McAnany v. Case

83 Pa. D. & C.4th 449
CourtPennsylvania Court of Common Pleas, Lawrence County
DecidedMarch 9, 2007
Docketno. 10393 of 2006, C.A.
StatusPublished

This text of 83 Pa. D. & C.4th 449 (McAnany v. Case) 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
McAnany v. Case, 83 Pa. D. & C.4th 449 (Pa. Super. Ct. 2007).

Opinion

MOTTO, P.J.,

Before the court for disposition is defendant’s motion for summary judg[450]*450ment. Defendant, Youngblood Paving Inc., contends:

(1) Defendant was not a seller or engaged in the business of selling paving equipment as is required to be a proper defendant in a products liability claim.

(2) Defendant did not owe plaintiff a duty; therefore, plaintiff cannot assert a negligence claim against defendant.

(3) Defendant did not breach any express warranty because no one associated with defendant made any representations about the trade-in loader, except Southeastern was taking it “as is.”

(4) Defendant cannot be liable under sections 2-314 and 2-315 of the Uniform Commercial Code because it is not a merchant as defined in section 2-104 or a seller.

On October 11,1999, defendant traded a Case Model 1845C skid steer loader in to Southeastern Equipment Co. Inc., for a new skid steer loader.'Shortly after the trade-in, plaintiff’s employer, Cade Paving, purchased the loader off-of Southeastern. Plaintiff’s employer bought the loader “as is.” Cade Paving did not speak to any employee or representative of the defendant before buying the loader, and Rusty Cade, owner of Cade Paving, stated that he bought the loader because it was in good shape.

Plaintiff was the primary operator of the loader, and considered himself an experienced operator of the loader. On the day of the accident, plaintiff was removing excess gravel and debris from a driveway and placing it on a slope. The gravel was packed in a manner that [451]*451enabled him to drive on it to get further into the pile. On his last load, he emptied the loader’s bucket and an imbalance in the weight of the loader caused it to begin sliding down the gravel pile. On his way down the slope, plaintiff was jostled around by the rough terrain, which forced his foot to extend out of the front of the machine. While trying to pull his foot back into the driver’s compartment, plaintiff may have pulled the handle, which caused the bucket to crash down, pinning his leg in between the crossbar on the arm of the machine and the frame of the machine. Plaintiff suffered severe injuries to his leg as a result of this accident.

In reviewing a motion for summary judgment this court must look at the record in a light most favorable to the opposing party, and all doubts should be resolved in favor of the nonmoving party. P.J.S. v. Pennsylvania State Ethics Commission, 555 Pa. 149, 152, 723 A.2d 174, 176 (1999). The motion should only be granted in cases where the record shows that there are no genuine issues of material fact and the moving party is entitled to judgment as a matter of law. Id. “In sum, only when the facts are so clear that reasonable minds cannot differ, may a trial court properly enter summary judgment.” Chepkevich v. Hidden Valley Resort L.P., 911 A.2d 946, 950 (Pa. Super. 2006).

In Webb v. Zern, 422 Pa. 424, 220 A.2d 853 (1966), the Pennsylvania Supreme Court adopted the theory of strict products liability. The court cited to the modern theoiy of products liability as declared in the Restatement (Second) of Torts §402A, which states:

“(1) One who sells any product in a defective condition unreasonably dangerous to the user or consumer or to [452]*452his property is subject to liability for physical harm thereby caused to the ultimate user or consumer, or to his property, if (a) the seller is engaged in the business of selling such a product, and (b) it is expected to and does reach the user or consumer without substantial change in the condition in which it is sold.” Id. at 427, 220 A.2d at 854 (citing Restatement (Second) of Torts §402A (1965)).

There are situations where a seller of used goods can be held liable for selling defective merchandise. Frey v. Harley Davidson Motor Company Inc., 734 A.2d 1 (Pa. Super. 1999). In Frey, the seller sold new and used motorcycles produced by the same manufacturer, and they maintained a close business relationship, making the seller strictly liable. The Pennsylvania courts have acknowledged that public policy demands that liability be fixed where it will be most effective at reducing the peril to life and health which arise from the selling of defective products. Francioni v. Gibsonia Truck Corp., 472 Pa. 362, 366, 372 A.2d 736, 738 (1977). “[T]he special responsibility for the safety of the public undertaken by one who enters into the business of supplying human beings with products which may endanger the safety of their persons and property.” Id. at 369, 372 A.2d at 739.

The policy behind strict liability is to ensure costs of injuries sustained from purchasing defective products are paid by the manufacturers who put the products on the market and not by the injured persons themselves. Cafazzo v. Central Medical Health Services Inc., 542 Pa. 526, 531, 668 A.2d 521, 524 (1995) (citing Shepard v. Alexian Brothers Hospital, 33 Cal. App. 3d 606, 610, [453]*453109 Cal. Rptr. 132, 132 (1973)). Strict liability is imposed in situations where this concern can be served. Id. at 531, 668 A.2d at 523-24 (citing Musser v. Vilsmeier Auction Co. Inc., 522 Pa. 367, 372, 562 A.2d 279, 281 (1989)). In Cafazzo, the court stated, “when one enters the hospital as a patient, he goes there, not to buy medicines or pills, not to purchase bandages or iodine or serum or blood, but to obtain a course of treatment in the hope of being cured of what ails him.” Id. at 534, 668 A.2d at 525. The Cafazzo court held that providing medical treatment is a service and it is distinguishable from merchandising.1 Id.

In the case sub judice, defendant merely traded in the used loader to purchase a new one. Although defendant has done this a number of times in the past, selling skid steer loaders or any other equipment remains outside of defendant’s business. Unlike the situation in Frey, where the seller normally sold products fashioned by the same manufacturer, defendant clearly does not deal in selling items created by one manufacturer. Although defendant has made 12 transactions either selling or trading in equipment, it does not sell equipment on a normal basis; it is in the business of paving.

Similarly, in Cafazzo, the instruments used in surgery are necessary to performing the service rendered; like[454]*454wise, the loader in this case is necessary to render the service of paving. It is apparent that defendant merely trades in its equipment to get new equipment in order to render a service, not as an act of selling or distributing them as a business venture.

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Related

Cafazzo v. Central Medical Health Services, Inc.
668 A.2d 521 (Supreme Court of Pennsylvania, 1995)
Francioni v. Gibsonia Truck Corp.
372 A.2d 736 (Supreme Court of Pennsylvania, 1977)
Frey v. Harley Davidson Motor Co., Inc.
734 A.2d 1 (Superior Court of Pennsylvania, 1999)
Berkebile v. Brantly Helicopter Corp.
337 A.2d 893 (Supreme Court of Pennsylvania, 1975)
Gavula v. ARA Services, Inc.
756 A.2d 17 (Superior Court of Pennsylvania, 2000)
Phillips v. Cricket Lighters
841 A.2d 1000 (Supreme Court of Pennsylvania, 2003)
Musser v. Vilsmeier Auction Co., Inc.
562 A.2d 279 (Supreme Court of Pennsylvania, 1989)
P.J.S. v. Pennsylvania State Ethics Commission
723 A.2d 174 (Supreme Court of Pennsylvania, 1999)
R.W. v. Manzek
888 A.2d 740 (Supreme Court of Pennsylvania, 2005)
Shepard v. Alexian Brothers Hospital, Inc.
33 Cal. App. 3d 606 (California Court of Appeal, 1973)
Webb v. Zern
220 A.2d 853 (Supreme Court of Pennsylvania, 1966)
Chepkevich v. Hidden Valley Resort, L.P.
911 A.2d 946 (Superior Court of Pennsylvania, 2006)
Porreca v. Atlantic Refining Co.
168 A.2d 564 (Supreme Court of Pennsylvania, 1961)
Morena v. South Hills Health System
462 A.2d 680 (Supreme Court of Pennsylvania, 1983)
Dumanski v. City of Erie
34 A.2d 508 (Supreme Court of Pennsylvania, 1943)
Boyce v. United States Steel Corp.
285 A.2d 459 (Supreme Court of Pennsylvania, 1971)

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Bluebook (online)
83 Pa. D. & C.4th 449, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcanany-v-case-pactcompllawren-2007.