Roosevelt-Bentman Trust for American Voters

44 Pa. D. & C.5th 404
CourtPennsylvania Court of Common Pleas, Philadelphia County
DecidedFebruary 2, 2015
DocketO.C. No. 608 IV of 2014
StatusPublished
Cited by1 cases

This text of 44 Pa. D. & C.5th 404 (Roosevelt-Bentman Trust for American Voters) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Philadelphia County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Roosevelt-Bentman Trust for American Voters, 44 Pa. D. & C.5th 404 (Pa. Super. Ct. 2015).

Opinion

CARRAFIELLO, J.,

Facts and Procedural History

The Roosevelt-Bentman Trust for American Voters (hereinafter referred to as the “Trust”) was established by the petitioner, 5 9th Republican Ward Executive Committee, on October 4, 2007.1 Respondent, Republican National Committee, is alleged to be a qualified beneficiary of the [406]*406Trust.2 Respondent, however, denies any involvement with or any interest in the Trust.3

On May 2, 2014, the petitioner herein filed to confirm an arbitration award alleging that, pursuant to an arbitration hearing held and an award entered in favor of the 59th Republican Ward Executive Committee and against respondent purportedly effective June 12, 20094, this court should confirm the award and enter a judgment against the respondent.5

Contemporaneously with the above petition, Peter Wirs, as Trustee of the Roosevelt-Bentman Trust for American Voters, filed his own petition for declaratory judgment on behalf of the Trust (hereinafter referred to as “Mr. Wirs’ petition”). However, his petition was dismissed on May 21, 2014 for the following deficiencies/irregularities:

1. The petition indicated Mr. Wirs was proceeding pro se, while the cover sheet indicated he was represented by counsel.
2. Mr. Wirs failed to give his address.
3. Mr. Wirs failed to request relief and inappropriately attached proposed findings of fact and conclusions of law which identified no issue(s) or any specific request for relief.
4. The petition was not in prescribed paragraph form and, in violation of Rules of Civil Procedure, it was unnecessarily anecdotal, prolix, and devoid of [407]*407necessary, specific factual allegations which would justify relief.
5. Mr. Wirs failed to identify any respondent(s), even though he made allusions to beneficiaries’ actions which he claimed had been injurious to the Trust.
6. Mr. Wirs failed to append or incorporate by reference or otherwise identify with specificity the Trust and its relevant provisions. Nor did he append a copy of the award of arbitrators or state the exact language of the award.6

Mr. Wirs filed Exceptions to the court’s decree on June 6, 2014, and while they were pending, withdrew his petition on July 3, 2014. The exceptions were dismissed on July 9, 2014 before the court received the praecipe for withdrawal.7

Following the dismissal of exceptions, this court ordered an on the record conference/hearing be held on October 2, 2014 on the 59th republican ward executive committee’s petition to confirm arbitration award and judgment. Present at the hearing were attorneys Jonathan Goldstein and Britain Henry for the respondent appearing specially to challenge propriety of service. Also present were attorney Lawrence Otter for the petitioner and Mr. Wirs as an officer of petitioner as well as a trustee. At the conclusion of that hearing, the court ordered both petitioner and respondent to each submit a memorandum of law within 60 days of the date of the decree.8 The parties were instructed to be discrete, concise, and address [408]*408solely the issues of: 1) whether the Orphans’ Court is the proper venue to confirm the arbitration award and enter a judgment and 2) whether the arbitration forum had obtained jurisdiction over the respondent.9

On December 4, 2014, the Republican National Committee filed its memorandum in response to the court’s October 6th decree. On December 9, 2014, the 59th republican ward executive committee filed its memorandum.

On December 11, 2014, the respondent filed a motion to strike petitioner’s memorandum of law as filed untimely and without just cause.10 In response, petitioner filed a motion requesting that its memorandum be deemed filed on December 8,2014.11 Respondent filed an answer to this motion on January 8th, 2015.

Discussion

I. The purported arbitration “award” in a forum lacking jurisdiction renders it a nullity.

An arbitration award in a nonjudicial arbitration is, binding and may not be vacated or modified “unless it is clearly shown that a party was denied a hearing or fraud, misconduct, corruption or other irregularity caused the rendition of an unjust, inequitable, or unconscionable award.” 42 Pa.C.S. §7341. The type of irregularity “refers to the process employed in reaching the result of the arbitration, not the result itself.” Gwin Engineers v. Cricket Club Estates Development Group, 555 A.2d 1328 [409]*409(Pa. Super. 1989) citing Chervenak, Keane & Co., Inc. v. Hotel Rittenhouse Assoc., Inc. 477 A.2d 482 (Pa. Super. 1984).

In the present matter, the court ordered petitioner to address the issue of jurisdiction and venue. Not only did it fail to do so, it failed to supply the most essential of information, not only in its petition but also in its memorandum. It failed to identify the arbitrator, the date and place of the arbitration hearing, and the details of notice and/or service to establish jurisdiction.

While petitioner failed to specifically identify the arbitrator, since Mr. Wirs is the only Trustee ever mentioned or identified, this leads to the inescapable conclusion that Mr. Wirs was in fact the arbitrator for the arbitration hearing. Given his position as trustee, as well as an officer of the petitioner 59th republican ward executive committee and the party initiating the arbitration and seeking confirmation of the award, he was anything but impartial.

In addition to petitioner’s failure to provide indication of even the semblance of a hearing, it is unquestionable that the arbitration forum lacked in personam jurisdiction over respondent. In order for an arbitration forum to have jurisdiction over an entity, it must be proven that the entity was properly served. Reco Equip., Inc. v. John T. Subrick Contracting, Inc., 780 A.2d 684, 687 (Pa. Super. 2001). Where service has not otherwise been agreed to, service pursuant to our Rules of Civil Procedure (which are applicable in Orphans’ Court matters) is required.

Petitioner willfully failed to disclose facts which would have constituted service, thereby establishing jurisdiction [410]*410over respondent. Instead, petitioner chose to make the bold, unsupported assertion in its memorandum that jurisdiction had been waived.

Petitioner’s factual allegations, scant as they are, depict a proceeding which is foreign to our concept of due process. Except for the 1960’s television comedy about the fictional town of “Mayberry,” no one, learned in the law or not, believes that in America, a judge, party, and prosecutor who all share the same identity can render a decision that is given the weight of law.

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Bluebook (online)
44 Pa. D. & C.5th 404, Counsel Stack Legal Research, https://law.counselstack.com/opinion/roosevelt-bentman-trust-for-american-voters-pactcomplphilad-2015.