Cornish v. Scott Township

29 Pa. D. & C.5th 144
CourtPennsylvania Court of Common Pleas, Lawrence County
DecidedApril 5, 2013
DocketNo. 10879 of 2009, C.A.
StatusPublished

This text of 29 Pa. D. & C.5th 144 (Cornish v. Scott Township) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Lawrence County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cornish v. Scott Township, 29 Pa. D. & C.5th 144 (Pa. Super. Ct. 2013).

Opinion

PICCIONE, J.,

Before the court for disposition is defendants’, Amy Braden, individually and as President of Inter-County Horseman’s Association and Inter-County Horseman’s Association, motion for summary judgment. The current action arises from an accident occurring at a horse event hosted by defendant, Inter-County Horseman’s Association. Inter-County Horseman’s Association leased show grounds from the Western Pennsylvania Quarter Horse Association on Harlansburg Road, New Castle Pennsylvania to host the three day event. The show grounds are comprised of two adjacent lots. The back portion of the show grounds is owned by the Western Pennsylvania Quarter Horse Association, and the front portion is owned by Scott Township Volunteer Fire Department. The Western Pennsylvania Quarter Horse Association rents the front lot from the Scott Township Volunteer Fire Department.

Plaintiff, Renee L. Cornish (hereinafter, “plaintiff’), [146]*146avers in the complaint that she attended the horse event on June 16, 2007. When she arrived at the show grounds, plaintiff seated herself on bleachers that surround the horse arena. The bleachers were positioned upon cinder blocks. After plaintiff was seated, a heavy set woman approached the bleachers and sat to plaintiff’s left. Shortly thereafter, the heavy set woman stood, which caused the bleacher to shake. As a result plaintiff was dislodged from her seat. Plaintiff then fell headfirst to the ground. Plaintiff claims the bleachers were not properly maintained by Scott Township, the Scott Township Volunteer Fire Department, Amy Braden, Individually and as President of Inter-County Horseman’s Association; Inter-County Horseman’s Association (hereinafter “Inter-County”), William Fuchs, Individually; and as President of Western Pennsylvania Quarter Horse Association, and the Western Pennsylvania Quarter Horse Association (hereinafter “WPQHA”). Plaintiff avers that defendants knew or had reason to know of the defective condition of the bleachers. Plaintiff additionally argues that defendants failed to properly inspect, maintain and secure the bleachers, and because of defendants’ negligence suffered injuries.

On July 6,2009, plaintiff filed the instant action against the above named defendants, claiming that the negligent behavior of the defendants caused plaintiff to sustain severe injuries to her nervous system and legs. Judgment was entered in favor of defendants S cott Township and S cott Township Volunteer Fire Department on August 1, 2012. [147]*147Defendants, Amy Braden, individually and as President of Inter-County Horseman’s Association, and Inter-County, filed the instant motion for summary judgment on November 28, 2012. Argument was held before this court on February 25, 2013. At the time of argument, all remaining parties consented to removing defendants Amy Braden, individually, and Josh Fuchs, individually, from this action. Consequently, the only remaining defendants in the case are Amy Braden, as President of Inter-County Horseman’s Association; Inter-County Horseman’s Association; William Fuchs, as President of Western Pennsylvania Quarter Horse Association; and WPQHA. Inter-County’s motion for summary judgment has been adequately argued and briefed by the parties and is presently before the court for a determination.

Under Pennsylvania law, the standard for summaiy judgment is set forth by Rule 1035.2 of the Pennsylvania Rules of Civil Procedure. The Rule states as follows:

After the relevant pleadings are closed, but within such time as not to unreasonably delay trial, any party may move for summary judgment in whole or in part as a matter of law (1) whenever there is no genuine issue of any material fact as to a necessary element of the cause of action or defense which could be established by additional discovery or expert report, or
(2) if, after the completion of discovery relevant to the motion, including the production of expert reports, an adverse party who will bear the burden of proof at trial [148]*148has failed to produce evidence of facts essential to the cause of action or defense which in a jury trial would require the issues to be submitted to a jury.

Pa.R.C.P. 1035.2.

The moving party bears the burden of proving that no genuine issue of material fact exists. Rush v. Philadelphia Newspapers, Inc., 732 A.2d 648, 650 (Pa. Super. 1999). In determining whether summary judgment is appropriate, the trial court is required to view the record in a 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 in favor of the nonmoving party.” P.J.S. v. Pennsylvania State Ethics Comm’n, 732 A.2d 174 (Pa. 1999) (citing Kapres v. Heller, 640 A.2d 888 (Pa. 1994)). Summary judgment is proper only when the uncontroverted allegations of record and submitted affidavits demonstrate that no genuine issue of material fact exists, and that the moving party is entitled to judgment as a matter of law. Potter v. Herman, 762 A.2d 1116, 1117 (Pa. Super. 2000).

Defendant Inter-County argues it is entitled to summary judgment for two reasons. First, because it was not a “possessor” of the bleachers. Second, Inter-County is not liable for any latent defects exhibited by the bleaches of which it did not have knowledge or could not have been discovered through reasonable inspection. For the following reasons, Inter-County’s motion for summary judgment is denied.

[149]*149A party is subject to liability for physical harm caused to an invitee if: 1) he knows of or reasonably should have known of the condition and the condition involves an unreasonable risk of harm; 2) he should expect that the invitees will not realize it or will fail to protect themselves against it; and 3) the party fails to exercise reasonable care to protect the invitees against the danger. Restatement (Second) of Torts § 343 (1965). This section of the Restatement has been adopted by the Pennsylvania courts. See Palenscar v. Michael J. Bobb, Inc., 266 A.2d 478 (Pa. 1970); Bowman v. Fretts & Leeper Construction Company, 322 A.2d 719 (Pa. Super. 1974).

In order for the party to be liable, it must first be a “possessor” of land. In order for a party to be a “possessor” of land, it must fit into one of the following descriptions: it must be in occupation of the land with the intent to control it; it must have been in occupation of the land with intent to control it if no other party has done so subsequently; or it is entitled to immediate occupation if neither of the other alternatives apply. Restatement (Second) of Torts § 328E (1965). The question of whether a party is a “possessor” of land is a determination to be made by the trier of fact. Blackman v. Federal Realty Inv. Trust, 664 A.2d 139, 142 (Pa. Super. 1995) (referencing Leichter v. Eastern Realty Company,

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Related

Kapres v. Heller
640 A.2d 888 (Supreme Court of Pennsylvania, 1994)
Blackman v. Federal Realty Investment Trust
664 A.2d 139 (Superior Court of Pennsylvania, 1995)
Leichter v. Eastern Realty Co.
516 A.2d 1247 (Supreme Court of Pennsylvania, 1986)
Potter v. Herman
762 A.2d 1116 (Superior Court of Pennsylvania, 2000)
Palenscar v. Michael J. Bobb, Inc.
266 A.2d 478 (Supreme Court of Pennsylvania, 1970)
Rush v. Philadelphia Newspapers, Inc.
732 A.2d 648 (Superior Court of Pennsylvania, 1999)
Bowman v. Fretts & Leeper Construction Co.
322 A.2d 719 (Superior Court of Pennsylvania, 1974)

Cite This Page — Counsel Stack

Bluebook (online)
29 Pa. D. & C.5th 144, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cornish-v-scott-township-pactcompllawren-2013.