John Doe c/o Andreozzi & Foote v. T. Dumas, Dollar Boyz, Inc.

CourtCommonwealth Court of Pennsylvania
DecidedJuly 15, 2025
Docket1183 C.D. 2023
StatusPublished

This text of John Doe c/o Andreozzi & Foote v. T. Dumas, Dollar Boyz, Inc. (John Doe c/o Andreozzi & Foote v. T. Dumas, Dollar Boyz, Inc.) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
John Doe c/o Andreozzi & Foote v. T. Dumas, Dollar Boyz, Inc., (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

John Doe c/o Andreozzi & Foote, : Appellant : : v. : : Tyree Dumas, Dollar Boyz, Inc. : a/k/a DollarBoyz, Y-Not : (Youth Now on Top), School District : of Philadelphia, and Multicultural : No. 1183 C.D. 2023 Academy Charter School : Submitted: June 3, 2025

BEFORE: HONORABLE CHRISTINE FIZZANO CANNON, Judge HONORABLE MATTHEW S. WOLF, Judge HONORABLE BONNIE BRIGANCE LEADBETTER, Senior Judge

OPINION BY JUDGE FIZZANO CANNON FILED: July 15, 2025

John Doe c/o Andreozzi & Foote (Doe) seeks review of orders of the Court of Common Pleas of Philadelphia County (Trial Court) that sustained the preliminary objections of Philadelphia School District (School District) and Multicultural Academy Charter School (Charter School) (jointly, Schools) and dismissed Doe’s claims against them on the basis of immunity from suit. In its written opinion pursuant to Rule 1925(a) of the Pennsylvania Rules of Appellate Procedure, Pa.R.A.P. 1925(a) (1925(a) Opinion), the Trial Court asserted that this Court should quash Doe’s appeal because the orders at issue are interlocutory and not appealable as of right as collateral orders, as they do not meet the requirements for appealable collateral orders. Because we agree and consequently conclude that we lack jurisdiction over the appeal, we quash Doe’s appeal. I. Background Doe alleges that in 2013 and 2014, when he was a minor, he was sexually assaulted repeatedly by an adult perpetrator he met while participating in activity programs for minors offered by Tyree Dumas, Dollar Boyz, Inc. a/k/a DollarBoyz, and Y-Not (Youth Now on Top) (jointly, Y-Not). The perpetrator of the assault was allegedly employed as a security officer by Schools during imprecisely pleaded time periods. Doe does not allege that the assaults occurred on property of either School District or Charter School or in the course of the perpetrator’s employment by either School District or Charter School. Instead, he alleges that the perpetrator engaged in unspecified improper conduct toward other minors while employed by Schools that should have caused them to report the perpetrator’s alleged conduct to authorities. Doe hypothesizes that such reports would have resulted in prosecution of the perpetrator or otherwise prevented the perpetrator from subsequently assaulting Doe. Schools filed preliminary objections asserting, inter alia, that Doe’s claims against them were barred by immunity. The trial court sustained the preliminary objections based on immunity and dismissed Doe’s claims against Schools with prejudice. Doe’s claims against Y-Not, however, remain pending in the Trial Court. Doe appealed to this Court, arguing that the Trial Court erred on various grounds in concluding that Schools were entitled to immunity from Doe’s claims. In his docketing statement and subsequent appellate brief, Doe does not suggest that the orders in question are appealable as final orders. Instead, he avers, regarding this Court’s jurisdiction, that his appeal is permitted as of right under Rule 313 of the

2 Pennsylvania Rules of Appellate Procedure, Pa.R.A.P. 313, allowing immediate interlocutory appeals of collateral orders. In its 1925(a) Opinion, the Trial Court did not address the merits of the issues raised by Doe on appeal. Instead, the Trial Court focused exclusively on why the appeal was not a permitted collateral appeal and should be quashed. See generally 1925(a) Opinion.

II. Discussion Notwithstanding the Trial Court’s exclusive focus on the question of this Court’s subject matter jurisdiction over Doe’s appeal, Doe provides virtually no development of that issue in his brief. He addresses the question of jurisdiction only in a few sentences in his Statement of Jurisdiction, merely stating in conclusory fashion that the Trial Court’s rulings regarding immunity are immediately appealable as collateral orders relating to immunity. Charter School likewise provides no analysis of this Court’s jurisdiction in its brief. School District, in its brief, echoes the Trial Court in asserting that this Court lacks jurisdiction over Doe’s appeal. School District maintains that the Trial Court’s orders do not satisfy the criteria for appealable collateral orders under Rule 313. School District distinguishes the authority cited by Doe, which related to appeals from denials of pretrial requests for relief seeking dismissal on immunity grounds. School District posits that the policy considerations and other factors weighed in assessing whether an interlocutory order is appealable as a collateral order apply much differently depending on whether the order under review has granted or denied pretrial requests for relief asserting immunity. We agree.

3 As a general rule, only final orders that dispose of all claims and all parties are appealable. Pa.R.A.P. 341(a) & (b). As our Supreme Court has explained, “[c]onsidering issues only after a final order maintains distinctions between trial and appellate review, respects the traditional role of the trial judge, and promotes formality, completeness, and efficiency.” Shearer v. Hafer, 177 A.3d 850, 855 (Pa. 2018). Rule 313, however, provides a narrow exception to the final order rule, as follows: (a) General Rule. An appeal may be taken as of right from a collateral order of a trial court or other government unit. (b) Definition. A collateral order is an order separable from and collateral to the main cause of action where the right involved is too important to be denied review and the question presented is such that if review is postponed until final judgment in the case, the claim will be irreparably lost. Pa.R.A.P. 313. Our Supreme Court has explained that Rule 313 codifies a three-part test for applicability of the collateral order doctrine, under which an order is considered final and appealable if (1) it is separable from and collateral to the main cause of action; (2) the right involved is too important to be denied review; and (3) the question presented is such that if review is postponed until final judgment in the case, the claimed right will be irreparably lost. . . . [W]here an order satisfies Rule 313’s three-pronged test, an appellate court may exercise jurisdiction even though the order is not final. If the test is not met, however, and in the absence of another exception to the final order rule, there is no jurisdiction to consider an appeal of such an order. Brooks v. Ewing Cole, Inc., 259 A.3d 359, 370 (Pa. 2021) (brackets in Brooks; internal quotation marks and additional citations omitted). As an exception to the

4 final order rule, the collateral order doctrine must be narrowly construed. Shearer, 177 A.3d at 858. “Regarding the first prong, an order is separable from the main cause of action if it can be resolved without an analysis of the merits of the underlying dispute and if it is entirely distinct from the underlying issue in the case.” Brooks, 259 A.3d at 371 (internal quotation marks and additional citation omitted). In Brooks, our Supreme Court held that a pretrial determination regarding immunity is separable from the underlying cause of action because it is a “purely legal question . . . and does not necessitate an examination of the merits of [the underlying] claim.” Id. Here, as in Brooks, no party disputes that the Trial Court’s orders concerning immunity are separable from Doe’s underlying claims against the various defendants, including Schools. Accordingly, the first prong of the collateral order doctrine has been met. The second prong of the collateral order analysis requires “examin[ing] the importance of the right involved by weighing the interests that immediate appellate review would protect against the final judgment rule’s interests in efficiency through avoiding piecemeal litigation.” Brooks, 259 A.3d at 372.

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

Related

Shearer, D., Aplts. v. Hafer, S.
177 A.3d 850 (Supreme Court of Pennsylvania, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
John Doe c/o Andreozzi & Foote v. T. Dumas, Dollar Boyz, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-doe-co-andreozzi-foote-v-t-dumas-dollar-boyz-inc-pacommwct-2025.