Olugbade-Oseyemi, C. v. Philip, M.

CourtSuperior Court of Pennsylvania
DecidedJuly 28, 2025
Docket1629 EDA 2024
StatusUnpublished

This text of Olugbade-Oseyemi, C. v. Philip, M. (Olugbade-Oseyemi, C. v. Philip, M.) 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
Olugbade-Oseyemi, C. v. Philip, M., (Pa. Ct. App. 2025).

Opinion

J-A08020-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

CECELIA OLUGBADE-OSEYEMI : IN THE SUPERIOR COURT OF : PENNSYLVANIA Appellant : : : v. : : : MIRIAM PHILIP : No. 1629 EDA 2024

Appeal from the Order Entered May 2, 2024 In the Court of Common Pleas of Montgomery County Civil Division at No(s): 2022-25228

BEFORE: LAZARUS, P.J., McLAUGHLIN, J., and SULLIVAN, J.

MEMORANDUM BY McLAUGHLIN, J.: FILED JULY 28, 2025

Cecelia Olugbade-Oseyemi appeals from the order dismissing her

complaint after she failed to appear for trial. Because the court’s Rule 1925(a)

opinion indicates it intended to enter judgment of non pros based on

Olugbade-Oseyemi’s failure to appear, we vacate and remand.

Olugbade-Oseyemi filed a complaint against Miriam Philip, seeking $500

for the alleged conversion of her daughter’s bicycle. She thereafter filed a

praecipe to send the case to arbitration, which contained an affirmation that

the parties agreed that all discovery was complete.

After arbitration, Olugbade-Oseyemi filed an appeal from the award of

arbitrators, requesting a jury trial. She also filed a motion to compel Philip to

respond to her request to produce documents. The court entered a discovery

order. J-A08020-25

The trial court scheduled a de novo bench trial. The scheduling order

stated that the previous order concerning outstanding discovery was “moot,”

because the parties had previously agreed that discovery was complete. Trial

was twice continued and ultimately scheduled for 9:00 a.m. on May 2, 2024.

Four days before trial, Olugbade-Oseyemi requested trial be continued

due to outstanding discovery and alleged spinal stenosis pain. The court

denied the request for a continuance on the basis that (1) the parties’

arbitration praecipe affirmed that discovery was complete; (2) the court would

accommodate Olugbade-Oseyemi’s medical issue by providing comfortable

seating and periodic trial breaks; and (3) the matter had already been

continued twice. See Order, 4/30/24.

According to the docket, on 9:19 a.m. on the morning of trial, Olugbade-

Oseyemi filed with the Clerk of Courts a motion to compel a response to her

interrogatories and request for production of documents. See Motion, 5/2/14,

at 1 (prothonotary timestamp). The court entered an order at 9:50 a.m.,

stating the following,

AND NOW, this 2nd day of May, 2024, this matter having been called for Trial this date and, for reasons set forth on the record this date, this complaint is hereby DISMISSED.

Order, 5/2/24, at 1 (prothonotary timestamp).

That same day, Olugbade-Oseyemi filed a notice of appeal. She raises

one issue:

Whether the Montgomery [County] Court of Common Pleas committed errors of law, violated [Olugbade-Oseyemi’s] constitutional rights, Pa[.] Code of judicial conduct, and abused

-2- J-A08020-25

its power and discretion when it unduly and capriciously dismissed [Olugbade-Oseyemi’s] case even though [Olugbade-Oseyemi] reported at [the] courtroom with 10/10 spinal stenosis pain and informed [the] court staff that [she] was in serious pain, needed to go to the bathroom to eas[e] herself and to drop a document off at the [prothonotary] downstairs before the judge comes in.

Olugbade-Oseyemi’s Br. at 4.

Olugbade-Oseyemi argues the court abused its discretion in dismissing

her complaint. She contends she arrived on time for trial, but the trial judge

had not yet taken the bench. Olugbade-Oseyemi asserts she told the

courtroom staff that she needed to use the bathroom and to drop off a

document at the prothonotary’s office. By the time she returned to the

courtroom, the court had dismissed her case. She argues that her continuance

request alerted the court that she was experiencing “spinal stenosis

exacerbation symptoms, that included radiating and shooting 10/10 pain” at

the time. Id. at 13. She further asserts she filed the discovery motion on the

morning of trial because she had only filed the praecipe for arbitration

(affirming that discovery was complete) after court staff told her that

arbitration was mandatory due to the amount of money at issue, and even

though she informed them that discovery was incomplete.

In its Rule 1925(a) opinion, the trial court states that it entered a

judgment of non pros pursuant to Rule 218(a) due to Olugbade-Oseyemi’s

failure to appear at trial. See Trial Court Opinion, 6/18/24, at 6. The court

contends that because Olugbade-Oseyemi failed to file a motion to open the

-3- J-A08020-25

non pros, we should find she waived all issues for appeal. See Trial Ct. Op. at

5-6.1

Rule 218(a) provides, “Where a case is called for trial, if without

satisfactory excuse a plaintiff is not ready, the court may enter a nonsuit on

motion of the defendant or non pros on the court’s own motion.” Pa.R.Civ.P.

218(a) (italics added). The Rule allows the court to determine the plaintiff has

no satisfactory excuse at the time they fail to appear. See id. at 218(c) (“A

party who fails to appear for trial shall be deemed to be not ready without

satisfactory excuse”); see also id. at Explanatory Comment--1993.2

A party seeking relief from a judgment of non pros entered under Rule

218 must file a petition to open the judgment. See Pa.R.Civ.P. 3051(a); see

also See Pa.R.Civ.P. 218 (Explanatory Comment--1993) (“If the court enters

a nonsuit or a judgment of non pros or dismisses an appeal and there exists

a sufficient excuse, the aggrieved party may present the excuse through a

____________________________________________

1 The court alternatively advances that Olugbade-Oseyemi waived her issues

by failing to request the transcript of trial pursuant to Pa.R.Civ.P. 1911. The court also substantively defends its dismissal of the case under Pa.R.Civ.P. 218(a) and (c), asserting that, according to its handwritten notes, Olugbade- Oseyemi first arrived at 9:10 and then left, was not present in the courtroom when the court took the bench at 9:23 a.m., and returned to the courtroom at 9:30, after her case had been dismissed. The court claims these circumstances would have been substantiated by a transcript of the proceedings.

2 “While we recognize that explanatory notes are nonbinding, this Court has

found the explanatory notes and comments accompanying rules of civil procedure to be both persuasive and instructive.” In re C.A.J., 319 A.3d 564, 574 n.3 (Pa.Super. 2024) (internal quotation marks and citation omitted).

-4- J-A08020-25

motion to remove the nonsuit or a petition to open the judgment or reinstate

the appeal”) (italics added).3 On a petition to open, the trial court must

determine whether “(1) the petition is timely filed, (2) there is a reasonable

explanation or legitimate excuse for the conduct that gave rise to the entry of

judgment of non pros, and (3) there is a meritorious cause of action.”

Pa.R.Civ.P. 3051(b) (italics added); Banks v. Cooper, 171 A.3d 798, 801

(Pa.Super. 2017). In the context of a failure to appear, the court must also

consider:

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Bluebook (online)
Olugbade-Oseyemi, C. v. Philip, M., Counsel Stack Legal Research, https://law.counselstack.com/opinion/olugbade-oseyemi-c-v-philip-m-pasuperct-2025.