Municipal Authority v. Chicago Bridge & Iron Co.

54 Pa. D. & C.2d 691, 1971 Pa. Dist. & Cnty. Dec. LEXIS 115
CourtPennsylvania Court of Common Pleas, Mifflin County
DecidedNovember 24, 1971
Docketno. 37
StatusPublished

This text of 54 Pa. D. & C.2d 691 (Municipal Authority v. Chicago Bridge & Iron Co.) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Mifflin County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Municipal Authority v. Chicago Bridge & Iron Co., 54 Pa. D. & C.2d 691, 1971 Pa. Dist. & Cnty. Dec. LEXIS 115 (Pa. Super. Ct. 1971).

Opinion

LEHMAN, P. J.,

On March 9, 1971, after argument and consideration of briefs, we opened the confessed judgment entered in favor of plaintiff and against defendants on an affidavit of default in the amount of $8,130 on a maintenance bond filed by defendants and decreed that plaintiff’s affidavit of default shall be considered as plaintiff’s complaint and defendants’ petition to open judgment shall be considered as defendants’ answer.

On May 5, 1971, counsel for the Chicago Bridge & Iron Company and Insurance Company of North America, defendants, filed a praecipe for a writ to join Lewis L. Gwin, Gwin Engineers, Inc., Gwin, Dobson & Foreman (hereafter referred to as Gwin Engineers), and Rust-Oleum Corporation (hereinafter referred to as Rust-Oleum) as additional defendants. Said writ was served on said defendants from May 10 to May 17, 1971, inclusive. On May 18, 1971, said counsel, on behalf of the Chicago Bridge & Iron Company, filed its complaint to join said additional defendants, alleging that Gwin Engineers and Rust-Oleum are alone liable to plaintiff, either jointly or severally, or are liable, either jointly or severally, over to the original defendant, the Chicago Bridge & Iron Company, on the ground the Chicago Bridge & Iron Company constructed the water tanks and painted same in accordance with the terms, conditions and detailed technical provisions prepared by plaintiff’s consulting engineer, Gwin Engineers, and if the stability of all materials, equipment and work was not maintained, as averred in plaintiff’s affidavit of default, such failure was not attributable to the Chicago Bridge & Iron Company but to said additional defendants, by reason of the fact that the paint sold to the Chicago Bridge & Iron Company and used by it on said project was the paint specified by Gwin Engineers and was [693]*693defective and did not conform to the merchantable condition impliedly represented by Rust-Oleum, a manufacturer and seller of paint. It is further alleged that Rust-Oleum, prior to sale and delivery, knew the purpose for which the paint was to be used and knew or should have known that the paint was inadequate for the purpose intended.

Both additional defendants filed preliminary objections in the form of motions to strike off the complaint on the ground that joinder was not made within the 60 days from service upon the original defendant of the initial pleadings as provided by Pennsylvania Rule of Civil Procedure 2253 and there is no law or rule of court permitting the joinder of additional defendants in proceedings of this type. Counsel for Gwin Engineers also alleges that since the original defendants averred that Lewis L. Gwin prepared the specifications, there aré no averments of record alleging any basis for liability on the part of Gwin Engineers, Inc., or Gwin, Dobson & Foreman, Inc. The preliminary objections filed by Rust-Oleum are also in the form of a motion for a more specific pleading in that there is no allegation of the manner in which the paint was defective and in what manner it failed to conform to a merchantable condition impliedly represented by Rust-Oleum. It is these preliminary objections that are now before us for disposition.

Pennsylvania Rule of Civil Procedure 2960 provides as follows:

“If a judgment is opened in whole or in part the issues to be tried shall be defined by the complaint if a complaint has been filed, and by the petition, answer and the order of the court opening the judgment. There shall be no further pleadings.”

In accordance with this rule, our decree of March [694]*6949, 1971, opening the judgment, provided that the affidavit of default shall be considered as plaintiff’s complaint and defendants’ petition to open judgment shall be considered as defendants’ answer. Prior to that decree, there was no pleading that could be classified as a complaint or initial pleading of plaintiff. The only instruments filed by plaintiff were an affidavit of default under a maintenance bond filed by the Chicago Bridge & Iron Company and Insurance Company of North America and praecipe for judgment alleging expenditures in excess of $13,944.15 to correct alleged poor workmanship in the interior painting of three water tanks. Neither of these could be termed an initial pleading by plaintiff as contemplated by Pa. R. C. P. 2253. In fact, there was no factual issue for disposition until our decree of March 9, 1971, which opened the judgment and permitted defendants to make a defense. Consequently, there was no initial pleading by plaintiff as contemplated by said rule until our decree declared that the affidavit of default was to be considered as plaintiff’s complaint. The opening of a judgment leaves the parties as if no judgment had been entered and proceedings thereafter are de novo: Dunn v. Orloff, 420 Pa. 492, 503, 218 A.2d 314, 320.

The Chicago Bridge & Iron Company could not have joined additional defendants until a factual issue had been framed by our decree of March 9, 1971 and said company filed its praecipe to join the additional defendants on May 5, 1971, a date within the 60-day period provided by said rule.

The additional defendants further contend that Pa. R. C. P. 2960 restricts the pleadings to a complaint, if filed, petition, answer and order of the court opening the judgment. But this rule does not relate to additional defendants.

[695]*695The recently amended Pa. R. C. P. 2252(a) authorizes defendant, or any additional defendant, to “join as an additional defendant any person . . . who may be alone liable or liable over to him on the cause of action declared upon by the plaintiff or jointly or severally liable thereon with him, or who may be liable to the joining party on any cause of action which he may have against the joined party arising out of the transaction or occurrence or series of transactions or occurrences upon which the plaintiff’s cause of action is based.” Accordingly, we hold that Pa. R. C. P. 2960 does not preclude defendants from joining Gwin Engineers and Rust-Oleum as additional defendants, and inasmuch as the allegations against said additional defendants relate to the same transaction upon which plaintiff is seeking to recover, the requirements of Pa. R. C. P. 2252(a) have been met.

It is manifestly clear that the 1969 amendment to Pa. R. C. P. 2252(a), a portion of which we have quoted, was intended to enlarge the scope of the “additional defendant” practice in Pennsylvania courts and to approach the general policy of settling all rights of all the parties in all the claims arising from the event upon which plaintiff has sued: Goodrich-Amram, §2252, Commentary, 1971 Supp. to Binders 3 and 4, p. 209. Were we to adopt the argument of the additional defendants that Pa. R. C. P. 2960 prevents defendant from joining additional defendants because no further pleadings are permitted, the very purpose of the 1969 amendments to Pa. R. C. P. 2252(a) would be defeated. Pa. R. C. P. 2960 relates solely to pleadings when no additional defendants are joined. It was not intended to preclude the disposition of all rights of all the parties in the event or transaction before the court.

Pa. R. C. P. 1017(a) deals with actions of assumpsit [696]

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

Related

Dunn v. Orloff
218 A.2d 314 (Supreme Court of Pennsylvania, 1966)
Snoparsky v. BAER
266 A.2d 707 (Supreme Court of Pennsylvania, 1970)

Cite This Page — Counsel Stack

Bluebook (online)
54 Pa. D. & C.2d 691, 1971 Pa. Dist. & Cnty. Dec. LEXIS 115, Counsel Stack Legal Research, https://law.counselstack.com/opinion/municipal-authority-v-chicago-bridge-iron-co-pactcomplmiffli-1971.