Garcia, A. v. Foley Incorp.

CourtSuperior Court of Pennsylvania
DecidedMarch 31, 2026
Docket3200 EDA 2024
StatusUnpublished
AuthorMcLaughlin

This text of Garcia, A. v. Foley Incorp. (Garcia, A. v. Foley Incorp.) 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
Garcia, A. v. Foley Incorp., (Pa. Ct. App. 2026).

Opinions

J-A20009-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

ANDRE GARCIA AND DANIELLE : IN THE SUPERIOR COURT OF CASTALEITE : PENNSYLVANIA : Appellants : : : v. : : : No. 3200 EDA 2024 FOLEY, INC., FOLEY RENTS, FOLEY : INCORPORATED D/B/A FOLEY : RENTS, AND CATERPILLAR, INC. :

Appeal from the Order Entered October 24, 2024 In the Court of Common Pleas of Philadelphia County Civil Division at No(s): 230700387

BEFORE: MURRAY, J., McLAUGHLIN, J., and FORD ELLIOTT, P.J.E. *

MEMORANDUM BY McLAUGHLIN, J.: FILED MARCH 31, 2026

Andre Garcia and his wife, Danielle Castaleite (together, “Appellants”),

appeal from the order granting the Motion to Dismiss Based Upon Forum Non

Conveniens. The motion was filed by Caterpillar, Inc. (“Caterpillar”), and was

joined by Foley Inc. and Foley Incorporated d/b/a Foley Rents (“Foley”) (we

will refer to Caterpillar and Foley collectively as Appellees). The court granted

the motion without prejudice to Appellants’ right to refile in New Jersey.

Appellants claim the trial court improperly determined that “weighty reasons”

existed to overcome the deference Pennsylvania law affords to a plaintiff’s

chosen forum. We reverse.

____________________________________________

* Retired Senior Judge assigned to the Superior Court. J-A20009-25

The trial court summarized the allegations giving rise to this suit as

follows:

On November 8, 2022, [Garcia], a resident of New Jersey, was at a worksite in New Jersey when he was struck by an excavator that was being operated by one of his coworkers. The excavator was manufactured by [] Caterpillar, a Delaware Corporation with its principal place of business in Irving, Texas, and leased to [] Garcia’s employer, Persistence Construction Company, a company based in Fairview, New Jersey, by . . . Foley, a Delaware Corporation with its principal place of business in Piscataway, New Jersey. After the incident, Mr. Garcia was transported to Jersey City Medical Center. The incident was investigated by the Jersey City, New Jersey[,] Police Department and the Parsippany, New Jersey Office of OHSA.

Trial Ct. Op., filed Feb. 18, 2025, at 2 (citations omitted).

Appellants instituted this suit in July 2023 by filing a writ of summons

against Foley. They followed with a complaint against Foley in August 2023.

They asserted causes of action for strict liability, negligence, and loss of

consortium. Foley filed an answer and new matter as well as a joinder

complaint adding Caterpillar as an additional defendant. Caterpillar filed an

answer.

In February 2023, Caterpillar moved to dismiss based on forum non

conveniens. It argued that New Jersey was an available and appropriate forum

for the action and that weighty reasons favored dismissal of the suit with leave

to refile in New Jersey. Caterpillar asserted that “the pertinent fact witnesses,

including eye-witnesses [sic], co-workers, police, EMTs, and treating

physicians are all located in New Jersey. See Ex. C. and D.” Add’l Def.

-2- J-A20009-25

Caterpillar’s Motion to Dismiss Based Upon Forum Non Conveniens at 10, ¶

53. It added an assertion that Appellants “received no medical treatment in

Pennsylvania, and no injuries occurred in Pennsylvania. See Ex. B, p[p.] 1-

3.” Id. at 11, ¶ 57.1 It stated that the machinery that injured Garcia was

operated by Glenn Waite, who resides in New Jersey, and asserted that Garcia

“has check-ups every six weeks with Dr. Evan at Newark Hospital[.]” Id. at

2, ¶¶ 3, 8. Caterpillar did not identify any person as a potential witnesses or

summarize any potential testimony. Foley joined the motion to dismiss.

Appellants responded that Foley required lease payments for the

excavator be sent to Philadelphia. They also submitted affidavits from three

Foley employees. Each employee stated he or she “would not find it

problematic to travel to Philadelphia and appear in the Philadelphia Court of

Common Pleas.” Pls.’ Response in Opposition to Add’l Def. Caterpillar’s Motion

to Dismiss, at 11-12 and Ex. B, C, D, at 2 ¶ 6. The employees were the project

manager, Domenic Grano; the excavator operator, Glenn Waite; and Foley’s

human resources and office manager, Janet Tawil. Id. Appellants argued that

the public and private factors considered when addressing forum non

conveniens motions favored denying the motion.

Caterpillar filed a reply that included an affidavit from Foley’s general

manager, Matthew Emerson. Emerson stated that Foley was located in

1 See also Mem. of Law in Support of Add’l Def. Caterpillar Inc.’s Motion to

Dismiss Based Upon Forum Non Conveniens at 15 (making identical assertions).

-3- J-A20009-25

Piscataway, New Jersey and did not have any offices in Philadelphia County.

He further asserted that that for ease of administration of payments mailed to

the bank Foley’s bank had opened a post office box in Philadelphia that the

bank controlled. Emerson further stated that it “is approximately fifteen (15)

minutes from Foley, Incorporated – where the product at issue and Foley

employees are located – to the Middlesex County Superior Court.” Aff. of

Matthew Emerson at ¶ 9. He stated that it would be “an undue hardship and

be oppressive” to Foley “to have multiple employees either be on call and

appear at the last minute and/or have multiple employees (technicians and

supervisors) be required to travel from Northern New Jersey to Philadelphia

on a daily basis for a two to three week product liability trial.” Id. at ¶ 10.

The trial court permitted the parties to file supplemental briefs. 2

Appellants’ supplemental memorandum of law pointed out that the parties had ____________________________________________

2 The court further provided that:

The Court will accept affidavits, deposition testimony, and documentary evidence relevant to the [forum non conveniens] issue . . . All affidavits must be submitted to opposing counsel and filed of record no later than 20 days from the docketing of this Order. If the party receiving an affidavit wished to depose the affiant on the issue stated above, said deposition must occur between the date the affidavit is produced and two days before supplemental briefs are due to the Court. Nothing in this Rule shall prevent the parties from taking depositions on the issue stated above prior to the production of an affidavit. The parties shall file of record any affidavits, deposition testimony, and documentary evidence; alternatively, the parties may attach such items as exhibits to the supplemental brief.

Rule to Show Cause, filed June 26, 2024.

-4- J-A20009-25

scheduled a joint inspection of the excavator in Bensalem, Pennsylvania, and

had scheduled depositions to occur in Philadelphia, Pennsylvania. Appellants’

Supp. Memo. in Support of Resp. to Mot. To Dismiss, filed Aug. 19, 2024, at

1, 4.

In October 2024, the trial court granted the motion. Appellants filed a

motion for reconsideration, which the trial court denied. Appellants appealed.

They raise the following issues:

1. Did the trial court err as a matter of law or otherwise abuse its discretion in ordering the dismissal of this suit for forum non conveniens, to be re–filed in New Jersey, given the inadequate evidence to obtain that relief that additional defendant Caterpillar Inc. offered to the trial court?

2. Should the trial court’s order dismissing this case for forum non conveniens be reversed in accordance with this Court’s decisions in Vaughan v.

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