Alston v. Commonwealth

20 Pa. D. & C.5th 49
CourtPennsylvania Court of Common Pleas, Philadelphia County
DecidedDecember 13, 2010
Docketno. 3710
StatusPublished
Cited by3 cases

This text of 20 Pa. D. & C.5th 49 (Alston v. Commonwealth) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Philadelphia County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Alston v. Commonwealth, 20 Pa. D. & C.5th 49 (Pa. Super. Ct. 2010).

Opinion

LEVIN, J.,

Plaintiff, Kira Alston, brought this action against the defendants, Commonwealth of Pennsylvania and Pennsylvania Department of Transportation (“PennDOT”); the city of Philadelphia (“the city”), and Lawrence Cook (“Mr. Cook,” a property owner), to recover damages stemming from a slip and fall [51]*51accident that occurred on June 1, 2005, in the vicinity of 5210 Baltimore Avenue, in the city of Philadelphia, near the juncture of a curbside handicap ramp and a sidewalk.

The claims against the city of Philadelphia and PennDOT were resolved by agreement. The releases signed by the plaintiff, Kira Alston, satisfied all of her claims against all of the defendants including Lawrence Cook. The Commonwealth of Pennsylvania did not pursue any cross-claims; however, the city of Philadelphia chose to try its cross-claim against Mr. Cook. Because the city of Philadelphia was only secondarily liable, it proved necessary for the city to try to establish the property owner, Mr. Cook’s responsibility to Kira Alston. The city’s attempt was to be compensated for the amount they paid to resolve the plaintiff, Kira Alston’s claim by seeking to establish the property owner’s liability, and then seeking payment from the property owner. The Commonwealth of Pennsylvania did not join in this process.

A jury trial was commenced on July 7, 2010, before the Honorable Stephen E. Levin, in the Court of Common Pleas of Philadelphia County, on the remaining cross-claim.

On July 12, 2010, at the conclusion of plaintiff’s case in chief, upon a motion for non-suit filed by defendant Cook, the court entered a compulsory non-suit in favor of defendant, Lawrence Cook, and against the city of Philadelphia on its cross claim. The court found, based on the evidence presented, including photographs of the handicap ramp and sidewalk, direct testimony, and expert testimony, that the alleged defect in the sidewalk was [52]*52trivial under the circumstances. The alleged defect was approximately 5/8 of an inch in depth, at most, as conceded by all parties and their experts, and as demonstrated by direct evidence, including photographs by plaintiff and defense.

On July 19, 2010, the city of Philadelphia filed a post-trial motion for judgment n.o.v. in which it argued that the defect was sufficient in size for a jury to find negligence on behalf of co-defendant Cook. Defendant Cook filed an answer in opposition to the city’s post trial motion in which he cited well-settled case law holding that minor defects in pavement do not engender liability.

On October 12, 2010, the Honorable Stephen E. Levin denied the city of Philadelphia’s motion for post trial relief by an order which stated in pertinent part:

...this court is bound, as a matter of law, to hold there is no negligence where the alleged defect, which here was 5/8ths of an inch, is determined to be trivial under the circumstances presented. The maintenance of sidewalks in a reasonably safe condition under the circumstances is all that is required of a property owner.

On October 29, 2010, defendant, Lawrence Cook, filed a praecipe to enter judgment in his favor, and against the city, with respect to its cross-claim.

Subsequently, on November 10, 2010, defendant, city of Philadelphia filed a timely notice of appeal seeking appellate review of this court’s order denying the city’s post-trial motion, and upholding compulsory non-suit.

For the following reasons, this court’s compulsory non-[53]*53suit and order denying the city’s post trial motion should be affirmed.

I. BACKGROUND

On June 5, 2005, at approximately 8:45 p.m. in the evening, plaintiff Kira Alston was walking in the vicinity of the northwest comer of 5200 Baltimore Avenue. The street lighting was dim. Ms. Alston was familiar with the area because her uncle and cousin lived around the comer. She visited them about twice a week. She had walked on the same comer many times before. On the evening in question, Ms. Alston testified that she and her cousin, Juanita Keno, had gone on foot to get food at a Chinese Store and at Crown Chicken on Baltimore Avenue across the street. They were returning from these errands when the accident occurred.

Ms. Alston crossed the street with her cousin and walked up the handicap ramp that PennDOT had installed as a cutout into the curb and sidewalk on the comer of 52nd Street and Baltimore. Ms. Alston testified that as she walked up the pavement handicap ramp, the toes of her foot went into a crack that was at the portion of the ramp adjoining the sidewalk. She fell to her knees, then twisted to her side, and ended up falling on her back. She did not see the crack until she was laying on her back with her head out toward the street.

Ms. Alston felt a combination of numbness and pain. She was taken by ambulance to Misercordia Hospital. Later she was transported to the University of Pennsylvania Hospital where she underwent surgery placing pins in her leg to stabilize a fracture. In addition a metal rod [54]*54was placed in her leg. The surgery was complicated by infection. Finally, she underwent rehabilitation at Manor Care Nursing Home, however, she now had a condition of drop foot. There was further surgery to shorten the tendon. A series of braces were placed on her leg to try to straighten it. For medium to long distances Ms. Alston requires a wheelchair. For very short distances she can use a walker.

There is no question that Ms. Alston was severely injured. The city of Philadelphia and PennDOT chose to settle their claims rather than risk a jury verdict, obtaining general releases signed by the plaintiff, Kira Alston, which satisfied all of her claims against all of the defendants. The city of Philadelphia’s cross claim was asserted based on its position that that the property owner had the primary responsibility to keep the sidewalk in repair, and that the municipality had only secondary liability, based on the Political Subdivision Torts Claims Act, 42 Pa. C.S. Section 8542 (b)(7). For the city to prevail on its cross claim against Mr. Cook, it had to step into the shoes of the original plaintiff, Kira Alston, and to prove her claim against Lawrence Cook. For its part, PennDOT chose not to pursue its potential cross claim. Thus, the question raised by this case was simply whether the defect in the pavement was large enough in size to give rise to liability under the circumstances, or whether the defect was so small as to not implicate the liability of the property owner.

II. DISCUSSION

A) Standard of Review

In the case subjudice, the trial court determined that a [55]*55cause of action was not established because of the minimal nature of the defect. In Wu v. Spence, M.D., 605 A.2d 395, (Pa. Super. 1992), the Superior Court enunciated the standard of review for compulsory non-suit as follows.

The standard of review on the appeal of a denial of a motion to remove a nonsuit is well settled. The plaintiff must be allowed the benefit of all favorable evidence and reasonable inferences arising therefrom, and any conflicts in the evidence must be resolved in favor of plaintiff. Coatesville Contractors v. Borough of Ridley, 509 Pa. 553, 558-60, 506 A.2d, 862, 865 (1986).

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Bluebook (online)
20 Pa. D. & C.5th 49, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alston-v-commonwealth-pactcomplphilad-2010.