Commonwealth Land Title v. Cowan, R.

CourtSuperior Court of Pennsylvania
DecidedJanuary 22, 2025
Docket332 EDA 2024
StatusUnpublished

This text of Commonwealth Land Title v. Cowan, R. (Commonwealth Land Title v. Cowan, R.) 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
Commonwealth Land Title v. Cowan, R., (Pa. Ct. App. 2025).

Opinion

J-A25025-24

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH LAND TITLE : IN THE SUPERIOR COURT OF INSURANCE COMPANY : PENNSYLVANIA : : v. : : : ROBERT COWAN AND BENCHMARK : VENTURES : No. 332 EDA 2024 : Appellants :

Appeal from the Order Entered December 22, 2023 In the Court of Common Pleas of Wayne County Civil Division at No(s): 253-JUDG-2023

BEFORE: OLSON, J., DUBOW, J., and SULLIVAN, J.

MEMORANDUM BY DUBOW, J.: FILED JANUARY 22, 2025

Appellants Robert Cowan and Benchmark Ventures (collectively,

“Appellants”)1 appeal from the order entered by the Wayne County Court of

Common Pleas on December 22, 2023, denying their petition to open a default

judgment entered against them in New York. After careful review, we affirm.

A.

A detailed factual history is unnecessary to our disposition. The

procedural history is as follows. Commonwealth Land Title Insurance

Company filed a complaint in Kings County, New York, and on July 20, 2015,

the Supreme Court of Kings County entered a default judgment against ____________________________________________

1 Appellant Cowan passed away during the pendency of this appeal, and thus,

his estate is an appellant. Additionally, Appellee is now GSFNT Recovery Fund, LLC, assignee of Commonwealth Land Title Insurance Company’s successor in interest. J-A25025-24

Appellants (“the New York Judgment”) in the amount of $111,295.00. In

2020, Cowan moved to 349 Steiner Road in Wayne County, Pennsylvania. On

June 2, 2023, Appellee recorded the New York Judgment with the

prothonotary’s office in Wayne County and obtained a writ of execution for

Appellant Cowen’s property at 349 Steiner Road.

On September 20, 2023, Appellants filed a petition in the Wayne County

Court of Common Pleas to open the New York Judgment (“Petition to Open”).

The Petition to Open challenged the New York Judgment on two grounds: (1)

Appellee did not serve Appellants with the underlying complaint and (2) the

Kings County court lacked personal jurisdiction over Appellant Cowan because

he lived in Colorado and “did not transact any business or commit a tortious

act in New York[.]” Proposed Preliminary Objections, 9/20/23, at ¶¶ 1-5.

Appellee filed an Answer and included the Affidavit of Service indicating that

a process server served Appellant Cowan at 349 Steiner Road on May 14,

2013.

The court held a hearing on the Petition to Open on December 21, 2023.

Relevantly, Appellant Cowan testified that, in May 2013, his mother lived at

349 Steiner Road, but he lived in Colorado and was possibly traveling for work

on the date of the process server’s Affidavit of Service. He stated that he was

“absolutely sure” he was not served on May 14, 2013, despite having “past

and present memory loss.” N.T. Hr’g, 12/21/23, at 16-17. The court did not

find his testimony credible and denied the Petition to Open.

-2- J-A25025-24

This timely appeal followed. Appellants and the trial court complied with

Pa.R.A.P. 1925.

Appellants raise the following issues for our review:

1. Whether the default judgment entered against the Appellants violated Pennsylvania Rules of Civil Procedure and is therefore void?

2. Whether the trial court erred and abused its discretion by denying Appellants’ petition to open the judgment entered by default?

3. Did the trial court abuse its discretion or commit an error of law where it appears from a review of the record that there is no evidence to support the [c]ourt’s findings?

4. Did the trial court err in denying the Petition to Open the default judgment and failing to consider all three criteria for opening a default where numerous meritorious defenses to the allegations were contained in the Appellants’ proposed Preliminary Objections to the Appellee’s Complaint, where the Appellants provided a reasonable explanation for failing to file a timely responsive pleading, and when the Appellants, through new counsel, promptly filed a petition to open default?

5. Where the Appellants’ Petition to [O]pen possessed a reasonable explanation or legitimate excuse for their default, did the trial court abuse its discretion in failing to give weight to the Appellants’ meritorious defenses to the Complaint?

Appellant’s Br. at 5-6.2

____________________________________________

2 Appellant raises a sixth claim: “[d]id the trial court err in denying the Petition

to Open the default judgment by failing to consider the equities of the matter, the prejudice to the Appellants if the petition to open was denied and whether the Appellee would suffer any prejudice if the petition to open default was granted?” Appellant’s Br. at 6. However, he failed to raise this claim in his Rule 1925(b) Statement and thus, it is waived. See Pa.R.A.P. 1925(b)(4)(vii) (“Issues not included in the Statement ... are waived.”).

-3- J-A25025-24

*

We begin by noting that it was the trial court in New York, and not the

one in Pennsylvania, that entered the default judgment. Appellants, however,

chose to challenge the entry of the default judgment in Pennsylvania, and not

New York, and argue that the trial court erred in not applying the Pennsylvania

Rules of Civil Procedure (“Pa.R.Civ.P.”) to its Petition to Open. Appellants’ Br.

at 11-24. Specifically, Appellants maintain that entry of a default judgment

was improper because Appellee failed to serve Appellant Cowan with the

complaint or the 10-day notice of default as required by Pa.R.Civ.P. 237,

237.1, and 237.5,3 and that the lower court lacked personal jurisdiction over

them due to the lack of both service and minimum contacts. Id. at 14-15.

Appellants also assert that the court rejected “without basis” their

“unrebutted” pleadings, which indicated that Appellant Cowan was not served.

Id. at 17.

The trial court, however, denied the Petition to Open because it had no

jurisdiction to open a default judgment entered in the New York court. Trial

Ct. Op., 2/20/24, at 2. Rather, the court concluded that Appellants were

limited in Pennsylvania to challenging the enforcement of the New York

Judgment by filing a Petition to Vacate the Foreign Judgment pursuant to the

3 Rules 237, 237.1 and 237.5 describe, inter alia, notice requirements for

the entry of a default judgment in Pennsylvania.

-4- J-A25025-24

Pennsylvania pursuant to the Uniform Enforcement of Foreign Judgments Act

(“UEFJA”).4

The UEFJA facilitates the transfer of money judgments from one state’s

courts to another. A foreign judgment, however, may not be attacked on its

merits. It is only the state court that entered the foreign default judgment

that has jurisdiction to open it. Greate Bay Hotel & Casino, Inc. v.

Saltzman, 609 A.2d 817, 818 (Pa. Super. 1992).

In this case, the trial court denied the Petition to Open because only a

New York court has the authority to open the default judgment. We agree.

The trial court in Pennsylvania lacks the authority to consider the grounds for

the entry of the default judgment in another state.

4 The UEFJA provides, in relevant part:

(b) Filing and status of foreign judgments.—A copy of any foreign judgment . . . .may be filed in the office of the clerk of any court of common pleas of this Commonwealth. The clerk shall treat the foreign judgment in the same manner as a judgment of any court of common pleas of this Commonwealth.

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Related

Commonwealth Capital Funding, Inc. v. Franklin Square Hospital
620 A.2d 1154 (Superior Court of Pennsylvania, 1993)
Greate Bay Hotel & Casino, Inc. v. Saltzman
609 A.2d 817 (Superior Court of Pennsylvania, 1992)
Capstone Capital Group v. Alexander Perry, Inc
2021 Pa. Super. 195 (Superior Court of Pennsylvania, 2021)

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Bluebook (online)
Commonwealth Land Title v. Cowan, R., Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-land-title-v-cowan-r-pasuperct-2025.