Lynch, J. v. Lexi's Auto Sales

CourtSuperior Court of Pennsylvania
DecidedMarch 20, 2025
Docket1468 WDA 2023
StatusUnpublished

This text of Lynch, J. v. Lexi's Auto Sales (Lynch, J. v. Lexi's Auto Sales) 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
Lynch, J. v. Lexi's Auto Sales, (Pa. Ct. App. 2025).

Opinion

J-A29041-24

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

JALMAR LYNCH, JUNIOR : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : LEXI'S AUTO SALES & SERVICE : : Appellant : No. 1468 WDA 2023

Appeal from the Judgment Entered May 20, 2024 In the Court of Common Pleas of Allegheny County Civil Division at AR-22-001443

BEFORE: OLSON, J., LANE, J., and BENDER, P.J.E.

MEMORANDUM BY BENDER, P.J.E.: FILED: March 20, 2025

Lexi’s Auto Sales & Service (Appellant) appeals from the judgment

entered after the trial court struck Appellant’s appeal from an arbitration

award and reinstated the $4,600 award in favor of Appellee, Jalmar Lynch,

Junior (Lynch). We affirm.

On May 19, 2022, Lynch filed a pro se complaint in arbitration. Lynch

averred that he had purchased a vehicle and “car protection plan” from

Appellant. Complaint, 5/19/22, at 2. Lynch claimed Appellant failed to honor

the protection plan, and he sought to recover costs he incurred to have the

vehicle “repaired after purchasing.” Id.1

____________________________________________

1 Lynch stated that when he attempted to use the protection plan, he “was told they didn’t know who [he was].” Id. When Lynch sought assistance in person, Appellant’s representative told him “nobody c[ould] assist” him, and “proceeded to get angry and ask [Lynch] if [he] wanted to fight.” Id. J-A29041-24

PROCEDURAL HISTORY

On October 7, 2022, the Board of Arbitrators held a hearing and entered

the award in favor of Lynch. Appellant filed a pro se appeal on October 17,

2022. See 42 Pa.C.S. § 7631(d) (stating a party to arbitration “shall have

the right to appeal for trial de novo in the court”). On March 31, 2023, the

trial court issued an order scheduling a de novo hearing for July 19, 2023.

The trial court explained:

On April 4, 2023, the Department of Court Records mailed copies of the scheduling [o]rder to all parties pursuant to Pa.R.C[iv].P. 236 (hereinafter Rule 236). On July 19, 2023, th[e] court advised the parties that the trial would be continued for Appellant to get legal counsel because pursuant to the local rules of Allegheny County Civil and Family Court[,] corporations must be represented by counsel. Th[e] court further advised both parties they would receive another scheduling order with a new trial date.

On August 3, 2023, th[e] court issued an order scheduling the trial on October 10, 2023. On August 11, 2023, the Department of Court Records mailed copies to all parties … pursuant to Rule 236. On October 10, 2023, the non-jury trial was held at 1:00 p.m.; only [Lynch] was present and ready to proceed. Neither Appellant nor counsel appeared. At 1:27 p.m., Appellant still had not appeared and had not contacted the court in any manner to explain the[] absence. The court proceeded to trial. [Lynch] summarized the facts of the[] case. On November 13, 2023, the court entered a non-jury verdict, striking [] Appellant’s [a]ppeal from the October 7, 202[2] [a]rbitration [a]ward and reinstating the $4,600 award for [Lynch]. On November 14, 2023, the Department of Court Records mailed notices of the non-jury verdict to the parties pursuant to Rule 236.

… Appellant [timely] filed a post-trial [m]otion and [m]otion for [p]ost-[t]rial [r]elief. The motions are identical. However, the court has no record that [] Appellant served, notified, or presented to the court said motions.

Trial Court Opinion (TCO), 2/28/24, at 3-4.

-2- J-A29041-24

The trial court did not rule on Appellant’s post-trial motions. On

December 13, 2023, Appellant filed a notice of appeal. The trial court did not

order Appellant to file a concise statement pursuant to Pa.R.A.P. 1925(b),

although it issued an opinion. The court recommended the appeal “be

dismissed as judgment had not been entered.” TCO at 4. In the alternative,

the court explained it “did not err in proceeding to trial where [Appellant] was

not ready when the case was called for trial.” Id. at 5.

On April 18, 2024, this Court issued an order directing Appellant to

praecipe the trial court Prothonotary to enter judgment. See Pa.R.Civ.P.

227.4(1)(b) (providing for entry of final judgment if a trial court does not

dispose of post-trial motions within 120 days). On June 7, 2024, Appellant

filed a response showing that judgment was entered on May 20, 2024. See

Pa.R.A.P. 905(a)(5) (stating that an appeal “filed after the announcement of

a determination but before the entry of an appealable order shall be treated

as filed after such entry and on the day thereof”). Accordingly, we consider

Appellant’s argument.

Appellant presents the following question:

Did the [t]rial [c]ourt abuse its discretion and commit an error of law by failing to grant Appellant’s motion for post-trial relief[,] which included a request for a new trial on the ground of a satisfactory excuse for [Appellant’s] failure to appear[,] which excuse included that a “hearing” was scheduled, and not a trial, so that Appellant never received notice of a trial and no trial date was listed on the docket?

Appellant’s Brief at 4.

-3- J-A29041-24

DISCUSSION

Appellant claims it: (1) “did not receive the [scheduling o]rder in the

mail,” and (2) “was never made aware that a ‘trial’ was being held on October

[10], 2023.” Id. at 7. Appellant properly cites Pa.R.Civ.P. 218, which applies

“where a party is not ready when a case is called for trial.” Id. at 8. According

to Appellant:

The docket … is clear that this case was never called for trial. … A party can avoid the consequences of Rule 218 if it has a satisfactory excuse. In the case at bar, Appellant never received a notice that the case was being called to trial and no trial date appears on the docket.

Id.

Appellant acknowledges that Rule 218 “also applies, through case law,

to conciliatory or pretrial conferences.” Id. at 9 (citations omitted). Appellant

further recognizes the trial court’s discretion to proceed in a party’s absence.

Id. However, Appellant asserts that the court “may not enforce the Rule[] so

rigidly that injustice will be produced.” Id. Appellant contends Lynch “would

not be prejudiced by the delay.” Id. at 11. Finally, Appellant suggests the

trial court should have “attempted to make contact with Appellant prior to

dismissing the appeal,” and “consider[ed] lesser sanctions.” Id.2

In reviewing Appellant’s argument, we “must focus on whether the trial

court’s decision … was a proper exercise of discretion based on all facts of the

case.” Jamison v. Johnson, 762 A.2d 1094, 1097 (Pa. Super. 2000)

2 Lynch has not filed a brief.

-4- J-A29041-24

(citation omitted). “It is well settled that the mere failure to appear for trial

is a ground for the entry of a nonsuit.” Id. (citations omitted).

Pertinently, Rule 218 provides:

(a) Where a case is called for trial, if without satisfactory excuse a plaintiff is not ready, the court may enter a nonsuit on motion of the defendant or a non pros on the court’s own motion.

(b) If without satisfactory excuse a defendant is not ready, the plaintiff may

(1) proceed to trial, or,

(2) if the case called for trial is an appeal from compulsory arbitration, [the plaintiff may] either proceed to trial or request the court to dismiss the appeal and reinstate the arbitration award. ...

(c) A party who fails to appear for trial shall be deemed to be not ready without satisfactory excuse.

Pa.R.Civ.P.

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Cite This Page — Counsel Stack

Bluebook (online)
Lynch, J. v. Lexi's Auto Sales, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lynch-j-v-lexis-auto-sales-pasuperct-2025.