Maggitti, U. v. Maggitti, V.

CourtSuperior Court of Pennsylvania
DecidedSeptember 28, 2022
Docket2420 EDA 2021
StatusUnpublished

This text of Maggitti, U. v. Maggitti, V. (Maggitti, U. v. Maggitti, V.) 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
Maggitti, U. v. Maggitti, V., (Pa. Ct. App. 2022).

Opinion

J-A13040-22

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT I.O.P. 65.37

URVE MAGGITTI : IN THE SUPERIOR COURT OF : PENNSYLVANIA Appellant : : v. : : VICTOR J. MAGGITTI, JR. : : Appellee : No. 2420 EDA 2021

Appeal from the Order Entered October 26, 2021 In the Court of Common Pleas of Chester County Civil Division at No(s): 2021-07135-CT

BEFORE: OLSON, J., DUBOW, J., and KING, J.

MEMORANDUM BY KING, J.: FILED SEPTEMBER 28, 2022

Appellant, Urve Maggitti, appeals pro se from the order entered in the

Chester County Court of Common Pleas, which denied Appellant’s motion to

seal the complaint and attached exhibits in this breach of contract action. We

vacate and remand for further proceedings.

The facts and procedural history of this case are as follows. On

September 9, 2021, while the parties were in the process of obtaining a

divorce, Appellant field a pro se complaint against Appellee, Victor J. Maggitti,

Jr., alleging breach of contract and other claims related to Appellee’s attempt

to modify a divorce agreement between the parties. Attached to the complaint

were two exhibits. Exhibit A is an email containing the details of the parties’

divorce agreement, and Exhibit B is another email where Appellee attempts

to modify the monetary amounts in the initial agreement. Contemporaneously J-A13040-22

with filing the complaint, Appellant filed a motion to seal the complaint and

exhibits. On September 13, 2021, the trial court denied the motion to seal,

finding that although both parties wished for the complaint and exhibits to be

kept private, Appellant did not show good cause that closure is necessary to

prevent a clearly defined and serious injury.

On September 14, 2021, Appellant filed a praecipe to withdraw the

complaint. On September 16, 2021, she filed a motion to reconsider the

court’s September 13, 2021 order, requesting again that the court seal the

complaint and exhibits. The court denied the motion for reconsideration that

same day.

Appellant subsequently filed a second motion for reconsideration

arguing that, because of the pending divorce action between the parties, the

breach of contract complaint pertained to the existing prenuptial agreement

between the parties. She also argued that Exhibit A constituted a confidential

agreement pursuant to 23 Pa.C.S.A. § 3105 (governing effect of agreement

between parties in divorce proceedings).

On October 26, 2021, the trial court granted in part and denied in part

the motion for reconsideration. The court granted Appellant’s request to seal

Exhibit A, finding that she had shown good cause for its closure. However,

the court denied Appellant’s request to seal the complaint and Exhibit B

because, it concluded, Appellant failed to identify any allegation that contains

confidential information under the Case Records Public Access Policy of the

-2- J-A13040-22

Unified Judicial System of Pennsylvania.

Appellant filed a timely notice of appeal on November 23, 2021. The

court did not order Appellant to file a concise statement of errors complained

of on appeal, and Appellant filed none.

Appellant raises the following issues on appeal:

I. Was it error for the Court of Common Pleas of Chester County, Pennsylvania to not allow the statutory 20-days for the opposing party to weigh in on the Motion to Seal confidential information?

II. Was it error for the Court of Common Pleas of Chester County, Pennsylvania to deny Motion to Seal Complaint which contained sensitive confidential information?

III. Was it error for the Court of Common Pleas of Chester County, Pennsylvania to grant Motion to Seal regarding one Exhibit A and deny … Motion to Seal to another Exhibit B that contained similar confidential information?

IV. Was it error for the Court of Common Pleas of Chester County, Pennsylvania to deny Appellant’s request for oral argument and/or an evidentiary hearing?

V. Was it error for the Court of Common Pleas of Chester County, Pennsylvania to deny Appellant’s request to seal confidential information contained in the original pleading the Verified Complaint and in the Exhibit “B”?

(Appellant’s Brief at 3-4).

Preliminarily, we must discern whether Appellant’s challenge is properly

before us. An appeal may be taken from: (1) a final order or an order certified

as a final order; (2) an interlocutory order as of right; (3) an interlocutory

order by permission; or (4) a collateral order. See Pa.R.A.P. 341, 311, 312,

and 313, respectively. “A collateral order is an order separable from and

-3- J-A13040-22

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(b).

“[T]he collateral order doctrine is a specialized practical application of

the general rule that only final orders are appealable as of right. Thus, Rule

313 must be interpreted narrowly, and the requirements for an appealable

collateral order remain stringent in order to prevent undue corrosion of the

final order rule.” A.A. v. Glicken, 237 A.3d 1165, 1169 (Pa.Super. 2020)

(quoting Melvin v. Doe, 575 Pa. 264, 272, 836 A.2d 42, 47 (2003)).

An issue is separable if it can be examined without analysis of the claims presented in the underlying litigation. See [Ben v. Schwartz, 556 Pa. 475, 729 A.2d 547, 552 (1999)]. To determine whether an issue is sufficiently important to support application of the collateral order doctrine, “[a court should] weigh the interests implicated in the case against the costs of piecemeal litigation.” Id. “[I]t is not sufficient that the issue be important to the particular parties. Rather it must involve rights deeply rooted in public policy going beyond the particular litigation at hand.” Id., quoting Geniviva v. Frisk, 555 Pa. 589, 725 A.2d 1209, 1213-1214 (1999). “[A]n issue is important if the interests that would potentially go unprotected without immediate appellate review are significant relative to the efficiency interests sought to be advanced by adherence to the final judgment rule.” Finally, irreparable loss results from postponement if no effective means of review exist after the entry of final judgment. See Schwartz, 729 A.2d at 552.

A.A., supra at 1169.

In A.A., this Court held that an order denying a motion to seal a petition

to approve a settlement agreement constituted a collateral order. Specifically,

-4- J-A13040-22

we determined that the issue of sealing the petition to approve the settlement

agreement was entirely separable from the merits of the underlying medical

malpractice action. This Court explained that immediate appellate review was

even more important because the parties had already resolved their dispute.

Finally, the Court decided that the appellants’ claim would have been

irreparably lost if the appeal was denied since it was improbable that there

would be a future appealable order that would allow the appellants to raise

their claim. Id. at 1169-70.

Here, we similarly hold that the order denying Appellant’s request to

seal the complaint and Exhibit B constitutes a collateral order. The issue of

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

Related

R.W. v. Hampe
626 A.2d 1218 (Superior Court of Pennsylvania, 1993)
Geniviva v. Frisk
725 A.2d 1209 (Supreme Court of Pennsylvania, 1999)
Ben v. Schwartz
729 A.2d 547 (Supreme Court of Pennsylvania, 1999)
Erie Insurance Exchange v. Claypoole
673 A.2d 348 (Superior Court of Pennsylvania, 1996)
Melvin v. Doe
836 A.2d 42 (Supreme Court of Pennsylvania, 2003)
Katz v. Katz
514 A.2d 1374 (Supreme Court of Pennsylvania, 1986)
In re D.A.
801 A.2d 614 (Superior Court of Pennsylvania, 2002)
A.A. and A.M. v. Glicken, S.
2020 Pa. Super. 197 (Superior Court of Pennsylvania, 2020)

Cite This Page — Counsel Stack

Bluebook (online)
Maggitti, U. v. Maggitti, V., Counsel Stack Legal Research, https://law.counselstack.com/opinion/maggitti-u-v-maggitti-v-pasuperct-2022.