Friendship Fire Co. No. 2 v. Durbano

27 Pa. D. & C.4th 88, 1995 Pa. Dist. & Cnty. Dec. LEXIS 100
CourtPennsylvania Court of Common Pleas, Delaware County
DecidedJuly 21, 1995
Docketno. 93-5113
StatusPublished

This text of 27 Pa. D. & C.4th 88 (Friendship Fire Co. No. 2 v. Durbano) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Delaware County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Friendship Fire Co. No. 2 v. Durbano, 27 Pa. D. & C.4th 88, 1995 Pa. Dist. & Cnty. Dec. LEXIS 100 (Pa. Super. Ct. 1995).

Opinion

BATTLE, J.,

The plaintiff, Friendship Fire Company, filed a complaint against the defendants, the Lower Chichester Volunteer Fire Company, George Durbano, John Anthony Rim, Mark Lamplugh, and George Lamplugh. The complaint alleges separate counts of defamation, conspiracy, misrepresentation, and tortious interference with the plaintiff’s right to contract. More specifically, the complaint states that [89]*89the plaintiff, Friendship Fire Company No. 2, and the defendant, Lower Chichester Volunteer Fire Company, were both state-recognized volunteer fire companies for the Lower Chichester Township community. The plaintiff alleges that the defendants made fraudulent misrepresentations to the press, the public, and township officials with the intent of causing damage to the plaintiff’s reputation. It is further alleged by the plaintiff that such actions resulted in the township commissioners’ express withdrawal of recognition of the plaintiff as a township fire company; such actions resulted in a loss of township subsidization. As a result of this harm, the plaintiff seeks punitive damages against the defendants for harm to its reputation and loss of revenue.

The defendants request a dismissal of the complaint and have filed the following preliminary objections in support of their request:

(1) Plaintiff, Friendship Fire Company, is a governmental entity and is incapable of being libeled.

(2) The defendant, Lower Chichester Volunteer Fire Company, is a local agency which cannot be held liable for damages pursuant to the Political Subdivision Tort Claims Act, 42 Pa.C.S. §8541 et seq.

(3) The officials are immune from suit under 42 Pa.C.S. §8545.

(4) The plaintiff failed to cause personal service of the complaint on the defendant, Mark Lamplugh, as required by Pa.R.C.P. 402(a).

When deciding a motion to dismiss, the court must examine the facts in the light most favorable to the non-moving party. In doing so, the court takes all of the allegations averred in the complaint as a true depiction of the defendant’s alleged misconduct. Amotion to dismiss will be granted if the complaint either fails [90]*90to state a claim or is in some other way legally deficient. For the following reasons the court hereby grants the defendants’ motions to dismiss. Each of the defendants’ preliminary objections will be addressed below.

1. WHETHER THE PLAINTIFF IS A GOVERNMENTAL ENTITY AND IS THEREFORE INCAPABLE OF BEING LIBELED

At the time of the injury, the plaintiff was a recognized fire company under state charter. It was, therefore, a governmental local agency for purposes of 42 Pa.C.S. §8501. In City of Philadelphia v. Washington Post Company, 482 F. Supp. 897 (E.D. Pa. 1979), the court was confronted with a complaint brought by the city against the Washington Post newspaper, charging that the newspaper had published malicious statements relating to alleged conduct of police oppression, for the sole purpose of falsely and maliciously misleading the public. The court, in granting the defendant’s motion to dismiss, stated: “The city cannot maintain an action for libel on its own behalf. A governmental entity is incapable of being libeled . . . [T]o permit such a lawsuit to be maintained either on behalf of the city itself, the citizens of the city, or officials or employees of the city would plainly violate the First Amendment of the United States Constitution.” City of Philadelphia, supra at 899.

Further, the United States Supreme Court in NY Times Co. v. Sullivan, 376 U.S. 254 (1964), stated that no court of last resort in this country has ever held, or even suggested, that actions for libel against the government have any place in the American system of jurisprudence. See also, Rosenblatt v. Baer, 383 U.S. 75, 86 S.Ct. 669 (1966). The United States Supreme Court found that, if such actions were allowed, the [91]*91floodgates would be swung open with suits brought by governmental agencies who had been subject to personal criticism. As stated in the Lower Chichester Volunteer Fire Company’s brief:

“A rule of law which would permit the plaintiff fire company, a former agency of local government, to maintain an action for damages against yet another agency and its officials on the former’s claim, that false statements uttered by the latter to its exclusion from public service by elected officials, would be repugnant to the guarantees embodied in the free speech and debate clauses of the First Amendment.”

Such action would enable governmental agencies, motivated by their own personal political agenda, to seek prosecution of civil lawsuits against their political opponents; such suits would be motivated by the actor’s own personal agenda and not by the desire to better serve the public which has entrusted them with their future and welfare.

The defendants’ motions to dismiss regarding the libel claim are hereby granted.

2. WHETHER THE DEFENDANT, MARK LAMPLUGH, WAS IMPROPERLY SERVED UNDER PA.R.C.P. 402(a)

The plaintiff has failed to personally serve the defendant, Mark Lamplugh, with original service of process according to Pa.R.C.P 402. The rule states in pertinent part:

“(a) original process may be served
“(1) by handing a copy to the defendant or
“(2) by handing a copy
“(i) at the residence of the defendant to an adult member of the family with whom he resides; but if [92]*92no adult member of the family is found, then to an adult person in charge of such residence; or . . .
“(in) at any office or usual place of business of the defendant to his agent or to the person for the time being in charge thereof.”

In this instance, the plaintiff purported to effectuate service of the complaint upon the defendant, Mark Lamplugh, by enclosing it with a letter addressed and mailed to the defendant. This is not proper service according to Pa.R.C.P. 402(a) which states that original process must be served by physically handing the complaint to either the defendant or another individual specifically listed under the rule. Mailing the complaint is not personal service, nor is mailing it to the defendant’s attorney, as the plaintiff has done. An attorney does not qualify as an appropriate receiver of the complaint under Pa.R.C.P 402(a).

The plaintiff, Friendship Fire Company, contends that the defendant’s attorney qualifies as an authorized agent of the defendant for purposes of Pa.R.C.P 402(b), and as such may be served the complaint in lieu of Pa.R.C.P 402(a). The plaintiff’s interpretation of Rule 402(b) is erroneous. Rule 402(b) provides that

“In lieu of service under this rule; the defendant or his authorized agent may accept service of original process by filing a separate document.”

An attorney does not qualify as an authorized agent unless the client expressly grants him that authority. Neither the defendant, Mark Lamplugh, nor his attorney filed a separate document agreeing to accept personal service in any manner other than according to Rule 402(a). Therefore, service was not properly effectuated. U.K. LaSalle Inc. v.

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Related

New York Times Co. v. Sullivan
376 U.S. 254 (Supreme Court, 1964)
Rosenblatt v. Baer
383 U.S. 75 (Supreme Court, 1966)
Malia Et Ux. v. Monchak
543 A.2d 184 (Commonwealth Court of Pennsylvania, 1988)
City of Philadelphia v. Washington Post Co.
482 F. Supp. 897 (E.D. Pennsylvania, 1979)
U.K. LaSalle, Inc. v. Lawless
618 A.2d 447 (Superior Court of Pennsylvania, 1992)
Petula v. Mellody
631 A.2d 762 (Commonwealth Court of Pennsylvania, 1993)
Guinn v. Alburtis Fire Co.
614 A.2d 218 (Supreme Court of Pennsylvania, 1992)

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Bluebook (online)
27 Pa. D. & C.4th 88, 1995 Pa. Dist. & Cnty. Dec. LEXIS 100, Counsel Stack Legal Research, https://law.counselstack.com/opinion/friendship-fire-co-no-2-v-durbano-pactcompldelawa-1995.