Mariano, W. v. Rhodes, A.

2022 Pa. Super. 15, 270 A.3d 521
CourtSuperior Court of Pennsylvania
DecidedJanuary 26, 2022
Docket2335 EDA 2020
StatusPublished
Cited by9 cases

This text of 2022 Pa. Super. 15 (Mariano, W. v. Rhodes, A.) 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.

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Mariano, W. v. Rhodes, A., 2022 Pa. Super. 15, 270 A.3d 521 (Pa. Ct. App. 2022).

Opinion

J-S29018-21

2022 PA Super 15

WILLIAM FRANK MARIANO III : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : ALYSSA ANN RHODES : : Appellant : No. 2335 EDA 2020

Appeal from the Order Entered October 26, 2020, in the Court of Common Pleas of Delaware County, Civil Division at No(s): No. 2020-004278.

BEFORE: PANELLA, P.J., KUNSELMAN, J., and STEVENS, P.J.E.*

OPINION BY KUNSELMAN, J.: FILED JANUARY 26, 2022

In this matter, we consider whether the prothonotary’s rejection of a

spouse’s imperfect pleadings constitute “a fatal defect apparent upon the face

of the record,” thereby obligating a court to vacate a divorce decree under 23

Pa.C.S.A. § 3332. Appellee, William Frank Mariano III (Husband), obtained

what amounted to an uncontested divorce decree, after the responsive

pleadings filed by Appellant, Alyssa Ann Rhodes (Wife), were rejected by the

prothonotary’s office. Although Wife’s counsel timely-submitted these

pleadings, counsel neglected to enter his appearance and pay the

corresponding filing fee. The prothonotary’s office then crossed out the

timestamp on the pleadings, and informed counsel of his mistake. Counsel

entered his appearance and paid the fee, but not until after the deadline

____________________________________________ * Former Justice specially assigned to the Superior Court. J-S29018-21

passed. The trial court deemed these pleadings untimely and issued the

divorce decree. Wife filed a motion to vacate, arguing the prothonotary’s

rejection constituted a fatal defect. The trial court denied Wife’s request, and

she appealed. After careful review, we agree the prothonotary’s office lacked

the authority to reject Wife’s pleadings, and thus we vacate the divorce decree

and remand for further proceedings.

The factual and procedural history is not in dispute. The parties married

in August 2016 and separated in 2018. Two years after they separated, on

July 6, 2020, Husband filed a complaint in divorce pursuant to 23 Pa.C.S.A. §

3301(d) (“Irretrievable breakdown”). By August 11, 2020, Husband had

initiated the necessary steps to obtain a decree. He served Wife with the

complaint, the requisite affidavit and blank counter-affidavit, as well as his

notice of intention to file the praecipe to transmit record.

Under the Pennsylvania Rules of Civil Procedure, once Wife was served

with these documents, she had 20 days – i.e., until August 31 – to reply.

Otherwise, Husband could file a praecipe to transmit the record and obtain a

divorce decree, at which point Wife would forfeit any economic claims related

to their marriage.1 Wife replied. She completed the counter-affidavit, as well

as an answer and counterclaim, wherein she disputed Husband’s averments

and requested equitable distribution.2 Counsel for Wife sent these pleadings

to be filed with the Delaware County Office of Judicial Support (colloquially, ____________________________________________ 1 See Pa.R.C.P. 1920.42(c). 2See Pa.R.C.P. 1920.72; see also Pa.R.C.P. 1920.14; and see Pa.R.C.P. 1920.15.

-2- J-S29018-21

the prothonotary’s office). The prothonotary’s office timestamped the

pleadings on August 28, 2020 – within the 20-day deadline.

However, the prothonotary’s office then informed counsel that he

“needed to pay a fifty-dollar entry of appearance fee.” See Wife’s Brief at 3.

On September 1, 2020 – one day after the 20-day deadline – Wife’s counsel

went to the prothonotary’s office in person, filed an entry of appearance and

paid the filing fee. At this point, counsel was under the impression that the

defect had been cured.

In the meantime, on August 31, Husband had filed the praecipe to

transmit record. On September 29, 2020, the trial court issued the divorce

decree, and Wife’s economic claims were forfeited. Only then did Wife’s

counsel realize that Wife’s responsive pleadings were never officially docketed

or otherwise reinstated. Although the responsive pleadings had been

timestamped before the deadline, their timestamps were crossed out.

October 6, 2020, Wife filed a motion to vacate the divorce decree. The court

denied Wife’s motion on October 26, 2020, and she timely filed this appeal.

Wife presents one issue for our review:

Did the trial court abuse its discretion by failing to grant [Wife’s] motion to vacate the decree in divorce, seven days after its entry, due to a clerical docketing mistake?

Wife’s Brief at 2 (superfluous capitalization omitted).

We begin with our well-settled standard of review. “A trial court’s

exercise or refusal to exercise its authority to open, vacate, or strike a divorce

-3- J-S29018-21

decree is reviewable on appeal for an abuse of discretion.” Bardine v.

Bardine, 194 A.3d 150, 152 (Pa. Super. 2018) (citation omitted). “An abuse

of discretion is not merely an error of judgment but is found where the law is

overridden or misapplied, or the judgment exercised is manifestly

unreasonable, or the result of partiality, prejudice, bias or ill will as shown by

the evidence or the record.” Fischer v. UPMC Northwest, 34 A.3d 115, 120

(Pa. Super. 2011).

Wife’s challenge involves the application of 23 Pa.C.S.A. § 3332, which

governs a trial court’s authority to open or vacate a divorce decree. The intent

of Section 3332 is “to codify the extraordinary circumstances which will

outweigh the interests of the parties and the court in finality, and to delimit

the time periods which within such circumstances must be established.”

Bardine, 194 A.3d at 153 (citing Anderson v. Anderson, 544 A.2d 501, 505

(Pa. Super. 1988)). Importantly, the concern is no longer about economic

fairness. “[A] general plea to economic justice will not satisfy the stringent

standard set forth [in Section 3332].” Melton v. Melton, 831 A.2d 646, 651

(Pa. Super. 2003) (citing Justice v. Justice, 612 A.2d 1354, 1357 (Pa. Super.

1992)). This “stringent standard” involves clear evidentiary requirements and

time constraints on a court’s authority to open or vacate a divorce decree:

§ 3332. Opening or vacating decrees

A motion to open a decree of divorce or annulment may be made only within the period limited by 42 Pa.C.S.A. § 5505 (relating to modification of orders) and not thereafter. The motion may lie where it is alleged that the decree was procured by intrinsic fraud or that there is new evidence

-4- J-S29018-21

relating to the cause of action which will sustain the attack upon its validity. A motion to vacate a decree or strike a judgment alleged to be void because of extrinsic fraud, lack of jurisdiction over the subject matter or a fatal defect apparent upon the face of the record must be made within five years after entry of the final decree. Intrinsic fraud relates to a matter adjudicated by the judgment, including perjury and false testimony, whereas extrinsic fraud relates to matters collateral to the judgment which have the consequence of precluding a fair hearing or presentation of one side of the case.

23 Pa.C.S.A. § 3332.

We observe Wife sought to vacate the decree, not open it.

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Mariano, W. v. Rhodes, A.
2022 Pa. Super. 15 (Superior Court of Pennsylvania, 2022)

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2022 Pa. Super. 15, 270 A.3d 521, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mariano-w-v-rhodes-a-pasuperct-2022.