LaCivita v. Town & Country Bar & Grill

48 Pa. D. & C.5th 498
CourtPennsylvania Court of Common Pleas, Lawrence County
DecidedJune 11, 2015
DocketNo. 10227 of 2014
StatusPublished

This text of 48 Pa. D. & C.5th 498 (LaCivita v. Town & Country Bar & Grill) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Lawrence County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
LaCivita v. Town & Country Bar & Grill, 48 Pa. D. & C.5th 498 (Pa. Super. Ct. 2015).

Opinion

COX, J.,

Before the Court for disposition are the Preliminary Objections filed on behalf of the defendant Town & Country Bar and Grill a/k/a Town & Country Lounge, 2550 Benjamin Franklin Highway, Edinburg, PA 16116, which argue that the Plaintiff’s Complaint lacked specificity and the Complaint should be dismissed as the Plaintiff has failed to join indispensable parties to the current case.

On January 29, 2015, the plaintiff Melissa Louise LaCivita filed a Complaint, which averred the following facts: On March 28 and March 29, 2012, the Defendant’s employees provided alcoholic beverages to James Karpik and R.J. Crawford at Town & Country Bar and Grill (hereinafter “Town & Country”) when they were visibly intoxicated. On March 29, 2012, the Plaintiff was a passenger in a vehicle that was owned and operated by Mr. Karpik, who drove in a westerly direction on State Route 422. At the same time, Mr. Crawford operated a vehicle owned by Kandice Karpik also in a westerly direction on State Route 422. At 2:38 a.m., Mr. Karpik [501]*501attempted to maneuver his vehicle toward the center lane of State Route 422 when it was struck by the vehicle being operated by Mr. Crawford, who attempted to pass Mr. Karpik’s vehicle. Mr. Karpik and Mr. Crawford were operating the motor vehicles after consuming alcoholic beverages at Town & Country, which, Plaintiff claims, rendered them incapable of safely operating the same.

On March 16, 2015, the Defendant filed Preliminary Objections asserting that the Plaintiff’s Complaint lacks specificity as there are no averments concerning the manner in which Mr. Karpik and Mr. Crawford were operating the vehicles or how the alleged furnishing of alcoholic beverages by the Defendant’s employees caused them to negligently operate the vehicles. Moreover, the Defendant argues that the Plaintiff’s Complaint should be dismissed as the Plaintiff has failed to join Mr. Karpik and Mr. Crawford, who are indispensable parties, which deprived this Court of jurisdiction over the current case.

First, the Court will address the Defendant’s Preliminary Objection concerning lack of specificity of the Plaintiff’s Complaint.

The specificity of a pleading is governed by Pa.R.C.P. No. 1019, which states “(a) The material facts on which a cause of action or defense is based shall be stated in a concise and summary form.” Pennsylvania is a fact-pleading jurisdiction, which requires the plaintiff to provide the defendant with notice of what the plaintiff’s claim is and the grounds for the claim. Unified Sportsmen of Pennsylvania v. Pennsylvania Game Com’n (PGC), 950 A.2d 1120, 1134 (Pa. Cmwlth. 2008) (quoting Sevin v. Kelshaw, 417 Pa. Super. 1, 611 A.2d 1232, 1235 (1992)). Additionally, the plaintiff must summarize the [502]*502facts essential to support the claims. Id. “The rule requires a plaintiff to plead all the facts that he must prove in order to achieve recovery on the alleged cause of action. The pleading must be sufficiently specific so that the defending party will know how to prepare his defense.” Commonwealth ex rel. Pappert v. TAP Pharmaceuticals Products, Inc., 868 A.2d 624, 635 (Pa. Cmwlth. 2005) (citing Department of Transportation v. Shipley Humble Oil Co., 29 Pa. Cmwlth. 171, 370 A.2d 438 (1977)). The purpose behind the rules of pleading is to enable parties to ascertain, by utilizing their own professional discretion, the claims and defenses that are asserted in the case. Krajsa v. Keypunch, Inc., 424 Pa. Super. 230, 236, 622 A.2d 355, 357 (1993). “The pleadings must adequately explain the nature of the claim to the opposing party so as to permit him to prepare a defense, and they must be sufficient to convince the court that the averments are not merely subterfuge.” In re Estate of Schofield, 505 Pa. 95, 477 A.2d 473 (1984) (citing Sokoloff v. Stride, 404 Pa. 343, 172 A.2d 302 (1961); Hornsby v. Lohmeyer, 364 Pa. 271, 72 A.2d 294 (1950); Rice v. Braden, 243 Pa. 141, 89 A. 877 (1914)). “A more specific complaint will not be required where the details requested are evidentiary in nature.” Hock v. L. B. Smith, Inc., 69 Pa. D. & C. 2d 420, 423 (Pa. Com. PI. Columbia 1974) (citing General Acceptance Corp. v. Wilson, 40 Northumb. L. N. 54).

In Connor v. Allegheny General Hospital, 501 Pa. 306, 311, 461 A.2d 600, 603 fn. 3 (1983) (citing Arner v. Sokol, 373 Pa. 587, 592-593, 96 A.2d 854, 856 (1953); King v. Brillhart, 271 Pa. 301, 114 A. 515, 516 (1921)), the Court determined that an averment stating, “otherwise fail[ed] to use due care and caution under the circumstances,” lacked specificity and the defendant could have filed a motion to [503]*503strike off that statement, but chose not to do so. However, a complaint is sufficiently specific if the whole complaint contains material facts which set forth a cause of action. Lipinsky v. Graham, 88 Pa. D. & C. 156, 158 (Pa. Com. PI. Mercer 1954). “A more specific complaint will not be required where the details requested are evidentiary in nature.” Hock v. L. B. Smith, Inc., 69 Pa. D. & C. 2d 420, 423 (Pa. Com. PL Columbia 1974) (citing General Acceptance Corp. v. Wilson, 40 Northumb. L. N. 54).

The Plaintiff’s Complaint fails to set forth any averments establishing the activities of Mr. Karpik and Mr. Crawford which caused the motor vehicle accident other than Mr. Crawford attempted to pass Mr. Karpik. There is no indication that the drivers were operating the vehicles in an erratic manner, the passing was improper or, that Mr. Karpik improperly entered the center lane, nor are there allegations that their alleged intoxication caused them to place the Plaintiff at risk. The Complaint is also devoid of any averments asserting that the drivers were speeding, failed to utilize turn signals, or that the area was a passing or no-passing zone. In addition, the Plaintiff failed to adequately describe the location of the vehicles and the events that culminated in the vehicles colliding. The Defendant needs those facts so it can adequately prepare its defense to the Dram Shop Act claim being asserted by the Plaintiff as the drivers’ conduct may demonstrate that they either were or were not visibly intoxicated at the time the Defendant’s employees provided them alcoholic beverages. The Plaintiff failed to aver any details concerning Mr. Karpik and Mr. Crawford’s actions while in Town & Country which indicated they were visibly intoxicated as required to establish a claim under the Dram Shop Act. Moreover, the lack of specific averments [504]

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Bluebook (online)
48 Pa. D. & C.5th 498, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lacivita-v-town-country-bar-grill-pactcompllawren-2015.