Hangey, R., et ux. v. Husqvarna Aplts.

CourtSupreme Court of Pennsylvania
DecidedNovember 22, 2023
Docket14 EAP 2022
StatusPublished

This text of Hangey, R., et ux. v. Husqvarna Aplts. (Hangey, R., et ux. v. Husqvarna Aplts.) 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
Hangey, R., et ux. v. Husqvarna Aplts., (Pa. 2023).

Opinion

[J-6-2023] [MO: Dougherty, J.] IN THE SUPREME COURT OF PENNSYLVANIA EASTERN DISTRICT

RONALD SCOTT HANGEY AND : No. 14 EAP 2022 ROSEMARY HANGEY H/W, : : Appeal from the Judgment of Appellees : Superior Court entered on March 8, : 2021, at No. 3298 EDA 2017 : reversing the Order entered on v. : September 7, 2017, in the Court of : Common Pleas, Philadelphia : County, Civil Division at No. 1015 HUSQVARNA PROFESSIONAL : March Term, 2017 PRODUCTS, INC., HUSQVARNA GROUP, : HUSQVARNA U.S. HOLDING, INC., : ARGUED: March 8, 2023 HUSQVARNA AB, AND TRUMBAUER'S : LAWN AND RECREATION, INC., : : Appellants :

DISSENTING OPINION

JUSTICE BROBSON DECIDED: NOVEMBER 22, 2023 The Pennsylvania Superior Court reversed the Court of Common Pleas of

Philadelphia County’s (trial court) transfer of venue to Bucks County in this personal injury

and product liability lawsuit, concluding that the trial court erred in focusing exclusively on

the percentage of the corporate defendant’s annual national sales revenue attributable to

Philadelphia County in assessing the “quantity” prong of the venue analysis. The Majority

concludes, and I agree, that the Superior Court did not err in this regard. Id. at 31-42.

Rather than vacate and remand the decision of the trial court for reconsideration,

however, the Superior Court evaluated the merits of the venue challenge de novo,

examining the record independently, assigning weight to relevant factual considerations,

and concluding as a matter of law that Philadelphia County is a proper venue for this lawsuit. The Majority engages in a similar analysis and reaches the same conclusion. Id.

at 42-47. As to this aspect of the Majority’s disposition, I respectfully dissent.

Scott and Rosemary Hangey (Hangeys), plaintiffs in the trial court, purchased a

lawnmower in Bucks County. According to the amended complaint, Scott Hangey was

severely and catastrophically injured on the Hangeys’ property in Wayne County,

Pennsylvania, while operating the mower. The Hangeys instituted their lawsuit in

Philadelphia County against several defendants, including Husqvarna Professional

Products, Inc. (HPP), a Delaware corporation with a principal place of business in

Charlotte, North Carolina. From the allegations in the amended complaint, there is no

connection between Philadelphia and the events giving rise to the Hangeys’ lawsuit. It

would be quite reasonable, under the circumstances, for a layperson to question how

Philadelphia County could possibly be a proper venue to litigate the Hangeys’ suit. The

short answer to that question is that the Pennsylvania Rules of Civil Procedure,

specifically Rule 2179(a)(2), allow a plaintiff to sue a corporate defendant in any “county

where . . . the corporation . . . regularly conducts business,” regardless of how

disconnected that forum may be to the facts or events that gave rise to the lawsuit.

Pa. R.C.P. 2179(a)(2).

With that said, a plaintiff’s choice of venue is not unassailable. A defendant may,

by preliminary objection, challenge the plaintiff’s choice of venue as improper.

Pa. R.C.P. 1006(e), 1028(a)(1).1 Here, HPP filed a preliminary objection, contending that

it does not regularly conduct business in Philadelphia and, therefore, Philadelphia County

is not a proper venue for the Hangeys’ lawsuit under Rule 2179(a)(2). As the Majority

properly explains, when faced with such a challenge, a trial court utilizes the

1 A defendant, or any party for that matter, may also petition to transfer a lawsuit from a

proper venue to another proper venue “[f]or the convenience of parties and witnesses.” Pa. R.C.P. 1006(d)(1).

[J-6-2023] [MO: Dougherty, J.] - 2 quality-quantity analysis to evaluate whether the corporate defendant regularly conducts

business in the venue of plaintiff’s choice. See Majority Opinion at 32-33. If either the

quality or quantity prong of the analysis is lacking, then the plaintiff’s choice of venue is

improper as to the corporate defendant. See Monaco v. Montgomery Cab Co., 208 A.2d

252, 256 (Pa. 1965) (explaining that, “when venue in a particular county depends upon

doing business there, [t]he business engaged in must be sufficient in quantity and quality”)

(citation and internal quotation marks omitted). Here, the trial court determined that the

Hangeys failed to prove that HPP’s activities in Philadelphia met the quantity prong based

solely on the court’s conclusion that the percentage of HPP’s national sales revenue that

was generated in Philadelphia was insufficient to justify subjecting HPP to suit in that

county.

In my view, the Majority correctly holds that, when a trial court assesses the

quantity prong of the improper venue inquiry, the court cannot reject a plaintiff’s choice of

venue based only upon consideration of the percentage of the national revenue that the

corporate defendant produced in the county in question. Majority Opinion at 33-42. As

the Majority accurately explains, this mathematical statistic, in and of itself, is not

dispositive of whether a corporate defendant’s acts within the plaintiff’s chosen forum are

so continuous and sufficient to be considered general or habitual, in accord with this

Court’s precedent. Id.

I am also in full agreement with the Majority’s observations that venue-based

decisions are intensely fact driven and, therefore, that trial courts should be afforded

“considerable discretion” in making those decisions. See Majority Opinion at 31 (stating

that the rules of civil procedure give “trial courts considerable discretion to determine

whether to grant a change of venue, and such a determination will not be disturbed on

appeal absent an abuse of discretion”). Because I agree with the Majority in this regard,

[J-6-2023] [MO: Dougherty, J.] - 3 I am open to the possibility that the trial court in this matter, upon the direction of this

Court to widen the aperture of its analysis of the quantity prong, could, in the exercise of

its considerable discretion, still conclude that the Hangeys’ choice of Philadelphia County

for venue in this case is improper under Rule 2179(a)(2). Unlike the Majority and the

Superior Court, I would not conduct a de novo review of HPP’s venue preliminary

objection, assign weight to particular facts over others, and conclude, as a matter of law,

that Philadelphia County is a proper venue in this case. See Majority Opinion at 44

(stating that, “[a]s a matter of law, when a company maintains a constant physical

presence in the forum county to perform acts that are ‘directly[] furthering, or essential to,

[its] corporate objects[,]’ even when it does so through an authorized dealer, its business

activities are necessarily ‘so continuous and sufficient to be termed general or habitual’”).2

In my respectful view, this approach undermines the “considerable discretion” we afford

to our common pleas courts in this area as well as the deferential nature of our appellate

standard of review in such matters. See Ball v. Bayard Pump & Tank Co., 67 A.3d 759,

767 (Pa. 2013) (“An abuse of discretion occurs only where the trial court has reached a

conclusion that overrides or misapplies the law, or when the judgment exercised is

manifestly unreasonable, or is the result of partiality, prejudice, bias or ill will.”).

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

Related

Monaco v. Montgomery Cab Co.
208 A.2d 252 (Supreme Court of Pennsylvania, 1965)
Ball v. Bayard Pump & Tank Co.
67 A.3d 759 (Supreme Court of Pennsylvania, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Hangey, R., et ux. v. Husqvarna Aplts., Counsel Stack Legal Research, https://law.counselstack.com/opinion/hangey-r-et-ux-v-husqvarna-aplts-pa-2023.