Commonwealth v. Ansell

56 Pa. D. & C.2d 759, 1971 Pa. Dist. & Cnty. Dec. LEXIS 61
CourtPennsylvania Court of Common Pleas, Somerset County
DecidedJanuary 13, 1971
Docketno. 30
StatusPublished

This text of 56 Pa. D. & C.2d 759 (Commonwealth v. Ansell) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Somerset County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Ansell, 56 Pa. D. & C.2d 759, 1971 Pa. Dist. & Cnty. Dec. LEXIS 61 (Pa. Super. Ct. 1971).

Opinion

COFFROTH, P. J.,

This is an appeal from the conviction of defendant for shoplifting under section 816.1 of The Penal Code of June 24, 1939, P. L. 872, 18 PS §4816.1, a summary offense.

The statute contains this sentence:

“A charge of shoplifting shall be brought before a [760]*760magistrate, alderman or justice of the peace in the city, borough, town or township in which the offense was committed; however, if there is no duly elected or appointed magistrate, alderman or justice of the peace in the city, borough, town or township in which the offense was committed, then a charge of shoplifting shall be brought before a magistrate, alderman or justice of the peace in an adjacent city, borough, town or township within the same county.”

The alleged offense occurred in Somerset Township, in which two justices of the peace axe commissioned: Harold D. Kimmel, Esq., under the old Constitution, and Elwood Dively, Esq., under the new Constitution whose district (3-3) embraces Somerset Township but whose office is in Somerset Borough. The prosecution was brought before P. G. Marenna, Esq., a justice of the peace in Somerset Borough under the old Constitution. The prosecuting officer gave as his reason for bringing the case before Mr. Marenna that Messrs. Kimmel and Dively were not available. It may be that Mr. Kimmel was not available on the day the officer elected to proceed. It is also true that Mr. Dively was disabled during the period in question, but that did not make a justice of the peace unavailable in his district because by order of this court, Constant N. Ferre, Esq., Justice of the Peace of Boswell (District 3-1) was formally assigned to Mr. Dively’s district, as inquiry at Mr. Dively’s office, which is open six days a week and staffed by a full time secretary, would readily have revealed. Also, there is no short-term statute of limitation on shoplifting, so that the prosecutor had ample time to obtain Mr. Dively or his substitutes Mr. Kimmel and thus to comply with the plain direction of the law.

Under these circumstances, counsel for defendant contends that Mr. Marenna was without jurisdiction and that the prosecution must, therefore, be dismissed. [761]*761On the other hand, the Commonwealth contends that the justice of the peace had jurisdiction and that only the venue in his court was improper. .If the statutory direction is jurisdictional, the issue may be raised on appeal: Commonwealth v. Schubert, 207 Pa. Superior Ct. 88. On the other hand, if it is a matter of venue, that is procedural and not substantive (McGinley v. Scott, 401 Pa. 310), and is waived by taking an appeal: Commonwealth v. Conn, 183 Pa. Superior Ct. 144; Emerson v. Standard Protective Society of Pennsylvania, 48 Pa. Superior Ct. 313. Whether venue may be raised on certiorari, see Commonwealth v. Pennsylvania Milk Products Corporation, 141 Pa. Superior Ct. 282; Commonwealth v. Quinn, 215 Pa. Superior Ct. 78; Commonwealth v. Koons, 216 Pa. Superior Ct. 402, 404. In this case, defendant raises the question for the first time on appeal.

The distinction between jurisdiction and venue is really simple and well settled. Jurisdiction refers to the competency of a court to determine controversies of the general class to which a case presented for its consideration belongs, and to bind the parties to the litigation by its adjudication. Venue, on the other hand, is the place in which a particular action is to be brought and determined as a matter of convenience for litigants; it is the particular courtroom where the particular action should be heard and decided. See 39 P. L. E., Venue, §1; McGinley v. Scott, supra. In the latter case, the court also stated, page 316: “Jurisdiction of subject matter can never attach nor be acquired by consent or waiver of the parties, while venue may always be waived.” To the same general effect are: Potteiger v. Fidelity-Philadelphia, 424 Pa. 418, 421; Kaelin v. University of Pittsburgh, 421 Pa. 220; Simpson v. Simpson, 404 Pa. 247; County v. Livengood Construction Corporation, 393 Pa. 39; Brumm v. Pittsburgh National Bank, 213 Pa. Superior Ct. 443; [762]*762Schulman v. Wynnewood Company, 191 Pa. Superior Ct. 66, 68.

We frequently speak of the territorial jurisdiction of a court (Commonwealth v. Quinn, supra), but that is a confusing phrase. Territory may limit jurisdiction when we are speaking of the power of a Pennsylvania court to reach beyond the boundaries of the sovereign State (Commonwealth v. Graham, 367 Pa. 553; Giampalo v. Taylor, 335 Pa. 121 (1939)); but when we are speaking of the territorial restrictions upon a Pennsylvania court in one judicial district, as respects other judicial districts within the state, territory is venue. Thus, as to courts within a State, territorial jurisdiction is a misnomer; an effort to improve the phraseology can be found in Mid-City Bank & Trust Co. v. Myers, 343 Pa. 465, where the court uses the phrase “venue jurisdiction.” Considerable confusion has resulted from the tendency of courts and lawyers to use the term “venue” and “jurisdiction” interchangeably: McGinley v. Scott, supra, page 318, footnote 2. There are two kinds of jurisdiction: of the type of action (subject matter) and of the person. Jurisdiction over the person is acquired by subjecting the persons of the litigant parties to the control of the court by appropriate process or by consent; but that sort of jurisdiction is not involved here because defendant was properly in court on due process. The issue here is whether Justice of the Peace Marenna had jurisdiction of the subject matter or class of controversy, namely, criminal prosecutions for shoplifting, a summary offense.

There would seem to be no doubt about the matter; justices of the peace are competent to try summary offenses, and shoplifting is a summary offense (see 42 PS §391); Mr. Marenna is a justice of the peace; QED, Marenna had jurisdiction of the subject matter [763]*763of the case, but since his is not the proper courtroom or place of trial, venue was improper. The same conclusion obtains even though the general class of case involved be regarded as shoplifting instead of the larger category of summary convictions; there is no question as to the competency of the court to handle either.

At common law, a legal proceeding brought in the wrong court, whether because the court lacked jurisdiction over the subject matter or because it lacked venue, was dismissed. If the statute of limitations had not expired, a new proceeding could be brought in the proper court so that, despite the error and loss of money and time involved, plaintiff or Commonwealth did not lose its remedy. But if the statute of limitations had expired, no other action could be brought, and the procedural error put the complaining or prosecuting party out of the court and the cause of action beyond adjudication, a harsh result. See 1 Goodrich-Amram §1006, Commentary, page 117 of 1970 Supplement. It would make more sense, better justice and improved efficiency if the action, instead of being dismissed, were transferred to the proper court, thereby obviating any problem of the statute of limitations or of beginning the action over again. Such a procedure was finally made applicable to civil actions where venue was improperly laid, but not until 1967 under Pennsylvania Rule of Civil Procedure 1006(e); the same principle was made applicable to justices of the peace under the new Constitution by Rule 155 adopted in 1969.

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Bluebook (online)
56 Pa. D. & C.2d 759, 1971 Pa. Dist. & Cnty. Dec. LEXIS 61, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-ansell-pactcomplsomers-1971.