Estate of A.J.M., Appeal of: Lynch Law Group

2024 Pa. Super. 4, 308 A.3d 844
CourtSuperior Court of Pennsylvania
DecidedJanuary 11, 2024
Docket962 WDA 2022
StatusPublished
Cited by8 cases

This text of 2024 Pa. Super. 4 (Estate of A.J.M., Appeal of: Lynch Law Group) 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
Estate of A.J.M., Appeal of: Lynch Law Group, 2024 Pa. Super. 4, 308 A.3d 844 (Pa. Ct. App. 2024).

Opinion

J-A18003-23 & J-A18004-23

2024 PA Super 4

ESTATE OF A.J.M., AN : IN THE SUPERIOR COURT OF INCAPACITATED PERSON : PENNSYLVANIA : : APPEAL OF: THE LYNCH LAW GROUP, : LLC : : : : No. 962 WDA 2022

Appeal from the Order Entered July 22, 2022 In the Court of Common Pleas of Washington County Orphans' Court at No(s): No. 63-21-1984

ESTATE OF J.A.M., AN : IN THE SUPERIOR COURT OF INCAPACITATED PERSON : PENNSYLVANIA : : APPEAL OF: THE LYNCH LAW : GROUP, LLC : : : : No. 963 WDA 2022

Appeal from the Order Entered July 22, 2022 In the Court of Common Pleas of Washington County Orphans' Court at No(s): No. 63-21-1985

BEFORE: BENDER, P.J.E., LAZARUS, J., and KUNSELMAN, J.

OPINION BY BENDER, P.J.E.: FILED: January 11, 2024

Appellant, The Lynch Law Group, LLC, appeals from the orphans’ court’s

orders dated July 21, 2022, and entered on July 22, 2022, which denied its J-A18003-23 & J-A18004-23

amended petitions for the allowance of legal fees and costs filed in the

underlying guardianship actions.1 After careful review, we affirm.

The orphans’ court set forth the following relevant background in its

Pa.R.A.P. 1925(a) opinion:

Th[ese] appeal[s] arise[] out of Appellant’s legal representation of [J.A.M. (“Wife”)] and [A.J.M. (“Husband”), by and through Frank C. Botta, Esquire (“Attorney Botta”)], in guardianship proceedings before the Washington County Orphans’ Court. Appellant was not a party to the guardianship proceedings and was not appointed by the orphans’ court to represent [Husband and Wife]. The guardianship proceedings were initiated by Husband and Wife’s sons, [M.J.M. and J.A.M. (“Sons”)], on November 5, 2021, who had been acting as the agents for their octogenarian parents[,]2 pursuant to a valid power of attorney [(“POA”)] dated June 25, 2021…. Upon discovering that their authority under the POA had been supplanted by a third[-]party corporate fiduciary, as a result of documents prepared by Attorney Botta, [Sons] immediately instituted the guardianship proceedings to protect their parents. The guardianship petitions were filed on November 5, 2021, in Washington County Orphans’ Court, docketed at No. CP-63-21-1985 for [Wife] and at No. CP- 63-21-1984 for [Husband]. 2 According [to] the guardianship petitions filed [on] November 5, 2021, [Wife] was born [i]n March [of] 1938, and [Husband] was born [i]n March [of] 1936. [Husband] died on July 17, 2022.

After two days of hearings, the orphans’ court adjudicated [Husband] and [Wife] as incapacitated persons[2] and entered ____________________________________________

1 For ease of disposition, we consolidate the appeals at Nos. 962 and 963 WDA

2022 sua sponte, as the issues in both matters involve the same parties and are closely related. See Pa.R.A.P. 513.

2 “‘Incapacitated person’ means an adult whose ability to receive and evaluate

information effectively and communicate decisions in any way is impaired to such a significant extent that he is partially or totally unable to manage his (Footnote Continued Next Page)

-2- J-A18003-23 & J-A18004-23

separate orders appointing their sons as the plenary guardians of their respective estates and persons dated January 10, 2022. No appeal was taken from these orders. During the proceedings, Attorney Botta did not offer any expert testimony to refute the expert testimony presented documenting [Husband] and [Wife’s] incapacity. In addition, [Attorney Botta] did not offer the testimony of [Husband] and [Wife] to attempt to dissuade the allegations of their incapacity or to contest their sons’ appointment as guardians. From [its] failure to offer [Husband and Wife’s] testimony, the orphans’ court was compelled to draw the adverse inference that Appellant was aware that [Husband and Wife’s] testimony would only support the court’s finding of incapacity.

Although no appeal was taken from the adjudication of incapacity and appointment of guardians for [Husband and Wife], on March 16, 2022, [Appellant] filed [its] petitions for allowance of legal fees, demanding payment of legal fees in excess of $37,000.00. After consideration of the preliminary objections filed by the guardians for [Husband and Wife], and the amended petition[s] for allowance of legal fees filed by [Appellant], the court denied the petition[s] for legal fees by order[s] dated July 21, 2022.[3]

Orphans’ Court Opinion (“OCO”), 4/10/23, at 1-2 (cleaned up).

On August 19, 2022, Appellant filed timely notices of appeal at docket

nos. 962 and 963 WDA 2022. Appellant was not directed to file concise

statements of matters complained of on appeal, pursuant to Pa.R.A.P.

1925(b). On March 3, 2023, the orphans’ court issued a single Rule 1925(a)

opinion addressing its denial of Appellant’s amended petition in each of the

underlying guardianship matters. In its opinion, the orphans’ court suggests,

____________________________________________

financial resources or to meet essential requirements for his physical health and safety.” 20 Pa.C.S. § 5501.

3 As the orders dated July 21, 2022, were not entered on the corresponding

dockets until July 22, 2022, we refer to them herein as the “July 22, 2022 orders.”

-3- J-A18003-23 & J-A18004-23

inter alia, that Appellant did not have standing to appeal its July 22, 2022

orders and that this Court does not have subject matter jurisdiction of these

matters on appeal. See OCO at 3. Appellant now presents the following

issues for our review:

1. Did the orphans’ court err in concluding that Appellant lacks standing in the instant appeal[s] when Appellant rendered legal services in the course of the representation of [Husband and Wife]?

2. Did the orphans’ court err in denying Appellant’s Amended Petition[s] for Legal Fees and Costs for services rendered in the course of Appellant’s representation of [Husband and Wife,] based on a subsequent adjudication of incapacity when an incapacitated person is entitled to representation and when the court should abide by an incapacitated person’s wishes regarding representation to the extent possible?

3. Did the orphans’ court abuse its discretion in denying Appellant’s Amended Petition[s] for Legal Fees and Costs by considering and applying improper factors and inferences in its determination that the fees and costs were not necessary or reasonable when there is a right to representation?

Appellant’s Brief at 4.4

As the orphans’ court raised the question of our jurisdiction, we begin

by determining whether these matters are properly before us. It is well-

settled that “[t]he appealability of an order directly implicates the jurisdiction

of the court asked to review the order.” See Estate of Considine v.

Wachovia Bank, 966 A.2d 1148, 1151 (Pa. Super. 2009) (citing Mother’s

Restaurant Inc. v. Krystkiewicz, 861 A.2d 327, 331 (Pa. Super. 2004)). ____________________________________________

4Appellant filed nearly identical briefs in the appeals at 962 and 963 WDA 2022. For ease, we refer to Appellant’s briefs in the singular throughout this writing.

-4- J-A18003-23 & J-A18004-23

“Accordingly, this Court has the power to inquire at any time, sua sponte,

whether an order is appealable.” Id. (citing Kulp v. Hrivnak, 765 A.2d 796,

797 (Pa. Super. 2000)). “Jurisdiction is purely a question of law; the appellate

standard of review is de novo, and the scope of review plenary.” Barak v.

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2024 Pa. Super. 4, 308 A.3d 844, Counsel Stack Legal Research, https://law.counselstack.com/opinion/estate-of-ajm-appeal-of-lynch-law-group-pasuperct-2024.