Allied Electrical Supply Co. v. Roberts

53 Pa. D. & C.4th 166, 2001 Pa. Dist. & Cnty. Dec. LEXIS 239
CourtPennsylvania Court of Common Pleas, Greene County
DecidedAugust 16, 2001
DocketA.D. no. 182, 2000
StatusPublished

This text of 53 Pa. D. & C.4th 166 (Allied Electrical Supply Co. v. Roberts) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Greene County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Allied Electrical Supply Co. v. Roberts, 53 Pa. D. & C.4th 166, 2001 Pa. Dist. & Cnty. Dec. LEXIS 239 (Pa. Super. Ct. 2001).

Opinion

NALITZ, J.,

Plaintiff has requested post-trial relief from the verdict of the jury. It raises two issues, but because of our disposition of the first we need not consider the second. Plaintiff argues that it was error not to declare a mistrial when the issue of insurance was injected into the trial. For the reasons set forth below, we agree. Plaintiff is Allied Electrical Supply Company, hereinafter known as Allied, and the defendant is Craig T. Roberts, i/a/t/a Greene County Pottery Works, hereinafter known as Roberts. Allied and Roberts each rented approximately one-half of a commercial building on East High Street in Waynesburg, Pennsylvania. On March 18, 1998, after Allied’s normal business hours, but while Roberts was still in his shop, a fire broke out in the building. The fire trapped Roberts in the rear of his store in a room with an outside door which was locked. Fortunately, passersby noticed the smoke and heard Roberts’ calls for help, and were able to break open the door and extricate him. The building was a total loss. Allied, or its subrogee insurer, brought suit against Roberts for loss of inventory and for the loss caused by the interruption of its business. The parties stipulated as to damages and the matter came to be heard by a jury on the issue of liability only.

On the morning of the second day of this two-day trial, counsel for Roberts called one Fred Simpson. Mr. Simpson occupied a unique position. He was apparently the last customer to call at the Pottery Works that day, at about 4:30 p.m., and was also one of the firefighters who responded to the emergency call at about 6 p.m. He was [169]*169on the first engine to arrive at the scene and was the second man on the first hose to enter the building. After Simpson described his observations during both of his visits, and his actions at the fire scene, the following exchange occurred.

“Q. [Mr. Walsh, Roberts’ counsel]: Did you ever talk to Attorney Barker [Allied’s trial counsel] about this case?

“A. Yes, Mr. Barker telephoned me and I spoke to him on the phone. And when I spoke to him on the phone I don’t remember the day, and I don’t recall if he identified himself as the attorney for the insurance company for Allied Electric.” (NT 315-16.)

During the recess which followed Mr. Simpson’s testimony, both counsel approached the bench. The colloquy was not recorded, but it seems that the conversation included Roberts’ counsel’s remarks that the question about Mr. Simpson’s contact with Allied’s counsel was designed to suggest to the jury that Allied had failed to call a witness with information that would be valuable to the jury’s understanding of the events of March 18, 1998. In our recollection, plaintiff’s counsel did not specifically request a mistrial at this point. Instead, we discussed a curative instruction. Following the recess, the jury heard the testimony of Richard Brugger, Robert’s expert. Mr. Brugger was the last witness called. The attorneys delivered their closing arguments, the jury was instructed (including a charge that the fact of insurance was irrelevant to the issues before them) (NT 393) and then excused to begin its deliberations. Only after the jury was excused did Allied move for a mistrial. Roberts argues that this sequence constitutes a waiver by Allied of the prejudicial effect of the mention of insurance, citing Dilliplaine [170]*170v. Lehigh Valley Trust Company, 457 Pa. 255, 322 A.2d 114 (1974), requiring a timely objection by trial counsel to errors that occur in the course of a trial. We do not read Dilliplaine quite so narrowly. The alleged error occurred midmoming and the motion for a mistrial occurred midafternoon on the same day. We do not consider this slight delay to be untimely.

If the motion was timely, should it have been granted? “As a general rule in a trespass action the fact that a defendant is insured is irrelevant and ... is so prejudicial that it calls for the withdrawal of a juror....” Deeney v. Krauss, 394 Pa. 380, 382, 147 A.2d 369, 370 (1959). This general rule is subject to many exceptions. The courts consider whether the reference was ambiguous and whether the insurance mentioned applied to a specific party, Phillips v. Schoenberger, 369 Pa. Super. 52, 534 A.2d 1075 (1987); whether the reference to insurance was intentional, Trimble v. Merloe, 413 Pa. 408, 197 A.2d 457 (1964); and whether the moving party can demonstrate prejudice, Gatto v. Kisloff, 437 Pa. Super. 328, 649 A.2d 996 (1994).

In this case, there is no suggestion the remark was intentionally elicited. Everybody agrees it was not and Mr. Simpson’s mention of insurance was not responsive to the question he was asked.

Many of the cases affirm the trial court’s denial of a mistrial in these circumstances because of the ambiguity of the reference. It is often difficult to tell which party is insured; e.g. Phillips v. Schoenberger, supra; Fleischman v. Reading, 388 Pa. 183, 130 A.2d 429 (1957). There was no ambiguity here; the jury learned-that Allied’s insurance carrier was interested in the case to the point [171]*171where it retained an attorney to prosecute the action against Roberts. Our courts have long recognized that jurors are aware almost everyone has automobile insurance, indeed the law requires it. Sackson v. Finlayson, 6 D.&C.2d 514 (1956); 75 Pa.C.S. §1701 et seq. Likewise, it is common knowledge that most people and businesses have fire insurance. It is obviously the business of insurance companies to investigate and adjust losses and the fact that an insurance company might be involved in the background of a court case arising from a fire or automobile accident would surprise no one. But we do not believe it is common knowledge that fire insurance companies often pursue their subrogation rights against those whom they perceive to be responsible for the fire. This was not some reference to an insurance adjuster for one of the parties at the fire scene as occurred in Dolan v. Carrier Corporation, 424 Pa. Super. 615, 623 A.2d 850 (1993), where the jury might have assumed that the investigator was inspecting the damage to begin the process of settling with the insured. Here was a reference to insurance which informed the jury that: (1) Allied’s loss was insured; (2) Allied had been paid for its loss; and (3) Allied’s insurance carrier was trying to recover that payment from Roberts, who it deemed responsible for the fire. Furthermore, the company was not identified with a nameless adjuster at a distant and bygone fire scene, but was incarnate before the jury in the person of Allied’s trial counsel, the same person who called Roberts as on cross-examination.

Having determined that the reference to insurance was unintentional, but direct and unambiguous, we next consider whether it was prejudicial to Allied. Obviously, there [172]*172is no way to know whether Allied’s cause was in fact damaged by Mr.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Deeney v. Krauss
147 A.2d 369 (Supreme Court of Pennsylvania, 1959)
Fleischman v. Reading
130 A.2d 429 (Supreme Court of Pennsylvania, 1957)
Carter v. United States Steel Corp.
604 A.2d 1010 (Supreme Court of Pennsylvania, 1992)
Trimble v. Merloe
197 A.2d 457 (Supreme Court of Pennsylvania, 1964)
Phillips v. Schoenberger
534 A.2d 1075 (Supreme Court of Pennsylvania, 1987)
Dolan v. Carrier Corp.
623 A.2d 850 (Superior Court of Pennsylvania, 1993)
Dilliplaine v. Lehigh Valley Trust Co.
322 A.2d 114 (Supreme Court of Pennsylvania, 1974)
Gatto v. Kisloff
649 A.2d 996 (Superior Court of Pennsylvania, 1994)
Hillworth v. Smith
624 A.2d 122 (Superior Court of Pennsylvania, 1993)

Cite This Page — Counsel Stack

Bluebook (online)
53 Pa. D. & C.4th 166, 2001 Pa. Dist. & Cnty. Dec. LEXIS 239, Counsel Stack Legal Research, https://law.counselstack.com/opinion/allied-electrical-supply-co-v-roberts-pactcomplgreene-2001.