Cahill v. Schults

643 A.2d 121, 434 Pa. Super. 332, 1994 Pa. Super. LEXIS 1782
CourtSuperior Court of Pennsylvania
DecidedJune 7, 1994
Docket02835
StatusPublished
Cited by37 cases

This text of 643 A.2d 121 (Cahill v. Schults) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cahill v. Schults, 643 A.2d 121, 434 Pa. Super. 332, 1994 Pa. Super. LEXIS 1782 (Pa. Ct. App. 1994).

Opinion

CIRILLO, Judge:

John T. Cahill appeals from an order entered in the Court of Common Pleas of Bucks County granting Kirk John Schults’ and Edward C. Schults’ (the Schultses) motion for summary judgment. We affirm.

The instant action arose out of an automobile accident on May 29, 1990. On May 18, 1992, eleven days before the expiration of the statute of limitations, 1 Cahill, through his attorney, Lee D. Rockafellow, Esq., filed a complaint in Bucks County alleging personal injuries as a result of the Schultses’ negligence. A copy of the complaint was also sent to the Schultses’ insurance carrier. Along with the complaint, Cahill delivered to the prothonotary an order for sheriffs service; Cahill did not, however, attach a check payable to the sheriff with the order for service. At Roekafellow’s deposition, when asked why he failed to attach a check for the sheriff, Rockafellow responded that he “wasn’t sure.” He elaborated on the procedure followed in Bucks County when an order for service is sent in the absence of a payment for the sheriff:

Standard procedure of that is they deliver it down to the sheriffs office. They won’t serve it without the check, and ■ what they do for attorneys that are well-known, they will call them up and say, “This is the amount,” and then you either send a check — and generally Joanne [Rockafellow’s secretary] handles that, all though [sic] I do, and normally *335 we will take sufficient checks with us. But that does not happen all the time. 2

When Rockafellow later discovered that he had not received a bill or telephone call from the sheriffs office, he reinstated the complaint on August 10, 1992, hand-delivered it to the sheriffs office, and requested immediate service. The reinstated complaint was served upon the Schultses on August 27, 1992, over three months after the original complaint was filed. 3

A discovery period ensued to determine the circumstances surrounding the failure to timely serve the complaint. See Pa.R.C.P. 401(a). Subsequently, the Schultses filed a motion for summary judgment, which the trial court granted. This appeal followed.

The issues on appeal, as set forth by Cahill, are as follows:

(1) Does the filing of a complaint and delivery of the complaint and additional copies, together with Sheriffs service in accordance with local custom constitute a good faith effort to toll the statute of limitations?
(2) Is the sending of a copy of the complaint to the Schults’ insurance carrier, who had been handling and negotiating all matters concerning the claim for nearly two years, sufficient to put the Schultses on notice of a claim for purposes of tolling the statute of limitations?

*336 It is well established that summary judgment shall be entered

if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law. Pa.R.C.P. 1035(b). The record must be viewed in the light most favorable to the non-moving party, and all doubts as to the existence of a genuine issue of material fact must be resolved against the moving party. Summary judgment may be entered only in cases where the right is clear and free from doubt.

Hayward v. Medical Center of Beaver County, 530 Pa. 320, 324, 608 A.2d 1040, 1042 (1992).

Because Cahill’s issues are so closely related, and this is conceded by Cahill in his appellate brief, we shall address them as one. The Schultses do not dispute the fact that Cahill filed his complaint within the time permitted by the applicable statute of limitations. This act alone, however, is not the only requirement for correctly commencing a law suit. Service of process must also be properly effectuated.

The mere filing of a praecipe for a writ of summons, without additional affirmative action to effect service of the writ, does not constitute a good faith effort to notify a defendant that he is being sued, and therefore is not sufficient to toll the statute of limitations and preserve a cause of action.

Feher by Feher v. Altman, 357 Pa.Super. 50, 53, 515 A.2d 317, 318 (1986).

Both parties, along with the trial court, agree that this case is governed by the Pennsylvania Supreme Court decision in Lamp v. Heyman, 469 Pa. 465, 366 A.2d 882 (1976) and its progeny. The rule which emerged from Lamp was that “a writ of summons shall remain effective to commence an action only if the plaintiff then refrains from a course of conduct which serves to stall in its tracks the legal machinery he has *337 just set in motion.” Id. at 478, 366 A.2d at 889. In support of its ruling, the Pennsylvania Supreme Court espoused,

[T]here is too much potential for abuse in a rule which permits a plaintiff to keep an action alive without proper notice to a defendant merely by filing a praecipe for a writ of summons and then having the writ reissued in a timely fashion without attempting to effectuate service. In addition, we find that such a rule is inconsistent with the policy underlying statutes of limitation of avoiding stale claims, and with that underlying our court rules of making the process of justice as speedy and efficient as possible.... Our purpose is to avoid the situation in which a plaintiff can bring an action, but, by not making a good-faith effort to notify a defendant, retain exclusive control over it for a period in excess of that permitted by the statute of limitations.

Id. at 477, 366 A.2d at 888-89.3 4 “[Ojne’s ‘good faith’ effort to notify a defendant of the institution of a lawsuit is to be assessed on a case-by-case basis[.]” Leidich v. Franklin, 394 Pa.Super. 302, 310, 575 A.2d 914, 918 (1990). There is no mechanical approach to apply in determining what constitutes a good faith effort to effectuate service; it is the plaintiffs burden, however, to show that his efforts were reasonable. Rosenberg v. Nicholson, 408 Pa.Super. 502, 506-07, 597 A.2d 145, 147 (1991). “At a minimum, the good faith requirement in [Lamp ] mandates compliance with the Pennsylvania Rules of Civil Procedure and, importantly, local practice.” Feher, 357 Pa.Super. at 54, 515 A.2d at 319 (1986) (emphasis added). Cahill, we conclude, has failed to satisfy his burden.

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

Related

W. Mayo v. J. Doe
Commonwealth Court of Pennsylvania, 2024
Gussom, R., Aplt. v. Teagle, M.
Supreme Court of Pennsylvania, 2021
Hester-Allen, S. v. Perry, K.
Superior Court of Pennsylvania, 2018
Nicolas, J. v. Zolner, C.
Superior Court of Pennsylvania, 2017
Yampolsky Mandeloff v. Liberties Lofts, LLC
Superior Court of Pennsylvania, 2017
Ali, M. v. Amoroso, A.
Superior Court of Pennsylvania, 2017
Roytman, M. v. Cesarone, K.
Superior Court of Pennsylvania, 2017
Bloome, M. v. Alan, M. and Hillside Gardens, LTD
154 A.3d 1271 (Superior Court of Pennsylvania, 2017)
Williams, M. v. Jauregui, R.
Superior Court of Pennsylvania, 2015
Trivitt, R. v. Serfass, L.
Superior Court of Pennsylvania, 2015
Feehan, J. v. Allstate Insurance Company
Superior Court of Pennsylvania, 2015
Parsons, L. v. Rose Valley Partnership
Superior Court of Pennsylvania, 2015
Peterson v. State Farm Fire & Casualty Co.
81 Pa. D. & C.4th 215 (Dauphin County Court of Common Pleas, 2006)
Fraisar v. Gillis
892 A.2d 74 (Commonwealth Court of Pennsylvania, 2006)
Hoberg v. Smith
73 Pa. D. & C.4th 536 (Lancaster County Court of Common Pleas, 2005)
Sampath v. Concurrent Technologies Corp.
227 F.R.D. 399 (W.D. Pennsylvania, 2005)
Phebus v. UPMC Horizon
71 Pa. D. & C.4th 513 (Mercer County Court of Common Pleas, 2005)

Cite This Page — Counsel Stack

Bluebook (online)
643 A.2d 121, 434 Pa. Super. 332, 1994 Pa. Super. LEXIS 1782, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cahill-v-schults-pasuperct-1994.