Cobb, G. v. Heritage Valley Health System

CourtSuperior Court of Pennsylvania
DecidedJune 17, 2026
Docket644 WDA 2025
StatusUnpublished
AuthorBeck

This text of Cobb, G. v. Heritage Valley Health System (Cobb, G. v. Heritage Valley Health System) 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
Cobb, G. v. Heritage Valley Health System, (Pa. Ct. App. 2026).

Opinion

J-A06045-26

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

GAYLE COBB, ASHTON COBB, : IN THE SUPERIOR COURT OF JATAUN COBB, DONOVAN COBB, : PENNSYLVANIA BENJAMIN COBB, INGRID COBB- : HALL, ZSA ZSA COBB-JOHNSON, : BLAIR-ALEXANDRIA FARRAH COBB : : Appellants : : : No. 644 WDA 2025 v. : : : HERITAGE VALLEY HEALTH SYSTEM, : HERITAGE VALLEY BEAVER :

Appeal from the Order Entered April 29, 2025 In the Court of Common Pleas of Beaver County Civil Division at No(s): 11246-2024

BEFORE: OLSON, J., MURRAY, J., and BECK, J.

MEMORANDUM BY BECK, J.: FILED: June 17, 2026

Gayle Cobb, Aston Cobb, Jatuan Cobb, Donovan Cobb, Benjamin Cobb,

Ingrid Cobb Hall, Zsa Zsa Cobb-Johnson, and Blair-Alexandria Farrah Cobb

(collectively, “Plaintiffs”) appeal from the order entered by the Beaver County

Court of Common Pleas (“trial court”) granting the preliminary objections filed

by Heritage Valley Health System and Heritage Valley Beaver (together,

“Defendants”) and dismissing Plaintiffs’ claims with prejudice. Because the

trial court correctly concluded that Plaintiffs could not amend their complaint

to add a new party after the expiration of the statute of limitations, we affirm.

The trial court summarized the pertinent facts and procedural history of

this case as follows: J-A06045-26

This is a professional negligence/medical malpractice action instituted by eight individual plaintiffs through the filing of a praecipe for writ of summons on August 16, 2024. A case management conference was held on December 3, 2024, and the [trial court] set a schedule for the case to proceed at that conference, which required Plaintiffs to file a complaint on or before January 17, 2025. Plaintiffs did not file a complaint by that date, but did file a complaint late and without leave of court on January 30, 2025.

That complaint alleges negligent treatment by Defendants with regard to Wayne B. Cobb, Sr. [(“Cobb, Sr.”).] Neither [Cobb, Sr.] nor his estate is listed as a party to the suit in either the praecipe for writ of summons or in the original complaint, and [Cobb, Sr.] is alleged to have died as a result of the negligent treatment on August 17, 2022. The only count asserted in the original complaint is for negligence, with no assertion of a wrongful death or survival action[.]

The [trial court] conducted a second case management conference on January 31, 2025, at which time Defendants expressed their desire to file preliminary objections to the complaint, and the court entered a schedule for the filing of, briefing with regard to, and argument on the preliminary objections. Defendants timely filed their preliminary objections and brief in support. Argument was scheduled on the preliminary objections for April 2, 2025. Plaintiffs did not file a response or brief in opposition to the preliminary objections by March 21, 2025 as required by [the trial court]’s order of January 31, 2025. Instead, Plaintiffs filed an amended complaint on April 1, 2025, well beyond the twenty-day period specified for the filing of an amended complaint in Pa.R.Civ.P. 1028(c)(1). Plaintiffs never sought or obtained leave of court to file the amended complaint late, and defense counsel objected to the untimely filing of the amended complaint on the record at the time set for the argument on the preliminary objections on April 2, 2025. Moreover, Plaintiffs’ counsel never requested permission nunc pro tunc to file the amended complaint and never filed preliminary objections with regard to Defendants’ preliminary objections.

While on the record on April 2, 2025, defense counsel stated his desire and intent to have “the preliminary objections … be considered as directed against the amended complaint, with the same force and effect as if the amended complaint was filed within

-2- J-A06045-26

the appropriate period.” Accordingly, the [trial court] set a schedule for the filing of additional briefs and for argument by counsel with regard to the preliminary objections on April 14, 2025.

It should be noted that Plaintiffs never amended or altered the caption in the amended complaint and never requested leave to do so. Further, Plaintiffs allege[d] in the amended complaint that an estate was opened for [Cobb, Sr.] on August 16, 2024, with individual plaintiff Gayle Cobb appointed as the administratrix. However, the estate is not named as a party[,] and Gayle Cobb is only identified as an individual plaintiff [at] this time. Moreover, the single negligence claim in the original complaint was eliminated and a wrongful death claim and survival action claim were asserted in the amended complaint instead as to each defendant for a total of four counts.

As noted[, D]efendants [chose] to pursue their preliminary objections as to the amended complaint. The [trial court] heard arguments of counsel on April 14, 2025.

Trial Court Opinion, 4/29/2025, at 1-2 (footnote and citations omitted).

On April 29, 2025, the trial court entered an order granting Defendants’

preliminary objections and dismissing Plaintiffs’ claims with prejudice. The

trial court concluded that the “amended complaint was improperly filed

without leave of court, without consent of opposing counsel, and without a

request to file nunc pro tunc. Moreover, the amended complaint purports to

add new claims and a new party after the expiration of the statute of

limitations.” Id. at 7.

On May 19, 2025, Plaintiffs filed a motion for reconsideration that the

trial court subsequently denied. Plaintiffs timely appealed to this Court. They

present the following issues for review:

-3- J-A06045-26

I. Did the trial court err and abuse its discretion by failing to permit [Plaintiffs] leave to amend the caption to include the estate of [Cobb, Sr.] as a party, where the executor/administrator was already a party to the proceedings?

II. Did the trial court err and abuse its discretion by sustaining preliminary objections with prejudice rather than permitting leave to file a second amended complaint?

III. Did the trial court err in failing to find that the estate of [Cobb, Sr.] was created in a timely manner, thereby tolling the statute of limitations and preserving the right of a necessary party to participate?

IV. Did the trial court err in finding that the amended complaint introduced new causes of action, rather than clarifying or amplifying existing claims?

V. Did the trial court err and abuse its discretion by imposing the harsh remedy of dismissal with prejudice based solely on procedural defaults, absent egregious conduct or demonstrable prejudice to [Defendants]?

Plaintiffs’ Brief at 8.

In reviewing a trial court’s grant of preliminary objections, the standard

of review is de novo and the scope of review is plenary. Caltagirone v.

Cephalon, Inc., 190 A.3d 596, 599 (Pa. Super. 2018). “Preliminary

objections in the nature of a demurrer require the court to resolve the issues

solely on the basis of the pleadings; no testimony or other evidence outside

of the complaint may be considered to dispose of the legal issues presented

by the demurrer.” Id. (citation omitted).

Preliminary objections in the nature of a demurrer test the legal sufficiency of the complaint. When considering preliminary objections, all material facts set forth in the challenged pleadings are admitted as true, as well as all inferences reasonably

-4- J-A06045-26

deducible therefrom.

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Bluebook (online)
Cobb, G. v. Heritage Valley Health System, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cobb-g-v-heritage-valley-health-system-pasuperct-2026.