Falco v. Bryn Mawr Trust Co.

10 Pa. D. & C. 115, 1927 Pa. Dist. & Cnty. Dec. LEXIS 418
CourtPennsylvania Court of Common Pleas, Montgomery County
DecidedJanuary 24, 1927
DocketNo. 40
StatusPublished

This text of 10 Pa. D. & C. 115 (Falco v. Bryn Mawr Trust Co.) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Montgomery County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Falco v. Bryn Mawr Trust Co., 10 Pa. D. & C. 115, 1927 Pa. Dist. & Cnty. Dec. LEXIS 418 (Pa. Super. Ct. 1927).

Opinion

Knight, J.,

According to the evidence produced by the plaintiff, on the morning of Sept. 30, 1924, Joseph Falco was driving the plaintiff’s truck toward Philadelphia over the State highway (Route No. 145), known as Sandy Hill Road, in Montgomery County. It was before dawn and a foggy, rainy, stormy morning. The estate of David Hess, deceased, had been the owner for a number of years of a farm of ninety-three acres fronting on the Sandy Hill Road, in Plymouth Township.

As Joseph Falco was driving the plaintiff’s truck by the Hess property on the morning in question, a large limb of a tree, which stood outside the fence-line of the Hess farm, fell about five feet in front of the plaintiff’s truck. The driver was unable to stop in time to avoid the fallen limb and the plaintiff’s truck was damaged in the resulting collision.

Plaintiff sued in trespass, alleging that the tree was in an obviously decayed and dangerous condition and that the defendant had constructive notice thereof. The case was tried before a jury and resulted in a small verdict for the plaintiff.

The defendant now moves for a new trial and judgment non obstante vere-dicto.

The reasons assigned for the new trial and judgment raise several interesting questions of law.

First of all, is an abutting property owner liable for damages caused by the fall of a tree which stands in front of his land but within the limits of a State highway?

Section 2 of the Act of May 31, 1911, P. L. 468, provides: “The State Highway Commissioner is directed to construct or improve and thereafter maintain and repair, at the cost and expense of the Commonwealth, the highways forming the plan or system of the State highways in the several counties and townships,* etc.,” and that the highway commissioner, in the construction and maintenance of the State highways, shall enjoy and possess, in addition to the powers conferred by the act, “all the rights and powers conferred by existing laws on supervisors or commissioners in townships in the construction and maintenance of township roads.”

[116]*116The defendant contends that the State had absolute and exclusive control of the highway and, hence, of the tree which fell, and was alone responsible for any damage caused by the fall.

The tree did not fall by reason of the construction, improvement or repair of the highway. It stood within the limits of the road, it is true, but it was not placed there by the public authorities, nor was it in any way connected with the traveled surface of the way.

It is conceded that the defendant is the owner in fee of the land on which the tree stood, and it follows, also, that it was the owner of the tree.

In Chambers v. Furry, 1 Yeates, 167, the court held that in a highway the right of passage belongs to the public, but the right to the soil, the.stones, wood or grass continues in the owners of the lands. See, also, Sanderson v. Haverstick, 8 Pa. 294.

Not only is a tree the property of an abutting land owner, but it cannot be removed or destroyed by the public authorities without compensating the owner: Seaman v. Washington, 172 Pa. 467.

For many years, property owners have been in the habit of planting shade trees in front of their properties, either with the express or implied consent of the highway authorities, without constituting a nuisance per se, but they may become a nuisance by disease or decay: City of Allegheny v. Zimmerman, 95 Pa. 287.

The right of ownership of abutting property owners in trees standing in the highway and their responsibility for these trees has been recognized by the courts. Thus, a property owner has restrained a municipality from cutting down a tree in front of his property: Gitt v. Hanover Borough, 4 Dist. R. 606. And an owner may be indicted for maintaining a nuisance if a tree in front of his property constitutes an unreasonable obstruction to the carriage way: Com. v. Hauek, 103 Pa. 536. See, also, Act of July 14, 1917, P. L. 840. Section 6 of the Act of 1911, supra, provides that the State Highway Department shall have exclusive authority over and jurisdiction of State highways, and there is no doubt that it is the duty of the highway commissioner to abate nuisances within the boundaries of the highway. But this does not relieve the abutting property owner of his liability for his affirmative act in creating or maintaining a nuisance in front of his property. It may be true that the property owner cannot open the highway in front of his property without the consent of the highway department, but if he did open it, with or without its consent, and negligently left a hole so that it became a nuisance, he would be liable for the consequences of his act.

The defendant relies on the case of McCormick v. Allegheny County, 263 Pa. 146, as authority for the proposition that the State alone was responsible for the tree. In this case, a suit was brought against Allegheny County for damages sustained by a pedestrian on a sidewalk along and upon a county road. The court based its decision in that case firmly upon the Act of June 26, 1895, P. L. 336, which vested the maintenance of county roads exclusively in the county commissioners and excluded every other agency or authority from any management or control over them. In the opinion of the court below, which was approved in a per curiam opinion by the Supreme Court, Judge Swearington said, in speaking of the Act of 1895: “In section 16, all road supervisors, authorities, persons and townships are expressly excluded from any management or control of such [county] roads, and are relieved from all responsibility therefor.” /it will also be noted that this was a sidewalk and that it had been laid by the public authorities, and not by the abutting property owner, who had nothing whatever to do with it.

[117]*117The industry of counsel and our own research have failed to disclose a single authority in Pennsylvania directly on the point. Turning to other jurisdictions, we find a New Jersey case, Weller v. McCormick, 52 N. J. L. 470, in which the facts were very similar to the case at bar and in which the abutting property owner was held liable.

We are of the opinion that the fact that this was a State highway and that the State had the management and control of the road, with the duty to maintain and repair it, does not relieve the defendant from liability for maintaining a nuisance, which the jury found this tree to be, within the limits of the highway.

If we concede, however, that there was a misjoinder and the State was the proper party defendant, another interesting question arises. The defendant not having filed an affidavit of defence, can he now interpose the defence that the wrong party was sued? Section 16 of the Practice Act of May 14, 1915, P. L. 483, provides: “Neither party shall be permitted at the trial to make any defence which is not set forth in the affidavit of defence or plaintiff’s reply, as the case may be, except as provided in sections 7 and 13.” Section 7 applies to defences made by fiduciaries and defines the nature of a defence which an executor, guardian, etc., may file. It does not apply to this case where no affidavit was filed.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Sanderson v. Haverstick
8 Pa. 294 (Supreme Court of Pennsylvania, 1848)
City of Allegheny v. Zimmerman
95 Pa. 287 (Supreme Court of Pennsylvania, 1880)
Commonwealth v. Hauck
103 Pa. 536 (Supreme Court of Pennsylvania, 1883)
Knauss v. Brua
107 Pa. 85 (Supreme Court of Pennsylvania, 1884)
Seaman v. Borough of Washington
33 A. 756 (Supreme Court of Pennsylvania, 1896)
McCormick v. Allegheny County
106 A. 203 (Supreme Court of Pennsylvania, 1919)
Gillespie v. Pennsylvania Co.
116 A. 540 (Supreme Court of Pennsylvania, 1922)
Mardo v. Valley Smokeless Coal Co.
123 A. 779 (Supreme Court of Pennsylvania, 1924)
McGlinchey v. Steigerwald
73 Pa. Super. 520 (Superior Court of Pennsylvania, 1920)
Meyers v. Somerset Trust Co.
75 Pa. Super. 40 (Superior Court of Pennsylvania, 1920)
Williams v. Williams
79 Pa. Super. 189 (Superior Court of Pennsylvania, 1922)
Chambers v. Furry
1 Yeates 167 (Supreme Court of Pennsylvania, 1792)

Cite This Page — Counsel Stack

Bluebook (online)
10 Pa. D. & C. 115, 1927 Pa. Dist. & Cnty. Dec. LEXIS 418, Counsel Stack Legal Research, https://law.counselstack.com/opinion/falco-v-bryn-mawr-trust-co-pactcomplmontgo-1927.