KILEY BY KILEY v. City of Philadelphia

645 A.2d 184, 537 Pa. 502, 1994 Pa. LEXIS 260
CourtSupreme Court of Pennsylvania
DecidedJuly 1, 1994
Docket25 Eastern District Appeal Docket 1993
StatusPublished
Cited by68 cases

This text of 645 A.2d 184 (KILEY BY KILEY v. City of Philadelphia) 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
KILEY BY KILEY v. City of Philadelphia, 645 A.2d 184, 537 Pa. 502, 1994 Pa. LEXIS 260 (Pa. 1994).

Opinions

OPINION OF THE COURT

PAPADAKOS, Justice.

This is the appeal of the City of Philadelphia (Appellant) from the unreported memorandum opinion and order of the [504]*504Commonwealth Court affirming in part and reversing in part the order of the Court of Common Pleas of Philadelphia County entering summary judgment in its favor, after finding Appellant, the City of Philadelphia, not liable for injuries sustained by Joseph Kiley, III (Joseph) in a tragic accident on April 28, 1985, which has left him in a permanent vegetative state.

Joseph, by his parents, Joseph and Deborah Kiley, Jr., (Appellees) filed the instant action alleging that in 1985, Appellant had possession of an abandoned row house located on the comer of Rosehill and Thayer Streets in the City of Philadelphia, and that Appellant hired a demolition Company, Robert Miner, Inc. (Miner) to demolish the house. Appellees further alleged that during the demolition, bricks and debris from the house fell onto the abutting sidewalk and street, and that community residents complained to Appellant about the dangerous conditions of the demolition site and the adjacent sidewalk and street. As a result of these complaints, Appellant erected barricades around the bricks and debris so that pedestrians would not walk on the affected sidewalk and street, but would be required to walk around the barricades on unobstmcted sidewalks and the street.

On April 28, 1985, little Joseph, then only five years old, accompanied by other children, walked on the street near the demolition site to an ice cream truck parked nearby. While walking on the street he was struck by an uninsured motor vehicle operated by Patricia Johanson (Johanson), leaving, him permanently injured with “spastic quadriplegia” and in a “vegetative state”.

Appellees brought suit against Miner and the City of Philadelphia, inter alia, alleging that their actions in blocking the sidewalk and street and not providing an alternate sidewalk was a substantial factor in bringing about Joseph’s injuries. Appellees also sued the police department, alleging that although help had been requested through the police emergency telephone number, police assistance was slow contributing to the seriousness of Joseph’s injuries.

[505]*505Appellant filed an answer and new matter alleging governmental immunity as a defense and alleging that the accident occurred 45-60 feet past the demolition site in the middle of the intersection and that, therefore, Appellant’s actions could not have been a substantial factor in causing the accident. The Honorable Abraham Gafni of the Court of Common Pleas of Philadelphia County agreed with Appellant and granted summary judgment in its favor. The Commonwealth Court affirmed that portion of the trial court’s order granting summary judgment for the actions of the police in arriving at the accident scene late, but reversed on the question of whether Appellant’s control of the street and sidewalk area around the demolition site were substantial factors bringing about the accident. That court concluded that sufficient facts were pled in Appellees’ complaint to establish that Appellant’s conduct in maintaining the sidewalk and street created a dangerous condition which, in some part, directly caused Joseph’s injuries and, under such circumstances, it would be better to allow a jury to determine the exact extent of the liability of Appellant to Appellees. Kiley v. Miner, 148 Pa.Commonwealth Ct. 637, 611 A.2d 378 (1992).

We granted further review to examine this case in light of our recent decision in Crowell v. Philadelphia, 531 Pa. 400, 613 A.2d 1178 (1992), which held that pursuant to the Political Subdivision Tort Claims Act a municipality can be held liable in damages only for its acts of active negligence, and Snyder v. Harmon, 522 Pa. 424, 562 A.2d 307 (1989), where we concluded that the real estate exception to the rule of immunity is applicable only in those cases where it is alleged that the dangerous conditions of the land itself causes an injury and not merely when it facilitates injury by acts of others, whose acts are outside of the Political Subdivision Tort Claims Act’s scope of liability.

We begin our analysis of this case, first, by noting that under our previously decided cases we have made clear that the Political Subdivision Tort Claims Act, 42 Pa.C.S. §§ 8541-8564, is a legislatively imposed shield of government immunity against any damages on account of any injury to any [506]*506person or property by any act of a local agency or employees thereof or any other person, except as provided in the statute itself. Mascaro v. Youth Study Center, 514 Pa. 351, 523 A.2d 1118 (1987). Because of the clear intent to insulate government from exposure to tort liability for any of its acts, exceptions carved out by the Legislature from this general rule are strictly construed. Love v. City of Philadelphia, 518 Pa. 370, 543 A.2d 531 (1988); Snyder v. Harmon, 522 Pa. 424, 562 A.2d 307 (1989).

The pertinent exceptions to the statute which Appellees argue expose Appellant to liability are the exception to real property and sidewalks, 42 Pa.C.S. §§ 8542(b)(3) and (b)(7), which provide respectively:

(b) Acts which may impose liability.—The following acts by a local agency or any of its employees may result in the imposition of liability on a local agency:
(3) Real property.—The care, custody or control of real property in the possession of the local agency, except that the local agency shall not be liable for damages on account of any injury sustained by a person intentionally trespassing on real property in the possession of the local agency....
(7) Sidewalks.—A dangerous condition of sidewalks within the rights-of-way of streets owned by the local agency, except that the claimant to recover must establish that the dangerous condition created a reasonably foreseeable risk of the kind of injury which was incurred and that the local agency had actual notice or could reasonably be charged with notice under the circumstances of the dangerous condition at a sufficient time prior to the event to have taken measures to protect against the dangerous condition. When a local agency is hable for damages under this paragraph by reason of its power and authority to require installation and repair of sidewalks under the care, custody and control of other persons, the local agency shall be secondarily liable only and such other persons shall be primarily liable.

For the real property exception of immunity to apply, we have required a showing that the artificial condition or defect [507]*507of the land itself caused an injury, not merely that it facilitates injury by acts of others, because their acts are outside the scope of the Tort Claims Act. Mascaro; Snyder. The same can be said for the sidewalk exception inasmuch as we have applied this standard to an interpretation of the sovereign immunity statute’s real estate, highway and sidewalk exception, 42 Pa.C.S.

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

Related

FULLMAN v. CITY OF PHILADELPHIA
E.D. Pennsylvania, 2025
Brooks v. Cole; Apl of: Family Court
Supreme Court of Pennsylvania, 2021
Degliomini, A., et ux., Aplts. v. ESM - 5 EAP 2020
Supreme Court of Pennsylvania, 2021
MADAR v. CITY OF PHILADELPHIA
E.D. Pennsylvania, 2021
Taha v. Bucks County Pennsylvania
367 F. Supp. 3d 320 (E.D. Pennsylvania, 2019)
Hope v. Fair Acres Geriatric Center
174 F. Supp. 3d 880 (E.D. Pennsylvania, 2016)
V. Martin v. City of Philadelphia and B. Mussaw
Commonwealth Court of Pennsylvania, 2016
Win & Son, Inc. v. City of Philadelphia
162 F. Supp. 3d 449 (E.D. Pennsylvania, 2016)
D. Moon v. Dauphin County
129 A.3d 16 (Commonwealth Court of Pennsylvania, 2015)
Mason v. City of Allentown
32 Pa. D. & C.5th 541 (Lehigh County Court of Common Pleas, 2013)
Allen v. County of Wayne
88 A.3d 1035 (Commonwealth Court of Pennsylvania, 2013)
Jones v. City of Philadelphia
893 A.2d 837 (Commonwealth Court of Pennsylvania, 2006)
Cowell v. Commonwealth, Department of Transportation
883 A.2d 705 (Commonwealth Court of Pennsylvania, 2005)
Jones v. City of Philadelphia
73 Pa. D. & C.4th 246 (Philadelphia County Court of Common Pleas, 2005)
Simko v. County of Allegheny
869 A.2d 571 (Commonwealth Court of Pennsylvania, 2005)
Govan v. Philadelphia Housing Authority
848 A.2d 193 (Commonwealth Court of Pennsylvania, 2004)
Cohen v. City of Philadelphia
847 A.2d 778 (Commonwealth Court of Pennsylvania, 2004)
Erb v. Greenmount Community Fire Co.
63 Pa. D. & C.4th 353 (Adams County Court of Common Pleas, 2003)
Van Horn v. Reinhart Flynn Inc.
62 Pa. D. & C.4th 358 (Carbon County Court of Common Pleas, 2003)
Levan v. City of Allentown
62 Pa. D. & C.4th 258 (Lehigh County Court of Common Pleas, 2003)

Cite This Page — Counsel Stack

Bluebook (online)
645 A.2d 184, 537 Pa. 502, 1994 Pa. LEXIS 260, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kiley-by-kiley-v-city-of-philadelphia-pa-1994.