Shoucair v. Comfort Inn

15 Pa. D. & C.4th 532, 1992 Pa. Dist. & Cnty. Dec. LEXIS 269
CourtPennsylvania Court of Common Pleas, Monroe County
DecidedAugust 14, 1992
Docketno. 116 Civil of 1990
StatusPublished

This text of 15 Pa. D. & C.4th 532 (Shoucair v. Comfort Inn) 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
Shoucair v. Comfort Inn, 15 Pa. D. & C.4th 532, 1992 Pa. Dist. & Cnty. Dec. LEXIS 269 (Pa. Super. Ct. 1992).

Opinion

O’BRIEN, J.,

On January 11,1990, plaintiff Samuel Shoucair, a Pennsylvania State Policeman, filed a complaint seeking money damages from the defendant Comfort Inn for injuries sustained by him while arresting additional defendant Saturday Crump at the Comfort Inn in Bartonsville. The policeman alleged that his injuries were caused by the defendant’s negligent failure to provide adequate security at the inn. Carol M. Shoucair [533]*533joined in the complaint making a claim for loss of consortium and the Comfort Inn joined Saturday Crump as an additional defendant. Following a three-day trial, a jury returned a verdict on June 10, 1992, finding that the defendant Comfort Inn was not negligent, thereby precluding any recovery by the plaintiffs. Plaintiffs filed a motion for post-trial relief in the nature of a motion for a new trial and a motion for judgment notwithstanding the verdict. Following the submission of briefs and argument before the court on August 3, 1992, plaintiffs’ motion is now before the court for disposition.

Plaintiffs’ sole contention in support of their motion is that this court erred in excluding evidence of prior acts of violence that occurred on the defendant’s premises in the year prior to the incident in question. Since the Commonwealth Court has held that the exclusion of evidence cannot be the basis for judgment notwithstanding the verdict (Hoffmaster v. Allegheny County, 121 Pa. Commw. 266, 550 A.2d 1023 (1988)), our inquiry is limited to a determination of whether or not the plaintiffs are entitled to a new trial. The proper test for resolving a motion for new trial is whether the trial court committed a manifest abuse of discretion or a clear error of law in its evidentiary rulings. Chanda v. Commonwealth, 86 Pa. Commw. 532, 485 A.2d 867 (1984). Questions regarding the admission or exclusion of evidence are within the sound discretion of the trial judge. Soda v. Baird, 411 Pa. Super. 80, 600 A.2d 1274 (1991); Engle v. West Penn Power Co., 409 Pa. Super. 462, 598 A.2d 290 (1991). In order to justify the grant of a new trial, the moving party must establish not only a clear abuse of discretion but also a showing of actual prejudice. Den-Tel-Ez Inc. v. Siemens Capital Corp., 389 Pa. Super. 219, 566 A.2d 1214 (1989). Thus, only an erroneous exclusion of evidence which is material and prejudicial [534]*534is a basis for granting a new trial. Eldridge v. Melcher, 226 Pa. Super. 381, 313 A.2d 750 (1973).

In the case at bar, the evidence presented at trial established that defendant Comfort Inn was closed and locked at approximately 2 a.m. Ten to 20 minutes later, additional defendant Saturday Crump was chased onto defendant’s premises by a group of people from Lee’s Chinese Restaurant. When additional defendant reached the door, he found it to be locked. Defendant’s employees assessed the situation, unlocked the door, and permitted additional defendant to enter the lounge. Once inside defendant’s premises, additional defendant did not create any disturbances nor was there any problem with defendant’s security guard. The State Police were called to the scene and entered defendant’s premises after it had been unlocked. The plaintiff and Trooper Hontz, with the assistance of defendant’s security guard, placed additional defendant under arrest. Plaintiff was allegedly injured while placing additional defendant under arrest.

Prior to trial, the defendant Comfort Inn filed a motion in limine seeking to preclude the plaintiffs from introducing computer summaries of prior incidents at the inn and any evidence of prior dissimilar incidents. This court reserved ruling on the motion until after the plaintiff had testified as to the particular circumstances involving his injury. Although the plaintiff was permitted to present the testimony of a manager of a security firm who previously provided security at the inn, that he had recommended a larger security force at the inn, we precluded the witness from testifying as to prior specific incidents. The testimony precluded would have described a number of completely dissimilar incidents including the following: On July 7, 1988, an undressed man attempted to enter the car of a female in defendant’s parking lot; On July 9,1988, a man threw a punch at another man while pa[535]*535tronizing defendant’s establishment; On August 4, 1988, a hit and run accident occurred in the parking lot while defendant’s establishment was open to the public; On August 25,1988, a fight occurred while defendant’s premises was open to the public; On September 11, 1988, a man was in the ladies room in defendant’s premises; On September 21, 1988, a stabbing occurred as three people were leaving defendant’s parking lot; On September 29, 1988, a fight occurred in defendant’s lounge while the premises were open to the public; On September 29, 1988, a tray was thrown at a waitress while she was working at defendant’s bar; On October 2, 1988, a disorderly conduct incident occurred after a patron was cut off from alcohol; On December 3, 1988, a fight broke out on the dance floor involving patrons while defendant’s premises were open to the public; On December 17,1988, a fight broke out when non-hotel guests attempted to enter defendant’s lounge at a time when only hotel guests were permitted to enter; On December 22,1988, a security officer was assaulted by a patron while defendant’s premises were open.

“Evidence of prior accidents or occurrences is generally relevant to show the existence of a defect or dangerous condition or to demonstrate knowledge on the part of the defendant that the hazard existed.... For such evidence to be admissible, however, the prior incidents must have taken place under the same or similar conditions. ” Vernon v. Stash, 367 Pa. Super. 36, 47, 532 A.2d 441, 446 (1987). In Whitman v. Riddell, 324 Pa. Super. 177, 471 A.2d 521 (1984), the Superior Court stated that “this limited exception, permitting the introduction of evidence of similar accidents, is tempered by judicial concern that the evidence may raise collateral issues, confusing both the real issue and the jury.” Id. at 181, 471 A.2d at 523. In that case the Superior Court held that it was reversible [536]*536error to admit evidence of 35 prior accidents occurring at a particular intersection. The court noted that other accidents occurring at the same place do not necessarily constitute “similar accidents occurring ... under the same or similar circumstances.” Id. The prior accidents resulted from causes wholly foreign to the cause at issue and would raise many collateral issues for the jury to consider.

In Majdic v. Cincinnati Machine Co., 370 Pa. Super. 611, 537 A.2d 334

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Related

Feld v. Merriam
485 A.2d 742 (Supreme Court of Pennsylvania, 1984)
Moran v. Valley Forge Drive-In Theater, Inc.
246 A.2d 875 (Supreme Court of Pennsylvania, 1968)
Hoffmaster v. County of Allegheny
550 A.2d 1023 (Commonwealth Court of Pennsylvania, 1988)
Engle v. West Penn Power Co.
598 A.2d 290 (Superior Court of Pennsylvania, 1991)
Majdic v. Cincinnati MacHine Co.
537 A.2d 334 (Supreme Court of Pennsylvania, 1988)
Soda v. Baird
600 A.2d 1274 (Superior Court of Pennsylvania, 1991)
Den-Tal-Ez, Inc. v. Siemens Capital Corp.
566 A.2d 1214 (Supreme Court of Pennsylvania, 1989)
Murphy v. Penn Fruit Co.
418 A.2d 480 (Superior Court of Pennsylvania, 1980)
Whitman v. Riddell
471 A.2d 521 (Supreme Court of Pennsylvania, 1984)
Kerns v. Methodist Hospital
574 A.2d 1068 (Supreme Court of Pennsylvania, 1990)
Holland v. Zelnick
478 A.2d 885 (Supreme Court of Pennsylvania, 1984)
Vernon v. Stash
532 A.2d 441 (Supreme Court of Pennsylvania, 1987)
Eldridge v. Melcher
313 A.2d 750 (Superior Court of Pennsylvania, 1973)
Chanda v. Commonwealth
485 A.2d 867 (Commonwealth Court of Pennsylvania, 1984)

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Bluebook (online)
15 Pa. D. & C.4th 532, 1992 Pa. Dist. & Cnty. Dec. LEXIS 269, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shoucair-v-comfort-inn-pactcomplmonroe-1992.