Degidio v. Degidio

20 Pa. D. & C.5th 408
CourtPennsylvania Court of Common Pleas, Lawrence County
DecidedJanuary 13, 2011
Docketnos. 40045 of 2001, E.Q. and 10255 of 2001, C.A.
StatusPublished

This text of 20 Pa. D. & C.5th 408 (Degidio v. Degidio) 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
Degidio v. Degidio, 20 Pa. D. & C.5th 408 (Pa. Super. Ct. 2011).

Opinion

HODGE, J.,

This case was before the court on December 14, 2010 on a motion to reinstate sanctions and a motion to appoint master filed on behalf of the plaintiff, Denise Caminite DeGidio. The defendant, Alexander J. DeGidio, filed a memorandum in response to plaintiff’s motions claiming that the doctrine of laches precluded plaintiff from obtaining the requested relief from this court. The court heard oral argument from counsel on the legal issue of whether the doctrine of laches is applicable in the instant case, and the matter is now before the court for determination.

A brief summation of this case’s factual history is as follows: The plaintiff and defendant were married on March 11, 1983, and they were separated on February 1, 2001. The separation occurred after an incident of domestic violence, which resulted in physical injury to the plaintiff. This specific incident prompted plaintiff to file a complaint in divorce and obtain a protection from abuse [410]*410order against defendant. A final protection from abuse order was issued on February 16, 2001. The February 16, 2001 order included a provision forbidding the parties from alienating, encumbering, and disposing of the marital property.

Thereafter, the defendant prevented the plaintiff from entering their home to obtain her personal belongings and her dog. Plaintiff could not access the marital residence until June of 2001, but by that time many of her personal possessions having any value were gone, including her dog. The residence itself was left by the defendant uninsured and unoccupied. The bank had foreclosed on the residence, and the property was eventually sold at the sheriff’s sale.

On January 7, 2002, the Flonorable President Judge Ralph Pratt found defendant in contempt of court and ordered remedies and sanctions. Defendant appealed the January 7, 2002 order of court. Plaintiff did not respond to defendant’s notice of appeal. The Superior Court subsequently affirmed all of the January 7, 2002 order, except paragraphs, 5(a) and (b)(i). This specific portion of the order was remanded to the trial court to make a determination regarding defendant’s ability to comply with the provision set forth in the order. Until plaintiff recently filed the motion to reinstate sanctions and a motion for appointment of master, this case was inactive since July 9, 2003, the date of remand from the Superior Court.

The court will first address plaintiff’s motion to reinstate sanctions. The specific sanctions imposed by the [411]*411Honorable Judge Pratt are extracted from the January 7, 2002 order and read as follows:

4) As sanctions, the court directs that defendant shall serve a term of imprisonment in the Lawrence County Jail of six (6) months and pay a $ 1,000.00 fine, effective immediately.
5) The sanctions imposed are suspended pending an opportunity for the defendant to purge himself of contempt by complying with the following conditions:
a) within 10 days from the filing of this order, defendant shall pay the plaintiff the sum of $340.00 for cell phone charges, $500.00 to replace a portion of plaintiff’s damaged clothing, and $400.00 for reasonable attorney’s fee;
b) within 90 days of the filing of this order:
i) pay all arrearages regarding the mortgaged loan which encumbers the marital residence to bring the installment payment obligations current and thereby preclude the pending mortgage foreclosure proceeding at No. 10585 of 2001, C.A.;
ii) clean, repair, and return to an orderly condition the interior and exterior of the marital residence so that it is appropriate for prospective buyers to view; and
iii) provide to plaintiff a full accounting in writing of all personal property in the marital [412]*412residence at the time plaintiff vacated the residence on February 16, 2001, and that personal property which currently exists in the residence; and
c) fully comply with the PFA order of February 16, 2001 as extended by this order.

As previously stated, the Superior Court remanded this case to the trial court for a determination of defendant’s ability to comply with provisions 5(a) and (b)(i-ii). However, subsequent to this case being remanded, no action was taken by either party to initiate proceedings as directed by the Superior Court.

The defendant now asserts the defense of laches. This defense bars relief when the complaining party has acted without due diligence and has consequently failed to initiate an action to another’s prejudice. Leedom v. Thomas, 473 Pa. 193, 200, 373 A.2d 1329, 1332 (Pa. 1977). The test for applying the doctrine of laches has been stated as follows: The party asserting laches must first show a delay arising from the other party’s failure to exercise due diligence, and second, prejudice from the delay. Pattern v. Vose, 590 A.2d 1307, 1309 (Pa. Super. 1991). It is not enough for a party to only show delay arising from failure to exercise due diligence, as the doctrine of laches will not be imputed where no injury has resulted to the other party by reason of the delay. Id.

“Prejudice is an essential element of laches; in the absence of prejudice, the doctrine of laches will not be applied.” Pattern v. Vose, 590 A.2d at 1309. Laches [413]*413is properly asserted when a change in the condition or relations of the parties occurs during the period of time the complainant unreasonably failed to act. Leedom v. Thomas, at 201, 373 A.2d at 1333. Thus, the burden of proof with respect to the doctrine of laches is upon the party asserting the defense, and as previously stated, “in order to meet this burden, the party alleging the delay must demonstrate prejudice.” Lipschutz v. Lipschutz, 571 A.2d 1046, 1051 (Pa. Super. 1990) (citing Kay v. Kay, 460 Pa. 680, 334 A.2d 585 (Pa. 1975). “[D]elay alone, no matter how long, does not itself establish laches.” Pattern, 590 A.2d at 1309 (quoting Jackman v. Pelusi, 550 A.2d 199, 202 (Pa. Super. 1988).

The court finds that plaintiff has failed to exercise due diligence to ensure that this case was resolved and finalized before the court. Seven years have passed since plaintiff took any initiative to proceed with the directions of the Superior Court and assess the defendant’s ability to pay the contempt conditions set forth by the court. Plaintiff rationalizes her failure to act by claiming that she was without the financial resources to continue forward with the litigation and that she had moved out of state for fear of the defendant.

The defendant contends that as a result of plaintiff’s failure to exercise diligence he has inevitably been prejudiced; the court must agree with the defendant’s assertion. Laches is founded on some change in the condition or relations of the parties which occurs during the period the complainant unreasonably failed to act. See Kay v. Kay, 460 Pa.

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Related

Jackman v. Pelusi
550 A.2d 199 (Supreme Court of Pennsylvania, 1988)
Lipschutz v. Lipschutz
571 A.2d 1046 (Supreme Court of Pennsylvania, 1990)
Kay v. Kay
334 A.2d 585 (Supreme Court of Pennsylvania, 1975)
Leedom v. Thomas
373 A.2d 1329 (Supreme Court of Pennsylvania, 1977)
Patten v. Vose
590 A.2d 1307 (Superior Court of Pennsylvania, 1991)

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Bluebook (online)
20 Pa. D. & C.5th 408, Counsel Stack Legal Research, https://law.counselstack.com/opinion/degidio-v-degidio-pactcompllawren-2011.