King, C. v. Alpha Sigma Tau Sorority

CourtSuperior Court of Pennsylvania
DecidedJanuary 13, 2025
Docket55 MDA 2024
StatusPublished

This text of King, C. v. Alpha Sigma Tau Sorority (King, C. v. Alpha Sigma Tau Sorority) 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
King, C. v. Alpha Sigma Tau Sorority, (Pa. Ct. App. 2025).

Opinion

J-A23040-24

2025 PA Super 8

CAROL KING, INDIVIDUALLY, AND : IN THE SUPERIOR COURT OF AS ADMINISTRATOR OF THE ESTATE : PENNSYLVANIA OF JUSTIN P. KING, DECEASED : : : v. : : : KAPPA SIGMA FRATERNITY, ALPHA : No. 55 MDA 2024 SIGMA TAU SORORITY, KENNETH : BELL, BRADLEY BRODZICK, : NICHOLAS COLANTINO, JR., : BENJAMIN CONFER, ADAM : HAYDUCEK, CIAN KELLETT, MICHAEL : KUPRESS, CESAR LABOY, BENJAMIN : PACKER, JUSTIN ROMANO, ALLAN : SCHAIBLE, ALEXANDER SCHEEL, : DEREK SHAPIRO, NATHAN : SLEDZIEWSKI, JOHN : STAUFFENBERG, RICHARD YI, : CAITLYNN ALBRIGHT, VICTORIA : BANKS, LINDSEY DEDICS, DANA : DOIMI, CARRISSA DONNELLY, : DANIELLE GODORECCI, KAITLYN : GRIFFITH, ALEXA HADY, RACHEL : JEFFERS, SHELBY KENNEDY, SARA : KERVICK, DANIELLE MAUCERI, : JOCELYN MORGAN, TAYLOR : ROBERTS, CARA THOMAS, JULIA : TRAINER, SARA WECH, JESSICA : WESTENBERGER, TAYLOR WILLIAMS, : AND KELSEY ZOLA : : : APPEAL OF: ALPHA SIGMA TAU : SORORITY :

Appeal from the Order Dated December 6, 2023 In the Court of Common Pleas of Luzerne County Civil Division at No: 2021-01858 J-A23040-24

BEFORE: OLSON, J., STABILE, J., and STEVENS, P.J.E.*

OPINION BY STABILE, J.: FILED JANUARY 13, 2025

This interlocutory appeal concerns whether 48 pages of handwritten

interview notes taken by representatives of Alpha Sigma Tau Sorority (“AST”)

are subject to disclosure to the plaintiff in the underlying action, Carol King,

individually and as administrator of the Estate of Justin P. King, deceased

(“Plaintiff”). Finding that the trial court did not commit an error of law or

abuse its discretion by ordering the notes to be partially redacted and

disclosed to Plaintiff, we affirm.

In 2019, Justin P. King (the decedent) attended a sorority party thrown

by the Beta Nu Chapter of AST at Bloomsburg University, where the decedent

was a freshman. It is alleged by Plaintiff that after being urged by sorority

members to drink several highly alcoholic beverages, the decedent got lost on

campus and fell down a steep slope, resulting in fatal injuries. The Beta Nu

Chapter was suspended by the university due to the role its members had in

that incident.

Plaintiff filed suit in 2021, alleging that AST, and its members who

attended the party at the Beta Nu Chapter house, were liable for the

decedent’s death. In the ensuing litigation, Plaintiff learned that, soon after

the incident, but before the suit was filed, AST’s representatives had

interviewed 15 of its members who were present at the Beta Nu Chapter party.

All of those members were later named as AST’s co-defendants in Plaintiff’s ____________________________________________

* Former Justice specially assigned to the Superior Court.

-2- J-A23040-24

action, and each of them attended their respective interviews with their own

counsel.

On May 2, 2023, Plaintiff filed requests for production so that it could

obtain from AST any documentation of the interviews that AST had conducted

with its members – this included the handwritten interview notes at issue in

the present appeal. As to those notes, AST objected that they were not

subject to disclosure under the work-product doctrine and the attorney-client

privilege. AST emphasized that the top of each page of the notes bore the

heading, “Attorney-Client Privilege For Work Product.” Plaintiff responded to

AST’s objection by moving to compel the production of the notes, insisting

that no such protections applied.

On September 8, 2023, the trial court ordered AST to produce a privilege

log, as well as the documents it believed were undiscoverable. No privilege

log was ever provided, but AST did produce 49 pages of notes taken during

the interviews of its members. AST argued at that point that all of the notes

were the work product of its lead counsel in the litigation, John J. Delany, III,

who was present at the interviews.

In an affidavit, another attorney representing AST (Michael Logue)

averred that Pages 1 to 45 of the notes in question were written by AST’s chief

executive officer (CEO), James Paponetti; Pages 46 and 47 were written by

AST’s chief operating officer (COO), Angie Bong; and Page 48 was a sign-in

sheet created to help Mr. Delany to keep track of who had been interviewed.

Neither Mr. Paponetti, nor Ms. Bong, are AST’s legal counsel.

-3- J-A23040-24

According to the verification, “Mr. Delany was present [when those

notes were written] to provide [AST] with advice and guidance on the issue of

why the Beta Nu chapter at Bloomsburg University was under interim

suspension as of October 2019, when the interviews in question took place.”

See Trial Court 1925(a) Opinion, 3/5/2024, at Exhibit “E” (Verification of

Michael R. Logue, dated 11/10/2023). The verification does not state whether

the notes were actually conveyed to Mr. Delany, or whether they were

transmitted/communicated to anyone other than AST’s attorneys. See id.1

Following oral argument on the issue, and due to the lack of the

mandated privilege log, the trial court conducted an in camera review of the

notes. This review was limited to determining whether the notes indeed

contained any privileged information, such as legal advice, opinions, or

litigation strategy. On December 6, 2023, the trial court entered an order

directing partial redactions of Pages 1, 3, 4, 5, and 46 of the interview notes.

The entirety of Page 49 was found to be the protected attorney work product

of AST. All unredacted portions of the notes were to be turned over to

Plaintiff.2

In response, AST filed the present interlocutory appeal to challenge the

trial court’s order requiring the production of Pages 1 through 48 of the ____________________________________________

1 The verification did not address Page 49 of AST’s interview notes.

2 As AST is only challenging the required disclosure of the unredacted portion

of the interview notes, the redacted portions are irrelevant for the purposes of this appeal.

-4- J-A23040-24

redacted notes to be disclosed. The trial court entered an opinion in

accordance with Pa.R.A.P. 1925(a). Essentially, the trial court rejected AST’s

invocation of the attorney work product doctrine because there was no

indication that the notes were prepared by or at the behest of AST’s counsel,

Mr. Delany. The notes were instead written by AST’s CEO and COO, and the

content of their writings was merely a factual summary of what the

interviewees had stated. See Trial Court 1925(a) Opinion, 3/5/2024, at 7-8.

As to the application of the attorney-client privilege, the trial court ruled

that AST waived the issue by not raising it when the parties argued their

respective positions. The trial court explained further that even if the issue

had been preserved, it would not be availing because AST failed to establish

that the notes contained any private communications between AST and its

counsel which related to facts concerning AST’s legal defense against Plaintiff’s

potential claims. See id., at 9-11.

In its brief, AST now raises two issues:

A.

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Bluebook (online)
King, C. v. Alpha Sigma Tau Sorority, Counsel Stack Legal Research, https://law.counselstack.com/opinion/king-c-v-alpha-sigma-tau-sorority-pasuperct-2025.