Security Peoples Trust Co. v. Erenstein

47 Pa. D. & C.3d 385, 1986 Pa. Dist. & Cnty. Dec. LEXIS 30
CourtPennsylvania Court of Common Pleas, Alleghany County
DecidedDecember 11, 1986
Docketno. G.D. 79-4351
StatusPublished

This text of 47 Pa. D. & C.3d 385 (Security Peoples Trust Co. v. Erenstein) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Alleghany County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Security Peoples Trust Co. v. Erenstein, 47 Pa. D. & C.3d 385, 1986 Pa. Dist. & Cnty. Dec. LEXIS 30 (Pa. Super. Ct. 1986).

Opinion

WETTICK, A.J.,

On November 21, 1979, Security Peoples Trust Company entered a confessed judgment against Bernard J. Erenstein and Evelyn Erenstein in the amount of $525,000. On February 14, 1983, Erenstein paid $125,521.09 to Sécurity Peoples. Erenstein contended that this payment satisfied the November 21, 1979, judgment and, shortly thereafter, requested Security Peoples to satisfy the judgment. Security Peoples did not instruct the prothonotary to mark the judgment satisfied until December 6, 1983.

On December 14, 1984, Erenstein filed a petition for supplemental proceedings which 'seeks a judgment against Security Peoples in the amount $252,500 for its failure to timely satisfy the judgment. Erenstein’s claim for supplemental relief is based upon legislation which awards liquidated damages for failure of a judgment creditor to have a docket marked satisfied within 30 days after receiving written notice from a judgment debtor who has paid the judgment that the docket should be so marked. This legislation, which is contained at 42 Pa.C.S. §8104, reads as follows: '

“(a) General rule. — A judgment creditor who has received satisfaction of any judgment in any tribunal of this commonwealth shall, at the written request of the judgment debtor, or of anyone interested therein, and tender of the fee for entry of satisfaction, enter satisfaction in the office of the clerk of the court where such judgment is outstand[387]*387ing, which satisfaction shall forever discharge the judgment.

“(b) Liquidated damages. — A judgment creditor who shall fail or refuse for more than 30 days after written notice in the manner prescribed by general rules to comply with a request pursuant to subsection (a) shall pay to the judgment debtor as liquidated damages 1 percent of the original amount of the judgment for each day of delinquency beyond such 30 days, but not less then $250 nor more than 50 percent of the original amount of the judgment. Such liquidated damages shall be recoverable pursuant to general rules, by supplementary proceedings in the matter in which the judgment was entered.”

Presently before this court is Security Peoples’ motion to compel answers to interrogatories and the production of documents. Through these discovery requests, Security Peoples seeks information concerning Erenstein’s relationship with various corporations with which Erenstein was involved that owed money to Security Peoples (Category One); information concerning negotiations between Security Peoples and Erenstein conducted between February 14, 1983, and December 6, 1983, over whether the February 14, 1983, payment had satisfied the November 21, 1979, judgment (Category Two); and information concerning the actual damages that Erenstein sustained as the result of any delay by Security Peoples in satisfying the judgment (Category Three).

Security Peoples seeks the information in Categories One and Two to show that it was not acting willfully or in bad faith in failing to have the judgment marked satisfied. Security Peoples wishes to show that between February 14, 1983, and December 6, 1983, several corporations which Erenstein operat[388]*388ed and whose debts Erenstein had guaranteed owed substantial sums to Security Peoples; that there was a bona fide dispute over whether the $125,000 payment should have been applied to the judgment in question; that the parties negotiated for several months in an effort to resolve this issue; and that a review of the negotiations will show that there was a bona fide dispute over whether the February 14, 1983, payment satisfied the November 21, 1979, judgment. Security Peoples seeks the. information described in Category Three because it wishes to establish that Erenstein sustained no actual damages as a result of its failure to satisfy the judgment prior to December 6, 1983.

Erenstein contends that the information which Security Peoples seeks is irrelevant. Under 42 Pa.C.S. §8104, Erenstein is entitled to recover liquidated damages in the amount of 1 percent of the original amount of the judgment for each day that Security Peoples failed to satisfy the judgment beyond 30 days following receipt of a written request to satisfy this judgment. Thus, the only factual issues, according to Erenstein, are whether the February 14, 1983, payment satisfied the judgment and, if so, when the written request to satisfy the docket was made. Erenstein contends that it makes no difference why Security Peoples failed to satisfy the judgment or whether Erenstein sustained any actual damages.

Security Peoples, on the other hand, contends that it may either defeat or reduce the amount of the recovery by showing that it had a reasonable basis for questioning whether the $125,000 payment had fully satisfied the November 21, 1979, judgment or by showing that Erenstein sustained no actual damages from Security Peoples’ delay in satisfying the judgment.

[389]*389In support of its position, Security Peoples relies on case law construing previous legislation which held that the amount of any damages that will be assessed against a creditor for failure to satisfy a judgment will be determined by a consideration of all relevant circumstances, including, the attitude and conduct of the creditor, whether the creditor’s conduct was wanton or willful, and the injury suffered by the debtor. Werner v. Automobile Finance Co., 347 Pa. 217, 31 A.2d 898 (1943). However, this case law construed the Act of May 13, 1715 which provided the following relief when a creditor failed to satisfy the record within three months after being requested to do so:

“. . . he, she, or they neglecting so to do [have the mortgage marked satisfied], shall for every such offense forfeit and pay unto the party or parties aggrieved, any sum not exceeding the mortgage money, to be recovered in any court of record within this province by bill, complaint or information.”

The basis for the case law holding that the amount of damages to be awarded under the Act of May 28, 1715, depends upon all relevant circumstances was that this legislation was intended to both compensate the aggrieved party- for its losses and to punish the offender. The Act of May 28, 1715, had no fixed formula for awarding damages. It provided for the creditor to “forfeit” a sum of money not exceeding the amount of the mortgage. Consequently, it was left to the courts to determine the factors that should be considered in determining the amount of the damages that should be awarded. This case law holding that the amount of damages to be awarded depends upon a consideration of all relevant factors, including the amount of damages sustained by the debtor, is not controlling because 42 Pa.C.S. §8104 — unlike the Act of May 28, 1715 [390]*390— is not intended to punish the creditor. Its sole purpose is to compensate a debtor for his or her losses through the award of damages based upon a specific formula.

Subsection (b) of §8104 is titled “liquidated damages” and provides that “a judgment creditor . . . shall pay to the judgment debtor as liquidated damages. ...” “Liquidated damages” is a technical term used throughout the law, so we must ascribe its particular meaning to it. 1 Pa.C.S. § 1903(a). “Liquidated damages” evolved as a device to permit compensation when the offensive conduct “ ‘may well result in damages too obscure and difficult of proof or estimate other than by liquidated damages.’ ” (Citation omitted.) Commonwealth v. Musser Forests Inc.,

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Bluebook (online)
47 Pa. D. & C.3d 385, 1986 Pa. Dist. & Cnty. Dec. LEXIS 30, Counsel Stack Legal Research, https://law.counselstack.com/opinion/security-peoples-trust-co-v-erenstein-pactcomplallegh-1986.