Santella v. Merchants Mutual Insurance

41 Pa. D. & C.3d 324, 1986 Pa. Dist. & Cnty. Dec. LEXIS 300
CourtPennsylvania Court of Common Pleas, Greene County
DecidedNovember 26, 1986
Docketno. 958 of 1982
StatusPublished

This text of 41 Pa. D. & C.3d 324 (Santella v. Merchants Mutual Insurance) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Greene County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Santella v. Merchants Mutual Insurance, 41 Pa. D. & C.3d 324, 1986 Pa. Dist. & Cnty. Dec. LEXIS 300 (Pa. Super. Ct. 1986).

Opinion

GRIMES, P.J.,

This issue comes before the court on a motion by the additional defendants to strike videotaped deposition of witness Ronald Arnold in the latest stage of a long and complex civil suit by original plaintiff Santella against original defendant Merchants Mutual Insurance Company (MMIC).

Plaintiff filed his original complaint in assumpsit on October 22, 1982, claiming proceeds of an insurance policy issued by MMIC as the result of a fire at plaintiff’s place of business on April 12, 1982. MMIC later filed a cross-complaint seeking to join additional defendants Joseph Krivan, Jr., and Frank J. Paletta, petitioner herein.

On June 4, 1984, following a jury trial in the U.S. District Court for the Western District of Pennsylvania in Pittsburgh, Pa., additional defendant Krivan was convicted of arson for setting the fire at plaintiff’s place of business in 1982. His appeal was denied on September 26, 1984 by the U.S. Court of Appeals. During the arson trial, certain testimony was offered alleging that Krivan had set the fire at [326]*326the request of Paletta who had allegedly paid Krivan money to carry out the task. On November 23, 1984, MMIC filed its writ to join Paletta.

On December 20, 1984, MMIC filed its additional complaint. Objections thereto were timely made and on March 8, 1985, this court overruled the preliminary objections and granted joinder of Paletta as an additional defendant along with the convicted arsonist Krivan. Paletta, however, was not named as a co-conspirator in Krivan’s indictment, nor was he joined in the arson trial as a co-defendant.

On October 24, 1986, as a step in the discovery process for this suit, defendant MMIC deposed a witness, one Ronald Arnold, at the State Regional Correctional Facility at Mercer, Pa. where he is now serving a sentence for an unrelated criminal act. Paletta’s attorney was present at the deposition and made timely objections, conducted a properly vigorous cross examination, and objected to the videotaping of Arnold’s statements and cross examination. MMIC videotaped the deposition for possible presentment to jury or bench in the upcoming civil trial on insurance policy coverage.

On. October 27, 1986, petitioner made a timely motion to hold the videotape inadmissible at trial, and seeking to compel the appearance of the witness at the trial itself, in accord with the Sixth Amendment of the U.S. Constitution guaranteeing defendants the right to confront witnesses at time of trial and to cross examine them in the presence of the trier of fact. On November 12, 1986, oral arguments were held on the question and written briefs were submitted by the parties.

DISCUSSION

ISSUE: Whether hearsay statements averring a party’s participation in an alleged criminal conspir[327]*327acy are admissible at trial without separate or independent proof that such a conspiracy existed, other than the admissions of a co-conspirator made in pursuance of the common plan.

At the videotaped deposition at Mercer Corree-; tional Facility, Paletta requested MMIC to make an offer of proof for the proposed testimony of Ronald Arnold. MMIC offered the testimony of Arnold to show that Krivan had made statements prior to the fire and statements after the fire took place implicating Paletta in a criminal plan to set the fire for lucre. According to Arnold, Krivan solicited Arnold’s help in setting the blaze at plaintiffs place of business, that Arnold refused this solicitation, and that Krivan told Arnold that he was performing the task for Paletta.

MMIC, in effect, offers Arnold’s testimony of Krivan’s statement that Paletta said he wished to bum down plaintiffs place of business and would pay to accomplish this objective. This is not only hearsay, nor double hearsay, but triple hearsay, by way of two different out-of-court exchanges and by two convicted felons. This is the worst kind of example (or perhaps the best kind of example) of situations where hearsay statements become repeated, creating in effect rumor, and illustrates precisely why the courts of this Commonwealth refuse to admit such statements except under certain carefully restricted exceptions, and even then only from the first person to hear the declaration, never from the second and third persons who hear someone say that someone heard someone say the declaration in question.

“When a statement is offered in evidence to prove the truth of the facts asserted therein, speaker’s credibility and the circumstances of the statement’s utterance becomes basic to the proper evaluation of [328]*328the statements ... so that the hearsay rule excludes such evidence unless the speaker is on hand to testify personally.” U.S. ex rel. Sullivan v. Cuyler, 553 F. Supp. 1236 (D.C. Pa. 1982); Commonwealth v. Williams, 262 Pa. Super. 508, 396 A.2d 1286 (1978); Commonwealth v. DiSilvio, 232 Pa. Super. 386, 335 A.2d 785 (1975). Such scrutiny must be brought even more firmly to bear when the hearsay is offered in recorded form. Commonwealth v. Paskings, 447 Pa. 350, 290 A.2d 82 (1972).

MMIC admits that Arnold’s statement is hearsay. They would have this court admit the statement nevertheless under one of the recognized exceptions to the general rule enunciated in Cuyler, supra. They cite Commonwealth v. Tumminello, 292 Pa. Super. 381, 437 A.2d 435 (1984), which states that, “Out of court declarations of a co-conspirator can be admitted against another conspirator provided that declarations were made during the conspiracy and in furtherance of the common criminal design.” As for the statements made by Krivan to Arnold after the fire took place, MMIC relies on Commonwealth v. Coccioletti, 493 Pa. 103, 425 A.2d. 387 (1981).

Similarly, MMIC relies on Commonwealth v. Hirsch, 225 Pa. Super. 494, 311 A.2d 679 (1973), for the following propositions: (1) If there was adequate proof of a conspiracy, then the statements of any one conspirator vicariously become the statements of all the others so long as the statements were made in furtherance of the criminal plan; (2) The point at which the evidence is sufficient' is determined by the judge as a matter of law; (3) Such evidence may be established by circumstantial evidence. (See also Commonwealth v. Bachert, 499 Pa. 398, 453 A.2d 931 (1982).

[329]*329Defendant cites Commonwealth v. Hassine, 340 Pa. Super. 318, 490 A.2d 438 (1985), which states, “In addition, an accomplice’s culpability may be established when, with the intent to promote or facilitate the crime, he solicits the perpetrator to carry out the crime ... 18 Pa. C.S. §306(c), (d).”

MMIC is asking the court to apply the holdings of these cases to a different set of circumstances than what the courts were considering.

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Related

Bruton v. United States
391 U.S. 123 (Supreme Court, 1968)
Dutton v. Evans
400 U.S. 74 (Supreme Court, 1970)
United States Ex Rel. Sullivan v. Cuyler
553 F. Supp. 1236 (E.D. Pennsylvania, 1982)
Commonwealth v. Bachert
453 A.2d 931 (Supreme Court of Pennsylvania, 1982)
Commonwealth v. Coccioletti
425 A.2d 387 (Supreme Court of Pennsylvania, 1981)
Commonwealth v. Tumminello
437 A.2d 435 (Superior Court of Pennsylvania, 1981)
Commonwealth v. Fontana
401 A.2d 1361 (Superior Court of Pennsylvania, 1979)
Commonwealth v. DiSilvio
335 A.2d 785 (Superior Court of Pennsylvania, 1975)
Commonwealth v. Williams
396 A.2d 1286 (Superior Court of Pennsylvania, 1979)
Commonwealth v. Hassine
490 A.2d 438 (Supreme Court of Pennsylvania, 1985)
Commonwealth v. Roux
350 A.2d 867 (Supreme Court of Pennsylvania, 1976)
Commonwealth v. Hirsch
311 A.2d 679 (Superior Court of Pennsylvania, 1973)
Commonwealth v. Paskings
290 A.2d 82 (Supreme Court of Pennsylvania, 1972)

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Bluebook (online)
41 Pa. D. & C.3d 324, 1986 Pa. Dist. & Cnty. Dec. LEXIS 300, Counsel Stack Legal Research, https://law.counselstack.com/opinion/santella-v-merchants-mutual-insurance-pactcomplgreene-1986.