIL 1993 IN RE: DEFENDANTS' PETITION TO OPEN DEFAULT JUDGMENT BEFORE HOFFER, BAYLEY and OLER, JJ. OPINION AND ORDER OF COURT Oler, J. This case presents the issue of whether a default judgment against a defendant may be opened, where the Defendant reasonably assumed that his legal interests were being protected by his counsel, where failure of the counsel to act prior to entry of the' judgment was a concomitant of health difficulties of counsel's spouse and discovery of a conflict of interest precluding his representation of defendant, where a petition to open was filed within a month of entry of the judgment, and where a meritorious defense was averred by defendant. For the reasons stated in this Opinion, the default judgment will be opened. Statement of Facts Plaintiffs are Vincent Loose and Ruth Loose. Defendants are Jeffrey Taylor Homes, Inc., and Jeffrey Taylor individually. On May 17, 1994, Plaintiffs obtained judgment against Defendant Jeffrey C. Taylor Homes, Inc., from the Honorable Susan K. Day, District Justice, in Mount Holly Springs, Cumberland No. 1973 CIVIL 1993 County, Pennsylvania.~ The judgment arose out of an alleged breach of warranty by the corporate defendant with respect to a home purchased by Plaintiffs.2 On June 14, 1993, the corporate defendant appealed from the district justice judgment.3 Pursuant to praecipe, a rule was entered upon Plaintiffs by the Prothonotary to file a complaint.4 On July 14, 1993, Plaintiffs filed a complaint naming Jeffrey Taylor Homes, Inc., as a defendant and adding Jeffrey Taylor individually as a second Defendant. The claims against the corporation were for breach of contract,s breach of express warranty,6 and violation of Pennsylvania's Unfair Trade Practices and Consumer Protection Law? in connection with a house which was built by and purchased from the corporate defendant and which ~ .See Notice of Appeal from District Justice Judgment, filed June 14, 1993. See id. Id. 4 Praecipe To Enter Rule To File Complaint and Rule To File Complaint, filed and entered June 14, 1993. Plaintiffs' Complaint, count I. Id., count II. ? Id., count III; see Act of December 17, 1968, P.L. 1224, as reenacted, 73 P.S. S§201-1 et seq. 2 No. 1973 CIVIL 1993 allegedly displayed water problems in the basement.8 The claim against the individual defendant, Jeffrey Taylor, was for misrepresentation in connection with the water problems.9 On August 5, 1993, according to affidavits of service of one John Granoff, Defendants were served with copies of the complaint.~0 On August 13, 1993, Mr. Taylor secured legal representation with respect to the litigation in the form of Sadis, Guido & Masland, a Cumberland County law firm.~ An associate of the firm with whom he conferred on that date discussed procedural and substantive issues with him and obtained information for preparation of a responsive pleading.~2 The file was given to a second associate in the firm for the purpose of research and the drafting of an answer.~3 In the absence of an extension, a responsive pleading appeared to be due on August Plaintiffs' Complaint, paragraphs 1-18. Id., count IV. ~0 Affidavits of Service, filed September 17, 1993. Because of the Court's disposition of this case, it is not necessary to consider the individual defendant's contention that service upon him, as a previous non-party, was defective for failure to utilize the sheriff. Brief in Support of Petition To Open Default Judgment, at 13. Deposition of William C. Vohs, Esq., N.T. 5. Id. Id. 3 No. 1973 CIVIL 1993 26, 1993,TM and the associate commenced work immediately;~S by August 19, 1993, he had completed research on the advisability of filing preliminary objections to the complaint and had drafted an answer.~ Unfortunately, the associate's wife became ill during pregnancy and on August 26, 1993, at 4:00 a.m. her condition had reached a point that an admission to a hospital emergency room had to be undertaken by the associate.~7 Their daughter was born on August 28, 1993.~8 It appears that the associate stayed in the hospital that weekend until Monday, August 30, 1993,~9 and remained at home with his wife and child immediately thereafter.20 On August 30, 1993, Mr. Taylor met with the first associate in the law firm to review and revise as necessary the draft of the answer which had been prepared by the second associate.2~ On September 1, 1993, he telephoned the firm's office, apparently to receive an update on progress on the case.22 Id., N. T. 6. Id., N.T. 5-6. Id., N.T. 5. Id. Id. Id. Id., N.T. 14. Deposition of Jeffrey C. Taylor, N.T. 28-29. Id., N.T. 29-30. 4 No. 1973 CIVIL 1993 On that same date, notices from Plaintiffs' counsel of intention to file a praecipe for entry of default judgment were received at a business owned by Mr. Taylor's father in Cumberland County, addressed to Defendants, sent by certified mail, and receipted by a receptionist.23 The notices were delivered to Mr. Taylor "around September 5th or 6th," 1993.24 According to his testimony in a deposition, Mr. Taylor stated that upon receipt of the notices he "would have called [the first associate in the law firm] ... and let her know that [he had] gotten that, to let her in on that at least [he] got some more 23 Id., N.T. 11; see Praecipes for Entry of Judgment, filed September 17, 1993. The notices were mailed on August 31, 1993. See Plaintiffs' Answer to Rule To Show Cause, paragraph 13 (new matter); Defendants' Reply to New Matter of Plaintiffs, paragraph 13. The reason that the notices were mailed to a business owned by Mr. Taylor's father is not entirely clear from the record. It appears that Mr. Taylor may have been an employee of his father's business. Deposition of Jeffrey C. Taylor, N.T. 11-12, 30. An allusion by Plaintiffs' counsel in a deposition question to having also sent the notices by certified and regular mail to the address given on the notice of appeal from district justice judgment prompted a response from Mr. Taylor that he assumed he had received at least the regular mail through postal forwarding. Id., N.T. 32. In earlier testimony, he indicated that he had moved from the address given on the notice of appeal from district justice judgment as of August 15, 1993. Id., N.T. 3. The default judgments eventually entered herein were predicated on the notices which came into Mr. Taylor's possession by way of his father's business. See Praecipes for Entry of Judgment, filed September 17, 1993. 24 Deposition of Jeffrey C. Taylor, N.T. 32. 5 No. 1973 CIVIL 1993 paperwork pertaining to this problem.-25 He could not, however, recall a specific conversation to this effect.26 Nor could he say for a fact that he gave a copy of the notices to the firm.27 At some time prior to a telephone conversation on September 16, 1993, with Mr. Taylor, the second associate in the law firm remembered an occasion in April or May of 1993 when Plaintiffs had met with him and discussed his possible representation of them in a suit against Defendants.~8 He brought this fact to the attention of the first associate, who suggested to him that Mr. Taylor be advised to return to a former attorney, Craig Diehl.29 Because of this unexpected discovery of a conflict of interest, a meeting scheduled with Mr. Taylor was not held and in a telephone conversation with Mr. Taylor on September 16, 1993, the second associate advised him that the firm's representation had to be withdrawn.3° Mr. Taylor retained Mr. Diehl on the same day.3~ Id., N.T. 32. Id. Id., N.T. 33. Deposition of William C. Vohs, Esq., N.T. 4, 7, 10, 11-12. His services were not ultimately retained. Id., N.T. 11. ~ Id., N.T. 18-19. ~o Id., N.T. 4, 13, 23. Until that telephone conversation, the firm was "actually representing him," according to the associate. Id., N.T. 23. Mr. Taylor was billed for the firm's services. Id., N.T. 8. ~ Deposition of Jeffrey C. Taylor, N.T. 15. 6 No. 1973 CIVIL 1993 According to testimony of the second associate, he called the Plaintiffs' attorney,32 and on September 17, 1993, sent a letter to Mr. Taylor confirming the withdrawal of representation and recommending the consultation with Mr. Diehl.33 On the morning of the same day the letter was sent, September 17, 1993, Mr. Taylor physically delivered his legal file to Mr. Diehl's office.34 At 3:30 and 3:31 p.m. in the afternoon, praecipes for entry of default judgments against Defendant Jeffrey Taylor and Defendant Jeffrey Taylor Homes, Inc., were filed on behalf of Plaintiffs. The judgment entered against Mr. Taylor was unliquidated; the judgment against the corporate defendant was in the amount of $27,921.00. By letter dated September 21, 1993, Defendants' new counsel wrote to Plaintiffs' attorney requesting an additional ten days within which to answer the complaint, citing the recent discovery of a conflict of interest by prior counsel.35 However, Plaintiffs' counsel responded by letter dated September 23, 1993, advising of the entry of default judgments against the Defendants on September 32 Deposition of William C. Vohs, Esq., N.T. 16-17. 33 Id., N.T. 9; Defendant's Petition To Open Default Judgment, Exhibit B. 34 Deposition of Jeffrey C. Taylor, N.T. 15. 35 Defendants, Petition To Open Default Judgement, paragraph 5, Exhibit C; Plaintiffs' Answer to Rule To Show Cause, paragraph 5. 7 No. 1973 CIVIL 1993 17, 1993, and explaining that as a consequence he was not in a position to facilitate the filing of an answer.36 On October 15, 1993, Defendants filed a Petition To Open Default Judgment, reciting the procedural history of the case and including as an exhibit a proposed answer with new matter to the complaint.37 The proposed responsive pleading contained averments contradicting, on behalf of the corporate defendant, the propositions that any contractual deficiencies in the construction of Plaintiffs' home had not been remedied, that any breach of warranty had occurred, and that a violation of the Unfair Trade Practices and Consumer Protection Law had been committed.~8 It also contained averments contradicting, on behalf of the individual defendant, the allegation that he made a misrepresentation as to water problems in the home.TM A Rule To Show Cause was issued upon Plaintiffs by the Honorable Kevin A. Hess with respect to Defendants' petition to open. An answer, containing new matter, was thereafter filed by 36 Defendants' Petition To Open Default Judgement, paragraph 7, Exhibit D; Plaintiffs' Answer to Rule To Show Cause, paragraph 7. Defendants' Petition To Open Default Judgement, Exhibit E. Id., paragraphs 1-35, 43-46. Id., paragraphs 36-42. 8 No. 1973 CIVIL 1993 Plaintiffs,4° and a reply to the new matter was filed by Defendants.4~ Depositions were then taken of Mr. Taylor and the aforesaid second associate.~2 In his deposition, Mr. Taylor presented, inter alia, an exculpatory version of his dealings with the Plaintiffs."3 The matter was subsequently listed for argument, briefs were submitted by the parties, and oral argument was held on March 30, 1994. In his brief and at oral argument, Defendants' counsel indicated that he was withdrawing the petition to open as to Defendant Jeffrey Taylor Homes, Inc., because of the corporation's filing of a bankruptcy petition.~4 Statement of Law It has been observed by a distinguished Cumberland County jurist and writer that "[d]efault judgments are not favored in the law." Shughart, Pennsylvania Civil Practice ~7.8, at 115 (2d ed. 1993). "The dislike of default judgments has resulted in the 40 Plaintiffs' Answer to Rule To Show Cause, filed November 12, 1993. 4~ Defendants' Reply to New Matter of Plaintiffs, filed January 6, 1994. ~2 These depositions were filed in the Prothonotary's Office on March 30, 1994. 43 Deposition of Jeffrey C. Taylor, N.T. 16-24. 44 Defendants' Brief in Support of Petition To Open Default Judgment, at 4. 9 No. 1973 CIVIL 1993 requirement of a special notice to the delinquent party of an intention to enter same.-45 This requirement, contained in Pennsylvania Rule of Civil Procedure 237.1, was designed to "ameliorate to some extent the default judgment problem." Pa. R.C.P. 237.1, Explanatory Note -- 1979. The Rule recognizes that "'It]here must be some point at which our courts must refuse to accept an attorney's negligent representation of his client when it interferes with orderly administration of justice.,-46 Consequently, the Rule "influence[s] the courts in defining the turning point at which grounds for opening judgments will no longer exist." Id. Thus, where the requisite notice of intention to enter a default judgment has been sent, it is believed that courts should be particularly circumspect before granting a petition to open. On the other hand, it is well recognized that "Ia] petition to open judgment is governed by equitable principles and is directed to the sound discretion of the court." 2B Anderson, Pennsylvania Civil Practice S1037.11, at 377 (1969). In this regard, it must be remembered that "[t]he purpose of the rules in authorizing the entry of default judgments is to prevent a dilatory defendant from impeding the plaintiff in establishing his claim. The rules are 45 Shughart, Pennsylvania Civil Practice §7.8, at 115-16 (2d ed. 1993). ~6 Pa. R.C.P. 237.1, Explanatory Note -- 1979, quoting Dupree v. Lee, 241 Pa. Super. 259, 266, 361 A.2d 331, 335 (1976). 10 No. 1973 CIVIL 1993 not primarily intended to provide the plaintiff with a means of gaining a judgment without the difficulties which arise from litigation." Moyer v. Americana Mobile Homes, Inc., 244 Pa. Super. 441, 445, 368 A.2d 802, 804 (1976). "Generally, three conditions must be met before a judgment can be opened: (1) the petition must be promptly filed; (2) the petitioner must aver a meritorious defense; and (3) there must be a reasonable excuse given for the failure to take the action resulting in the default judgment." Shughart, Pennsylvania Civil Practice S7.8, at 116-17 (2d ed. 1993). With respect to promptness of filing, "[i]t has been held ... that filing a petition to open a default judgment within ... generally less than 1 month, after the entry of the default judgment, meets the requirement of prompt filing." 12 Standard Pennsylvania Practice 2d §71.53, at 80 (1983). With respect to a meritorious defense, one commentator has stated as follows: Generally, a meritorious defense must be pleaded in a manner which shows that the defense asserted is genuinely meritorious and which shows that it can be established at trial. It has been stated that the petition must set forth facts which would support a verdict in favor of the petitioner. Unless the facts alleged in the petition in support of a defense to the original action are sufficient to have prevented a judgment in the original action, the petition is insufficient. In other words, if the statement of defense in the petition to open would have been a sufficient statement of defense in the 11 No. 1973 CIVIL 1993 original action, the statement will be taken as sufficient for purposes of the petition to open. 47 "[I]f the testimony taken [on the allegedly meritorious defense] would be sufficient to justify the submission of the question to the jury and to sustain a verdict in the petitioner's favor, the judge may ... open the judgment." 12 Standard Pennsylvania Practice 2d S71.137, at 239-40 (198~3). With.respect to a reasonable excuse for a defendant's failure to take the action resulting in the default judgment, a number of principles may be cited. First, it has been said that "pertinent case law reveals that the power to open judgment should be exercised when the default is the result of oversight or mistake by counsel." Versak v. Washington, 359 Pa. Super. 454, 460, 519 A.2d 438, 441 (1986). On the other hand, "while it is true that a mistake or inadvertence of counsel will often justify the opening of a default judgment ..., a reasonable excuse for the default must be offered." Vorhauer v. Miller, 311 Pa. Super. 395, 404, 457 A.2d 944, 949 (1983) (emphasis omitted). In this regard, an attorney's "dilatoriness, failure to act with knowledge of the implications, or deliberate decision not to defend" are to be distinguished from less culpable errors of the practitioner. See Davis v. Burton, 365 Pa. Super. 160, 163, 529 47 12 Standard Pennsylvania Practice 2d S71.123, at 217 (1983). 12 No. 1973 CIVIL 1993 A.2d 22, 23 (1987), allocatur denied, 518 Pa. 655, 544 A.2d 1342 (1988). Illustrative of this distinction is the statement that "[a] default judgment may be opened where the defendant's attorney was prevented from looking after his client's interests because ... of an illness in his family .... " 12 Standard Pennsylvania Practice 2d S71.87, at 164 (1983). Second, delays precipitated by the discovery of a conflict of interest by counsel have factored into decisions by courts to exercise their discretion to open default judgments entered in technical compliance with the rules. See, e.g., Moyer v. Americana Mobile Homes, Inc., 244 Pa. Super. 441, 368 A.2d 802 (1976) (lower court's refusal to open judgment reversed). A withdrawal of counsel is similarly treated. See, e.g., Williams v. Allegheny Union Plaza, Inc., 231 Pa. Super. 170, 332 A.2d 493 (1974) (lower court's refusal to open judgment reversed). Third, a mistaken and reasonable belief on the part of a defendant that counsel was protecting his or her interests is another factor that has been held to militate in favor of opening a judgment entered by default. See, e.g., Versak v. Washington, 359 Pa. Super. 454, 519 A.2d 438 (1986); Ferguson v. King, 43 Beaver L.J. 71 (1984). Application of Law to Facts In this case, the petitioner promptly moved to open the judgment entered by default. In addition, he alleged, and 13 No. 1973 CIVIL 1993 sufficiently demonstrated, a meritorious defense. Finally, he provided a reasonable excuse for failure to take the action resulting in the default judgment. In the latter regard, the petitioner clearly relied upon his counsel to protect his interests. In addition, several factors which have traditionally weighed in favor of opening a default judgment - illness within counsel's family, unexpected discovery of a conflict of interest by counsel, and withdrawal of legal representation - contributed to the delay which facilitated entry of the default judgment. Furthermore, the actions of counsel belie any suggestion of dilatoriness, failure to act with knowledge of the implications, or deliberate decision not to defend. Bearing in mind the purpose of the rules in authorizing the entry of default judgments as expressed heretofore, and without intending to suggest in any way any impropriety on the part of Plaintiffs' counsel in furthering the interest of his clients by causing entry of the judgment, the Court believes that the judgment should be opened. For this reason, the following Order will be entered: ORDER OF COURT AND NOW, this~day of May, 1994, upon careful consideration of Defendants' Petition To Open Default Judgment, for the reasons stated in the accompanying Opinion, the Petition is DEEMED WITHDRAWN, and the Rule heretofore issued is DISCHARGED, as to Defendant Jeffrey Taylor Homes, Inc., and the Petition is GRANTED, and the Rule heretofore issued is MADE ABSOLUTE, as to Defendant 14 No. 1973 CIVIL 1993 Jeffrey Taylor. BY THE COURT, J. Wesley Oler, /Jr.~, J. ' ~ ~ J. Jay Cooper, Esq. 320 Market Street Strawberry Square P.O. Box 1268 Harrisburg, PA 17108-1268 Attorney for Plaintiffs John D. Briggs, Esq. 3464 Trindle Road Camp Hill, PA 17011 Attorney for Defendants : rc 15