Sabatini v. Weber-Harris Ford 4M Inc.

11 Pa. D. & C.5th 344, 2010 Pa. Dist. & Cnty. Dec. LEXIS 53
CourtPennsylvania Court of Common Pleas, Crawford County
DecidedFebruary 12, 2010
Docketno. D.S.B. 2009-749
StatusPublished

This text of 11 Pa. D. & C.5th 344 (Sabatini v. Weber-Harris Ford 4M Inc.) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Crawford County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sabatini v. Weber-Harris Ford 4M Inc., 11 Pa. D. & C.5th 344, 2010 Pa. Dist. & Cnty. Dec. LEXIS 53 (Pa. Super. Ct. 2010).

Opinion

SPATARO, J.,

Plaintiff, Matt C. Sabatini, filed an action in the District Court of Shawnee County, Kansas, seeking to recover the sum of $1,801.01 in damages in connection with a 2002 Dodge Ram pickup truck that he purchased from the defendant, Weber-Harris Ford Lincoln Mercury Inc.1 Weber-Harris is an automobile dealership, located on Baldwin Street in Meadville, Pennsylvania. Sabatini is a resident of Topeka, Kansas. Sabatini successfully prosecuted his suit against Weber-Harris to judgment and then filed a praecipe to file foreign judgment in the amount of $ 1,600 with the prothonotary of Crawford County on August 3, 2009. Weber-Harris filed a motion to vacate the judgment, contending that judgment should be stricken because the District Court of Shawnee County, Kansas did not have personal jurisdiction over Weber-Harris.

[346]*346The origin of this dispute goes back to August 2007, when Sabatini learned of the sale of a 2002 Dodge Ram pickup truck on Weber-Harris’ web site. He contacted Weber-Harris to express his interest in the vehicle. Weber-Harris later mailed a contract of sale to Sabatini, which set forth the terms of the transaction. The vehicle was to be sold “as is,” although Weber-Harris did warrant that the vehicle had no previous or existing collision repairs, nor any existing damage or interior bums. Sabatini signed the sales agreement and then sent it back to Weber-Harris. Upon receipt of the purchase price, the vehicle was available for delivery. Sabatini “contracted with a carrier to pick up the vehicle in Pennsylvania and deliver it to Kansas.” (Plaintiff’s reply to defendant’s motion to vacate, averments 6 and 7.)

Weber-Harris asserts that its limited amount of involvement within the State of Kansas is insufficient to vest the District Court of Shawnee County with jurisdiction and that the judgment entered in the Kansas Court is unenforceable in Pennsylvania. Sabatini asserts that Weber-Harris submitted itself to the jurisdiction of the State of Kansas by advertising the sale of the pick-up truck on the Internet, knowing that citizens of Kansas were within the pool of potential buyers; furthermore, that sending the contract to Sabatini demonstrated the intention of Weber-Harris to submit to personal jurisdiction in the courts of Kansas.

We begin by examining the pertinent provisions of the Uniform Enforcement of Foreign Judgments Act. 42 Pa.C.S. §4306. This Act is designed to provide compliance with the “constitutional mandate that each state give [347]*347full faith and credit to judgments transferred from sister states” and permits a “simplistic and systematic .transfer of money judgments from one state’s court to another.” Commonwealth Capital Funding Inc. v. Franklin Square Hospital, 423 Pa. Super. 149, 153, 620 A.2d 1154, 1156 (1993). (footnote omitted)

The Uniform Enforcement of Foreign Judgments Act requires the filing of foreign judgments properly entered in a foreign sister state. Such judgments shall be subject to the “same procedures, defenses and proceedings for reopening, vacating, or staying as a judgment of any court of common pleas of this Commonwealth.” 42 Pa.C.S. §4306(b). The validity of the judgment in this Commonwealth, and enforcement of the judgment, requires that the sister state had proper jurisdiction. Commonwealth Capital Funding Inc., supra, see also, RECO Equipment Inc. v. John T. Subrick Contracting Inc., 780 A.2d 684 (Pa. Super. 2001), appeal denied, 567 Pa. 763, 790 A.2d 1018 (2001). We are, therefore, required to examine Kansas law to determine whether the courts of Kansas had jurisdiction over Weber-Harris.

In Kansas, a two-step analysis is required to determine whether there is specific, personal jurisdiction over a nonresident;

(1) Whether the long arm statute in Kansas includes the conduct of the nonresident, noting that the statute is to be liberally construed. Volt Delta Resources Inc. v. Devine, 241 Kan. 775, 740 P.2d 1089 (1987).

(2) If so, whether the assertion of jurisdiction comports with due process requirements. Slawson v. Hair, 716 F. [348]*348Supp. 1373, 1375 (D.Kan.1989). Satisfaction of due process depends on the quality and nature of the activities of the defendant, determined on a case by case basis. Woodring v. Hall, 200 Kan. 597, 602, 438 P.2d 135, 141 (1968).

The pertinent provisions of the Kansas long arm statute read as follows:

“(b) Submitting to jurisdiction-process. Any person, whether or not a citizen or resident of this state, who in person or through an agent or instrumentality does any of the acts hereinafter enumerated, thereby submits the person and, if an individual, the individual’s personal representative, to the jurisdiction of the courts of this state as to any cause of action arising from the doing of any of these acts:

“(7) The transaction of any business within this state” Kan. Stat. Ann. 60-308(b)(l) and (b)(2).

Kansas courts have defined what is meant by the transaction of business:

“ ‘Business’ is transacted within the state when an individual is within or enters this state in person or by agent and, through dealing with another within the state, effectuates or attempts to effectuate a purpose to improve his economic conditions and satisfy his desires. Woodring v. Hall, 200 Kan. at 607, 438 P.2d 135. The transaction of business exists when the nonresident purposefully does some act or consummates some transaction in the forum state. White v. Goldthwaite, 204 Kan. 83, 88, 460 [349]*349v. Devine, 241 Kan. 775, 778, 740 P.2d 1089, 1092 (1987).

The record is minimal as to whether Weber-Harris engaged in a “transaction” within the State of Kansas. The only document submitted by the parties by stipulation is the first page of the parties’ contract. One cannot glean from this document the full extent of the terms and conditions, as it is apparent that there is at least one other page missing. Moreover, while there are various signatures on the document, it is impossible to determine when they were placed on the document. Presumably, Weber-Harris mailed the document to Sabatini, without any signatures by Weber-Harris personnel. Most likely, Sabatini then affixed his signature where indicted and mailed the document back to Weber-Harris, along with the down payment. At that point, someone from Weber-Harris must have communicated with Sabatini to let Sabatini know that the truck was available for delivery. Sabatini then arranged for a contractor to go to Pennsylvania and pick up the vehicle. “An offer to make a contract shall be construed as inviting acceptance in any manner and by any medium reasonable in the circumstances.” (13 Pa.C.S. § 2206(a)(1), Kan. Stat. Ann. 84-2-206.) Weber-Harris invited acceptance by mailing the contract to Sabatini.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

International Shoe Co. v. Washington
326 U.S. 310 (Supreme Court, 1945)
World-Wide Volkswagen Corp. v. Woodson
444 U.S. 286 (Supreme Court, 1980)
Burger King Corp. v. Rudzewicz
471 U.S. 462 (Supreme Court, 1985)
Pedi Bares, Inc. v. P & C Food Markets, Inc.
567 F.2d 933 (Tenth Circuit, 1977)
White v. Goldthwaite
460 P.2d 578 (Supreme Court of Kansas, 1969)
Woodring v. Hall
438 P.2d 135 (Supreme Court of Kansas, 1968)
Rosedale State Bank & Trust Co. v. Stringer
579 P.2d 158 (Court of Appeals of Kansas, 1978)
Volt Delta Resources, Inc. v. Devine
740 P.2d 1089 (Supreme Court of Kansas, 1987)
Maritz, Inc. v. Cybergold, Inc.
947 F. Supp. 1328 (E.D. Missouri, 1996)
RECO Equipment, Inc. v. John T. Subrick Contracting, Inc.
780 A.2d 684 (Superior Court of Pennsylvania, 2001)
Commonwealth Capital Funding, Inc. v. Franklin Square Hospital
620 A.2d 1154 (Superior Court of Pennsylvania, 1993)
Bensusan Restaurant Corp. v. King
937 F. Supp. 295 (S.D. New York, 1996)
Jensvold v. Shalala
925 F. Supp. 1109 (D. Maryland, 1996)
Slawson v. Hair
716 F. Supp. 1373 (D. Kansas, 1989)

Cite This Page — Counsel Stack

Bluebook (online)
11 Pa. D. & C.5th 344, 2010 Pa. Dist. & Cnty. Dec. LEXIS 53, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sabatini-v-weber-harris-ford-4m-inc-pactcomplcrawfo-2010.