Nader v. Hughes

643 A.2d 747, 164 Pa. Commw. 434, 1994 Pa. Commw. LEXIS 271
CourtCommonwealth Court of Pennsylvania
DecidedJune 2, 1994
Docket1412 C.D. 1993
StatusPublished
Cited by10 cases

This text of 643 A.2d 747 (Nader v. Hughes) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nader v. Hughes, 643 A.2d 747, 164 Pa. Commw. 434, 1994 Pa. Commw. LEXIS 271 (Pa. Ct. App. 1994).

Opinion

*437 SILVESTRI, Senior Judge.

Frank Nader (Nader) appeals the order of the Court of Common Pleas of Crawford County (trial court) dismissing his action in mandamus against G. Arden Hughes, Coroner for Crawford County (Hughes). 1

In his complaint against Hughes, Nader alleged that he was the father of Mark Nader (Mark), who died on March 8, 1987 as a result of injuries sustained from a gunshot wound. Mark’s death was investigated by the Pennsylvania State Police on behalf of the District Attorney. Thereafter, Hughes ruled that Mark’s death was a suicide. Nader, not accepting Mark’s death to be a suicide, engaged the services of an attorney and a private investigator. Nader, after an investigation by the private investigator, asked Hughes that a coroner’s jury be impaneled for the purpose of determining the manner of Mark’s death, which request was denied. Nader alleges that he has suffered “incalculable stress and mental anguish ... over ... the refusal of ... the Coroner’s office to act responsibly” and that he, Nader, has an intense interest, “both religious ... and social, in clearing the stigma of suicide from the family and the deceased.” The relief sought by Nader in the mandamus action was for the trial court to enter judgment against Hughes, commanding him to impanel a coroner’s jury and conduct an inquest into the death of Mark.

Hughes filed an answer to Nader’s complaint denying the relevant factual averments contained therein and also filed a motion for summary judgment. The trial court dismissed Hughes’ motion for summary judgment and the matter was scheduled for trial in the April, 1992 term of civil jury trials. After several continuances, a pre-trial conference was held on *438 February 4, 1993 with trial set for February 11, 1993. On February 11, 1993, following jury selection but before the jury was sworn, a third pre-trial conference was held in the trial judge’s chambers. A transcript of the conference reveals the following:I 2

THE COURT:
At a second pretrial conference this morning I raised the issue of standing, admittedly late. I don’t remember it being raised before in this case by anybody.
[A]m (sic) inclined to think that maybe I should now decide that he has no standing or interest to bring this suit as a matter of law, so that if there is a [sic] appeal on that issue, that issue is resolved before we go through a lengthy and expensive and somewhat publicly charged trial. (Transcript, pp. 2-3).

After comments from both counsel, essentially requesting the opportunity to file briefs, the trial judge stated:

THE COURT: Here is what I am going to do. I am going to continue this case and probably going to give you a brief briefing period and make a ruling. My leaning now is he doesn’t, he is not a party aggrieved so as to be a private citizen entitled to bring a Mandamus action.
If somebody convinces me I am wrong, then we can always list this case on the next trial term two months from now.
I will go in and we will dismiss the jury as not being necessary (sic) this time because I am continuing the case to resolve a legal matter.
(Transcript, pp. 6-9.)

*439 The trial court then directed counsel for both parties to submit briefs on the standing issue by 4:30 p.m. on February 16, 1993. The trial judge returned to the courtroom and discharged the jury and continued the case generally. The parties filed their briefs as directed by the trial judge.

On March 31,1993, the trial court filed an opinion and order in which it determined that Nader lacked standing to maintain the action in mandamus, dismissed the action and entered judgment in favor of Hughes. In its opinion in support of the order, the trial court set forth the following facts: 3

Mark Nader died as a result of a gunshot wound on March 8, 1987. The death was investigated by the Pennsylvania State Police, particularly Trooper Scott Patterson. The defendant, as Coroner, did not visit the scene where the shooting occurred, nor did he interview the one eyewitness to the event. Patterson did those things.
The Coroner did order an autopsy by the Allegheny County Coroner’s Department and did seek certain ballistic opinions from the State Police Crime Lab in Harrisburg. The Coroner reviewed the criminal investigation performed by the Pennsylvania State Police (including eyewitness statements), met with John Dawson, the District Attorney, and talked with Trooper Patterson on a number of occasions ....
Frank Nader (plaintiff) ... disturbed with the Coroner’s conclusion, hired an attorney. Plaintiff ... hired private investigators.... Plaintiff, through his attorney and investigators, wrote to the Coroner and District Attorney. Plain *440 tiff then met with them in an effort to encourage the Coroner to change his conclusion and conduct an inquest. Plaintiff disagrees with the Coroner’s conclusion and filed his complaint on September 4, 1990____
The injury to the Plaintiff that he believes was caused by the Coroner’s action is set forth in paragraph 20 of the complaint as follows:
The Plaintiff, Frank Nader, is the father of the deceased, and has suffered incalculable stress and mental anguish over the death of his son and over what he believes to be the refusal of the District Attorney and the Coroner’s office to act responsibly upon the evidence in the matter of Mark Nader’s death. Further, the Plaintiff has an intense interest, both religious (both the Plaintiff and the deceased are Roman Catholics) and social, in clearing the stigma of suicide from the family and the deceased.
(Original record, Item 36, trial court opinion, pp. 2-4).

Nader argues that the trial court erred by raising the issue of standing sua sponte after the jury was “empaneled” 4 and that the trial court improperly determined that Nader did not have standing to bring a mandamus action compelling the coroner to perform an inquest into the death of Nader’s deceased child.

We will first address the issue of whether the trial court’s raising the issue of standing at the pre-trial conference following the selection of the jury on February 11, 1993 constituted a sua sponte disposition of the issue of standing. It is clear that, although the trial court raised the issue of Nader’s standing at the February 11, 1993 pre-trial conference, it did not, at that time, decide the issue, but did so only after giving the parties notice and an opportunity to present briefs relative thereto, which the parties submitted.

In Vogel v. Berkley, 354 Pa. Superior Ct. 291, 295,

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Bluebook (online)
643 A.2d 747, 164 Pa. Commw. 434, 1994 Pa. Commw. LEXIS 271, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nader-v-hughes-pacommwct-1994.