Gidor, M., Aplt. v. Mangus, B.

CourtSupreme Court of Pennsylvania
DecidedOctober 23, 2025
Docket21 WAP 2024
StatusPublished

This text of Gidor, M., Aplt. v. Mangus, B. (Gidor, M., Aplt. v. Mangus, B.) is published on Counsel Stack Legal Research, covering Supreme Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gidor, M., Aplt. v. Mangus, B., (Pa. 2025).

Opinion

[J-27-2025] IN THE SUPREME COURT OF PENNSYLVANIA WESTERN DISTRICT

TODD, C.J., DONOHUE, DOUGHERTY, WECHT, MUNDY, BROBSON, McCAFFERY, JJ.

MARY JOAN GIDOR, : No. 21 WAP 2024 : Appellant : Appeal from the Order of the : Superior Court entered January 8, : 2024, at No. 541 WDA 2023, v. : reversing and remanding the Order : of the Court of Common Pleas : Crawford County Civil Division BENJAMIN E. MANGUS D/B/A MANGUS : entered September 20, 2022, at No. INSPECTIONS, : 605 AD 2019 : Appellee : ARGUED: April 10, 2025

OPINION

JUSTICE DONOHUE DECIDED: OCTOBER 23, 2025 In this case we are asked to determine whether 68 Pa.C.S. § 7512 (“Section 7512”)

of the Pennsylvania Home Inspection Law1 is a statute of repose or a statute of limitations.

Section 7512 provides:

§ 7512. Statute of limitations.

An action to recover damages arising from a home inspection report must be commenced within one year after the date the report is delivered. 68 Pa.C.S. § 7512.

We find the plain language of Section 7512 creates a statute of repose.

Accordingly, a plaintiff who does not bring “[a]n action to recover damages arising from a

home inspection report … within one year after the date the report is delivered[,]” is barred

1 Act of December 20, 2000, P.L. 815, as amended, 68 Pa.C.S. § 7512. from doing so, regardless of when the claim accrues. See id. Thus, we affirm the

judgment of the Superior Court.

I. Background

In May 2017, Appellant Mary Joan Gidor (“Gidor”) entered into an agreement to

purchase a home (the “Property”) in Titusville, Pennsylvania. Amended Complaint,

10/10/2019, ¶ 4. Prior to completing the purchase, Gidor orally agreed with Appellee

Benjamin E. Mangus (“Mangus”)2 that he would perform a home inspection of the

Property. Id. ¶¶ 2, 6. On June 6, 2017, Mangus delivered to Gidor his home inspection

report (“Inspection Report”) for the Property, which did not disclose any problems with the

Property’s structural components or foundation. Id. ¶¶ 9-11. On July 31, 2017, based on

“Mangus’ representations in the Inspection Report,” Gidor purchased the Property. Id. ¶¶

12-13.

During the winter of 2018-2019, a water pipe in the Property froze and burst

beneath the primary bathroom. Id. ¶ 14. A plumber repaired the pipe and discovered

that the addition to the Property was built without a foundation over bare ground supported

only by wooden posts. Id. ¶ 16. According to Gidor, the lack of foundation exposed the

bathroom pipes to the elements, which caused the pipes to freeze and burst. Id. ¶ 17.

She also discovered that the vinyl ductwork on the Property was not rated for exterior

use, which allowed animals to chew through it, leading to infestation on the Property. Id.

¶ 18.

On August 21, 2019, Gidor filed a complaint against Mangus bringing three claims:

Count I - a claim under the Pennsylvania Home Inspection Law; Count II - a common law

breach of contract claim; and Count III - a claim under the Pennsylvania Unfair Trade

2Mangus operates his business under the tradename “Mangus Inspections.” Amended Complaint, 10/10/2019, ¶ 2.

[J-27-2025] - 2 Practice and Consumer Protection Law (“UTPCPL”).3 Mangus filed preliminary

objections to which Gidor filed the operative amended complaint (“Amended Complaint”)

on October 10, 2019. In Count I, Gidor alleges that “Mangus breached the duty of care

under the Pennsylvania Home Inspection [L]aw by not revealing or discovering the

Property’s various defects and deficiencies when completing the Property Inspection

Report because such defects and deficiencies should have been apparent to a

reasonably prudent home inspector.” Id. ¶ 27. In Count II, Gidor premises her breach of

contract claim on her “oral contract with Mangus … to provide a property inspection

report[,]” and Mangus’ breach of the duties that were set forth “[i]n the Inspection

Report[.]” Id. ¶¶ 30-34. In Count III, Gidor complains that Mangus violated the UTPCPL

by:

(a) Representing that goods or services have sponsorship, approval, characteristics, ingredients, uses, benefits or quantities that they do not have;

(b) Representing that goods or services are of a particular standard, quality or grade, or that goods are of a particular style or model, if they are of another;

(c) Failing to comply with the terms of any written guarantee or warranty given to the buyer at, prior to or after a contract for the purchase of goods or services is made; and/or

(d) Engaging in any other fraudulent or deceptive conduct which creates a likelihood of confusion or of misunderstanding. Id. ¶ 38(a)-(d).4

3 73 P.S. § 201-1 – 201.10. 4 Subparagraphs (a)-(d) of paragraph 38 of the Amended Complaint mirror the specific examples of “unfair methods of competition” and “unfair or deceptive acts or practices” set forth in the UTPCPL at 73 P.S. §§ 201-2(4)(v), (vii), (xiv), (xxi).

[J-27-2025] - 3 On October 31, 2019, Mangus filed preliminary objections to the Amended

Complaint. First, Mangus argued that Gidor’s breach of contract and UTPCPL claims

were preempted by the Home Inspection Law. Mangus’ Preliminary Objections to

Amended Complaint, 10/31/2019, ¶¶ 4-8. In the alternative, Mangus argued that Gidor

failed to plead sufficient facts to establish her breach of contract claim, id. ¶¶ 9-15, and

failed to plead sufficient facts to establish her UTPCPL claim, id. ¶¶ 16-34. The trial court

overruled Mangus’ first and second preliminary objections, but sustained, in part, his third

preliminary objection to strike subparagraphs (a)-(c) from paragraph 38 of the Amended

Complaint. Trial Court Opinion, 4/14/2020, at 2.

Subsequently, Mangus filed an answer and new matter where he raised Section

7512 and averred that Gidor “failed to file a lawsuit within one year of the delivery of the

Inspection Report.” Mangus’ Answer and New Matter, 7/8/2020, ¶¶ 54-55. After Gidor

admitted this fact in her reply to new matter,5 Mangus filed a motion for judgment on the

pleadings (“Motion for Judgment on the Pleadings”), arguing that Gidor’s claims were

time-barred pursuant to the statute of repose in Section 7512. Mangus’ Motion for

Judgment on the Pleadings, 9/16/2020, ¶¶ 4-6; 8-9.

In opposition, Gidor argued that the General Assembly clearly intended for Section

7512 to be a statute of limitations subject to equitable tolling pursuant to the discovery

rule.6 Gidor’s Brief in Opposition to Motion for Judgment on the Pleadings, 5/31/2022, at

6. In the event the court deemed Section 7512 to be a statute of repose, Gidor argued

that it would violate Article I, Section 11 of the Pennsylvania Constitution (the “Remedies

5 Gidor’s Reply to New Matter, 7/24/2020, ¶ 55. 6 “The discovery rule is a judicially created device which tolls the running of the applicable

statute of limitations until the point where the complaining party knows or reasonably should know that he has been injured and that his injury has been caused by another party’s conduct.” Crouse v. Cyclops Indus., 745 A.2d 606, 611 (Pa. 2000) (citations omitted).

[J-27-2025] - 4 Clause”) which states, in part, that “‘[a]ll courts shall be open; and every man for an injury

done him in his lands, goods, person or reputation shall have remedy by due course of

law[.]’” Id. at 10-11 (quoting PA. CONST. art. I, § 11). Lastly, Gidor maintained that her

separate breach of contract and UTPCPL claims were not subject to Section 7512

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

Related

Abrams v. Pneumo Abex Corp.
981 A.2d 198 (Supreme Court of Pennsylvania, 2009)
Hill v. Divecchio
625 A.2d 642 (Superior Court of Pennsylvania, 1993)
McConnaughey v. Building Components, Inc.
637 A.2d 1331 (Supreme Court of Pennsylvania, 1994)
MCI Worldcom, Inc. v. Pennsylvania Public Utility Commission
844 A.2d 1239 (Supreme Court of Pennsylvania, 2004)
Alliance Home of Carlisle, PA v. Board of Assessment Appeals
919 A.2d 206 (Supreme Court of Pennsylvania, 2007)
Commonwealth v. Magwood
469 A.2d 115 (Supreme Court of Pennsylvania, 1983)
Crouse v. Cyclops Industries
745 A.2d 606 (Supreme Court of Pennsylvania, 2000)
Vargo v. Koppers Co., Inc.
715 A.2d 423 (Supreme Court of Pennsylvania, 1998)
Altoona Area School District v. Campbell
618 A.2d 1129 (Commonwealth Court of Pennsylvania, 1992)
Pocono International Raceway, Inc. v. Pocono Produce, Inc.
468 A.2d 468 (Supreme Court of Pennsylvania, 1983)
Noll by Noll v. Harrisburg Area YMCA
643 A.2d 81 (Supreme Court of Pennsylvania, 1994)
Gleason v. Borough of Moosic
15 A.3d 479 (Supreme Court of Pennsylvania, 2011)
A.S. v. Pennsylvania State Police
143 A.3d 896 (Supreme Court of Pennsylvania, 2016)
Downingtown Borough (Friends of Kardon Park,Aplts)
161 A.3d 844 (Supreme Court of Pennsylvania, 2017)
Dubose, R. v. Willowcrest Nur. Home, Aplts.
173 A.3d 634 (Supreme Court of Pennsylvania, 2017)
Misitis v. Steel City Piping Co.
272 A.2d 883 (Supreme Court of Pennsylvania, 1971)
Kornfeind, W. v. New Werner Holding Co.
2020 Pa. Super. 266 (Superior Court of Pennsylvania, 2020)
Venema, M. v. Moser Builders
2022 Pa. Super. 171 (Superior Court of Pennsylvania, 2022)
Tibbitt, E. v. Eagle Home Inspections
2023 Pa. Super. 219 (Superior Court of Pennsylvania, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
Gidor, M., Aplt. v. Mangus, B., Counsel Stack Legal Research, https://law.counselstack.com/opinion/gidor-m-aplt-v-mangus-b-pa-2025.