RCKA Investments LLC v. Johnson, C.

2022 Pa. Super. 139, 281 A.3d 328
CourtSuperior Court of Pennsylvania
DecidedAugust 11, 2022
Docket1051 EDA 2021
StatusPublished
Cited by2 cases

This text of 2022 Pa. Super. 139 (RCKA Investments LLC v. Johnson, C.) 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
RCKA Investments LLC v. Johnson, C., 2022 Pa. Super. 139, 281 A.3d 328 (Pa. Ct. App. 2022).

Opinion

J-A07036-22

2022 PA Super 139

RCKA INVESTMENTS LLC : IN THE SUPERIOR COURT OF : PENNSYLVANIA Appellee : : v. : : CHARLES JOHNSON : : Appellant : No. 1051 EDA 2021

Appeal from the Order Entered May 12, 2021 In the Court of Common Pleas of Philadelphia County Civil Division at No(s): Feb. Term, 2021 No. 00244

BEFORE: DUBOW, J., McLAUGHLIN, J., and KING, J.

OPINION BY KING, J.: FILED AUGUST 11, 2022

Appellant, Charles Johnson, appeals from the order entered in the

Philadelphia County Court of Common Pleas which granted the motion of

Appellee, RCKA Investments LLC, to dismiss Appellant’s de novo appeal. We

vacate and remand for further proceedings.

The relevant facts and procedural history of this case are as follows.

Appellant entered into a residential lease agreement with Appellee to rent

Appellee’s property in Philadelphia. On March 5, 2020, Appellee initiated an

eviction action against Appellant in Philadelphia Municipal Court, seeking

possession of the property and a money judgment for failure to make timely

rental payments. On January 22, 2021, the Municipal Court entered judgment

in favor of Appellee, awarding possession of the property and a money

judgment of $24,286.75. On February 1, 2021, Appellant filed a notice of

appeal to the Philadelphia County Court of Common Pleas, seeking a trial de J-A07036-22

novo. On the same day, the trial court issued a case management order which

stated in relevant part:

FOR TENANTS ─ SUPERSEDEAS: If you are a tenant and you filed the appeal, you must pay money into an escrow account to remain in the property until your appeal is decided. This is called a supersedeas. The supersedeas will suspend the Municipal Court judgment and will prevent your eviction until your case is heard by a judge and a final decision is made on the appeal. IF YOU FAIL TO PAY YOUR MONTHLY RENT INTO ESCROW IN FULL AND ON TIME, YOU COULD BE EVICTED BEFORE YOUR APPEAL IS HEARD.

(Case Management Order, filed February 1, 2021, at 1) (emphasis in original).

Appellant did not deposit funds into an escrow account to seek

supersedeas. On April 15, 2021, Appellee filed a motion to dismiss on the

grounds that Appellant failed to comply with the case management order

because Appellant did not deposit funds into an escrow account. Appellee had

not attempted to execute the judgment for possession prior to filing the

motion to dismiss. On May 12, 2021, the court granted Appellee’s motion and

dismissed Appellant’s appeal with prejudice. Appellant filed a timely notice of

appeal on May 21, 2021. On May 27, 2021, the court ordered Appellant to

file a Pa.R.A.P. 1925(b) concise statement of errors, and Appellant timely

complied on June 16, 2021.

Appellant raises the following issue for our review:

Whether the [trial court] may dismiss a tenant’s de novo appeal of Philadelphia Municipal Court judgments for money and possession solely because the tenant did not seek supersedeas against eviction (i.e., did not deposit escrow payment or bond with the Office of Judicial Records or apply for a reduced payment)?

-2- J-A07036-22

(Appellant’s Brief at 2).

On appeal, Appellant asserts that he exercised his right not to seek

supersedeas against eviction when he appealed to the trial court for a trial de

novo. Appellant claims that neither the case management order nor the

Philadelphia local court rules condition a tenant’s right to pursue an appeal on

depositing money into an escrow account and obtaining a supersedeas.

Appellant argues that the only consequence of failing to deposit money into

an escrow account is the risk of being evicted while the appeal is pending.

Appellant concludes the court erroneously dismissed his appeal, and this Court

should vacate the court’s order and remand for further proceedings in

accordance with the Pennsylvania Rules of Civil Procedure. We agree.

The relevant standard and scope of review are as follows:

[T]he application, construction and interpretation of a local rule of court are matters primarily to be determined by the court promulgating the local rule and we will interfere only where the court commits an abuse of discretion. Moreover, an abuse of discretion is not merely an error in judgment; rather it occurs when the law is overridden or misapplied, or when the judgment exercised is manifestly unreasonable or the result of partiality, prejudice, bias, or ill will.

Rolla v. Westmoreland Health Sys., 651 A.2d 160, 163 (Pa.Super. 1994).

Rule 1001 of the Philadelphia County local rules establishes that final

orders issued by the Municipal Court in connection with money judgments and

landlord-tenant orders are appealable to the Court of Common Pleas. See

Phila.Civ.R. 1001(a)(1). Once a notice of appeal is filed, “[t]he proceedings

-3- J-A07036-22

on appeal shall be conducted de novo in accordance with the Rules of Civil

Procedure that would be applicable if the action being appealed was initially

commenced in the Court of Common Pleas.” Id. Additionally, if the appeal is

from a judgment for possession of property subject to a residential lease:

[R]eceipt by the Municipal Court of a copy of the Notice of Appeal shall operate as a supersedeas only if the appellant/tenant, at the time of the filing of the Notice of Appeal, deposits with the Office of Judicial Records a sum of money (or a bond, with surety approved by the Office of Judicial Records) equal to the lesser of three months’ rent or the rent actually in arrears on the date of the filing of the Notice of Appeal, based on the Municipal Court judgment, and thereafter deposits each month with the Office of Judicial Records an amount equal to the monthly rent which becomes due while the appeal is pending in the Court of Common Pleas.

Phila.Civ.R. 1008(c).

“Local courts have the power to formulate their own rules of practice

and procedure. These rules have equal weight to those rules established by

the Pennsylvania Supreme Court provided that the local rules do not abridge,

enlarge or modify the substantive rights of a party.” Anthony Biddle

Contractors, Inc. v. Preet Allied Am. St., LP, 28 A.3d 916, 922 (Pa.Super.

2011) (internal quotation and citations omitted). Case management orders

issued by the trial court are court orders setting forth the deadlines and

procedural guidelines governing a case pursuant to the local court rules. See

id. A court may issue sanctions for failure to adhere to the directives of a

case management order in accordance with the Pennsylvania Rules of Civil

Procedure. Id.

-4- J-A07036-22

Instantly, the court dismissed Appellant’s de novo appeal, reasoning:

Appellant failed to comply with the court’s clear, explicit and unambiguous case management order. The case management order lists several options to assist Appellant in paying rent money into an escrow account with the Office of Judicial Records. These options include instructions regarding how to proceed as a low-income party and a payment schedule detailing how much rent money should be deposited and when. [Appellant] has not deposited any money into an escrow account since the court issued its order on February 1, 2021. [Appellant] is clearly in violation of the court’s order. [Appellant]’s violation of the case management order is persistent and ongoing.

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RCKA Investments LLC v. Johnson, C.
2022 Pa. Super. 139 (Superior Court of Pennsylvania, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
2022 Pa. Super. 139, 281 A.3d 328, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rcka-investments-llc-v-johnson-c-pasuperct-2022.