Rivera v. Pleasant Valley School District

32 Pa. D. & C.5th 568
CourtPennsylvania Court of Common Pleas, Monroe County
DecidedSeptember 23, 2013
DocketNo. 4718 CV 2008
StatusPublished

This text of 32 Pa. D. & C.5th 568 (Rivera v. Pleasant Valley School District) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Monroe County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rivera v. Pleasant Valley School District, 32 Pa. D. & C.5th 568 (Pa. Super. Ct. 2013).

Opinion

ZULICK, J.,

This lawsuit arises out of an injury allegedly suffered by the minor plaintiff, Kimberly Rivera (Kimberly) on May 24, 2007. The complaint alleges that Kimberly was a 6th grade student at Pleasant Valley Intermediate School. During recess, Kimberly slid down a “fireman’s pole” that was part of a jungle gym unit on the playground. When she landed, she fractured her ankle. She eventually needed two surgeries for repair of the ankle. On May 21,2008, Paul and Darlene Rivera (Riveras) filed suit against Pleasant Valley School District (PVSD), individually and as their daughter’s guardians. The Riveras allege that the layer of wood chips (which serve as a padding) beneath the fireman’s pole was not deep enough, and that this insufficiency caused Kimberly’s injury.

After the completion of discovery, PVSD filed a motion for summary judgment, alleging that: (1) plaintiffs’ claims were barred, as PVSD had immunity under the Political Subdivision Tort Claims Act (PSTCA), 42 Pa.C.S. § 8541, et seq., and (2) plaintiffs’ claim for non-economic damages was barred as plaintiffs failed meet the requirements for such damages under the PSTCA. The Riveras filed a brief [570]*570in opposition to PVSD’s motion, which was argued before the court on July 1, 2013.

DISCUSSION

“Summary judgment is only appropriate in cases where there are no genuine issues of material fact and the moving party is entitled to judgment as a matter of law.” Gleason v. Borough of Moosic, 609 Pa. 353, 361 (2011). A material fact is one that directly affects the outcome of the case. Bartlett v. BradfordPubl’g, Inc., 885 A.2d 562, 568 (Pa. Super. 2008). A court must view the evidence in the light most favorable to the nonmoving party, and all doubts as to a genuine issue of material fact must be resolved against the moving party. Gleason, 609 Pa. at 361 (citing Fine v. Checcio, 582 Pa. 253 (2005)). When the moving party satisfies its initial burden, the nonmoving party may not simply rest upon the allegations or denials contained in the pleadings, instead the nonmoving party must show there is a genuine issue for trial. Preferred Fire Prot., Inc. v. Joseph Davis, Inc., 984 A.2d 20, 24 (Pa. Super. 2008). A nonmoving party’s failure to adduce sufficient evidences on an issue essential to the case establishes that no genuine issue of material fact exists, and the moving party is entitled to judgment as a matter of law. Ario v. Ingram Micro, Inc, 965 A.2d 1194,1207 n. 15 (Pa. 2009).

The Riveras allege that PVSD was negligent in its care, custody or control of its real property. They contend that the wood chips below the fireman’s pole weren’t deep enough. PVSD asserts that the Riveras’ action should be dismissed, as PVSD has immunity under the PSTCA.

The PSTCA generally provides that “no local agency shall be liable for any damages on account of any injury to [571]*571a person or property caused by any act of the local agency or an employee thereof or any other person.” 42 Pa.C.S. § 8541. However, the PSTCA provides several exceptions:

(a) Liability imposed. —A local agency shall be liable for damages on account of an injury to a person or property within the limits set forth in this subchapter if both of the following conditions are satisfied and the injuiy occurs as a result of one of the acts set forth in subsection (b):
(1) The damages would be recoverable under common law or a statute creating a cause of action if the injuiy were caused by a person not having available a defense under section 8541 (relating to governmental immunity generally) or section 8546 (relating to defense of official immunity); and
(2) The injury was caused by the negligent acts of the local agency or an employee thereof acting within the scope of his office or duties with respect to one of the categories listed in subsection (b). As used in this paragraph, “negligent acts” shall not include acts or conduct which constitutes a crime, actual fraud, actual malice or willful misconduct.
(b) Acts which may impose liability. — The following acts by a local agency or any of its employees may result in the imposition of liability on a local agency:
...(3) Real property. — The care, custody or control of real property in the possession of the local agency, except that the local agency shall not be liable for damages on account of any injury sustained by a person intentionally trespassing on real property in [572]*572the possession of the local agency. As used in this paragraph, “real property” shall not include:
(i) trees, traffic signs, lights and other traffic controls, street lights and street lighting systems;
(ii) facilities of steam, sewer, water, gas and electric systems owned by the local agency and located within rights-of-way;
(iii) streets; or
(iv) sidewalks.

42 Pa.C.S. § 8542. The parties here agree that the playground equipment itself was not defective or otherwise the cause of Kimberly’s injury. The dispute is whether the wood chips (or mulch) which served as a protective carpeting for the playground are real or personal property.

It is clear that up until the time the wood chips were spread on the playground, they were the personal property of the PVSD. However, when the wood chips were spread on the playground area, they became real property.

Chattels used in connection with real estate are of three classes: First, those which are manifestly furniture, as distinguished from improvements, and not peculiarly fitted to the property with which they are used; these always remain personalty.... Second, those which are so annexed to the property, that they cannot be removed without material injury to the real estate or to themselves; these are realty.... Third, those which, although physically connected with the real estate, are so affixed as to be removable without destroying or materially injuring the chattels themselves, or the [573]*573property to which they are annexed; these become part of the realty or remain personalty, depending on the intention of the parties at the time of annexation....

Repko v. Chichester School Dist., 904 A.2d 1036, 1040 (Pa. Cmwlth. 2006) (citing Clayton v. Lienhard, 167 A.2d 321, 322 (Pa. 1933). It is clear that the wood chips are not of the first class, as they are not furniture or some other easily portable thing.

PVSD argues that this is not the case. They argue that “school equipment attached to real property by gravity remains personalty.” Defendant’s Motion for Summary Judgment at 27 (citing Canon-McMillan School Dist. v. Bioni, 561 A.2d 853, 854 (Pa. Cmwlth. 1989)). Canon-McMillan is distinguishable from the present matter.

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Bluebook (online)
32 Pa. D. & C.5th 568, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rivera-v-pleasant-valley-school-district-pactcomplmonroe-2013.