Commonwealth v. Fiore

69 Pa. D. & C.2d 84, 1975 Pa. Dist. & Cnty. Dec. LEXIS 514
CourtPennsylvania Court of Common Pleas, Washington County
DecidedJuly 8, 1975
Docketmiscellaneous docket 1975, no. 101
StatusPublished

This text of 69 Pa. D. & C.2d 84 (Commonwealth v. Fiore) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Washington County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Fiore, 69 Pa. D. & C.2d 84, 1975 Pa. Dist. & Cnty. Dec. LEXIS 514 (Pa. Super. Ct. 1975).

Opinion

SWEET, P. J.,

This is a very unusual case. It seems that a criminal complaint was filed on or about December 3, 1974, and a hearing held by Magistrate Tempest on or about February 26, 1975. Magistrate Tempest never returned the transcript to court. On June 4, 1975, Samuel S. Pangburn, private prosecutor, wrote a letter to Mr. Costa, which has been made a part of the proceedings. Based on this, the district attorney asked for an application for order extending the time for commencement of trial under Rule 1100, and asked for a hearing on a rule to show cause why the extension should not be granted and a rule to show cause on Magistrate Tempest why he [85]*85should not forward the papers, “wherein he found a prima facie case, to the District Attorney’s Office for action thereon.”

After an answer was filed by Magistrate Tempest with exhibits and an affidavit of I. W. Cordisco, Esq., we had a hearing on June 17, 1975. No one opposed the grant of the extension, so that rule is made absolute. The rule against Magistrate Tempest occasions considerable more difficulty.

The gist of Mr. Tempest’s answer and Mr. Cor-disco’s affidavit is that he dismissed the charges against defendant, William Fiore. We took the oral testimony of Attorney Samuel S. Pangburn, private prosecutor; Assistant District Attorney, Robert Clarke, who' represented the district attorney’s office in this matter; Steve Segedi, International Representative of United Mine Workers of America and three coal miners, Miller Savage, Metro Matas and William Andrews. Mr. Pangburn, who attended the squire’s hearing, testified unequivocally that the magistrate held William Fiore for court for terroristic threats. In this, he was corroborated by Mr. Segedi and the three coal miners who were parties. Mr. Pang-burn announced that he had 14 other coal miners in attendance at the hearing before Magistrate Tempest on February 26th, who he offered further would corroborate what these five witnesses heard at the magistrate’s office, at the end of the hearing. Assistant District Attorney Clarke also testified to a plea bargain conference before Judge DiSalle in which there was certain circumstantial support for the Pangburn testimony. Mr. Tempest’s return and Mr. Cordisco’s affidavit, which are attached as part of the record, both assert that Mr. Tempest did not hold William Fiore for court; the respondent offered Fiore’s testimony, which if given, would corroborate the magistrate.

[86]*86This, of course, raises the question: how much proof does it take to overcome the return of the magistrate? We can find nothing squarely on point, since the system is relatively new and this has apparently not come up in Pennsylvania under the Constitution of 1968.

The analogy which at once occurs to mind is the parallel of the sanctity of the sheriff’s return. The standard book in the field is Anderson On Sheriffs, Coroners, Constables, which deals with this matter in sections 601 and 602. Anderson says this:

“An accurate, and yet concise statement of the rule as to the quantum of proof demanded of a litigant to impeach a return of an officer is difficult of statement. Assailment of such return to be successful is not required to go to the extreme of beyond a reasonable doubt, yet more than ‘a mere preponderance of the evidence’ is demanded to sustain the impeachment. Rule applicable to the ordinary issue of fact is not applied to the issue in these cases.” Anderson cites Raulf v. Chicago Fire Brick Co., 138 Wis. 126, 119 N.W. 646:”
“evidence, reasonably, clearly satisfying the trior of triors that the return is false, is sufficient.’ ”

From this Anderson concludes that “. . . evidence must be strong, clear, and convincing.” He goes on to say: “One witness is insufficient to overturn the certificate of the officer in these cases, whether the witness is the party served or otherwise. It must not be supposed, however, that a false return in any case cannot be established by parol evidence, since this is the only mode by which the falsity can be established.”

In section 601 of the text, it says this:

“In a collateral proceeding an officer’s return ‘imports absolute verity as other judicial records. By [87]*87direct proceedings, such as a bill in equity, the return may be impeached upon clear averments and proof of want of service, and the existence of a valid defense. This is to the end that a party have his day in court, that a party without fault be not concluded by a record which does not speak the truth.’ ”

The only Pennsylvania case which we were able to find is Vaughn v. Love, 324 Pa. 276, 188 Atl. 299 (1936). It holds:

“A sheriff’s return showing personal or constructive service in this State on one who claims to be a nonresident and not present in this State when the service was made, is not conclusive, and defendant may establish these facts by evidence dehors the record.”

The opinion by Mr. Chief Justice Kephart is not quite as clearcut as the headnote. For instance, it says, pages 279-280:

“It scarcely needs any citation of authority to show that in this State, in the absence of fraud, a sheriff’s return, full and complete on its face, is conclusive upon parties resident in the state and cannot be set aside on extrinsic evidence. The early history of the rule is clouded by contradictions. Because of its strictness, all but eight states, of which Pennsylvania is one, have thrown off the old idea that the return of a sheriff must be accepted as verity.”

The footnote to this same paragraph, however, quotes a case in the time of Edward III (1340) as saying: “We must proceed according to the return of the Sheriff,” and then goes on to comment, “These last ten words, reaching an absurd result under the facts, contain no reason for the result.”

The Vaughn case finally ends with this paragraph:

“Both reason and justice demand that the rule of conclusiveness should not be carried any further. [88]*88This is in accord with the best authorities and the Restatement of the Law of Conflict of Laws, sec. 77, comment a, which states, ‘A state cannot exercise jurisdiction over an individual on the ground that the sheriff or other officer of the state makes a return stating that he has served him with process if the return is false. The truth of the return may be brought in question in a court of any state.’ We therefore hold that a sheriff’s return showing personal or constructive service in this State on one who claims to be a nonresident and not present in this State when the service was made, is not conclusive and defendant may establish these facts by evidence dehors the record.”

From the foregoing, we elicit the following principles, (a) prima facie the return of the magistrate is true and correct; (b) a party claiming that the record is inaccurate may have resort to parol evidence to contradict it; (c) the evidence of the party himself is legally insufficient to contradict the record; (d) the proof necessary to contradict the record must be “clear, precise and indubitable”;

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Related

AB v. Continental Imports
281 A.2d 646 (Superior Court of Pennsylvania, 1971)
Wheatcroft v. Schmid
301 A.2d 377 (Commonwealth Court of Pennsylvania, 1973)
Vaughn v. Love
188 A. 299 (Supreme Court of Pennsylvania, 1936)
Raulf v. Chicago Fire Brick Co.
119 N.W. 646 (Wisconsin Supreme Court, 1909)

Cite This Page — Counsel Stack

Bluebook (online)
69 Pa. D. & C.2d 84, 1975 Pa. Dist. & Cnty. Dec. LEXIS 514, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-fiore-pactcomplwashin-1975.