Smith v. Sperduti

74 Pa. D. & C.4th 395, 2005 Pa. Dist. & Cnty. Dec. LEXIS 108
CourtPennsylvania Court of Common Pleas, Beaver County
DecidedAugust 5, 2005
Docketno. 10257 of 1998
StatusPublished

This text of 74 Pa. D. & C.4th 395 (Smith v. Sperduti) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Beaver County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Smith v. Sperduti, 74 Pa. D. & C.4th 395, 2005 Pa. Dist. & Cnty. Dec. LEXIS 108 (Pa. Super. Ct. 2005).

Opinion

KUNSELMAN, P.J.,

This case presents an issue of first impression. Can an aggrieved party secure relief from a judgment of a district justice (now a magisterial district judge) by way of a writ of certiorari, claiming lack of jurisdiction over him, after the case records of the district justice have been destroyed pursuant to the record retention and disposition schedule adopted to implement Pa.RJ.A. 507(b)? This issue is presented by the following factual and procedural history.

The respondent, Frank Smith, and Erie Insurance Company filed a civil action against the petitioner, Louis Sperduti, seeking damages Smith claimed to have sustained in a motor vehicle accident allegedly caused by the negligence of Sperduti. Erie apparently has a subrogation interest in the case. The accident occurred on September 19, 1985, in the City of Aliquippa and suit was filed on April 28, 1986, in the office of District Justice Peter J. Loschiavo. District Justice Loschiavo entered judgment by default on May 20, 1986, in favor of Erie Insurance and Smith and against Sperduti in the amount of $3,236.09. Acertified copy ofthis judgment was filed with the prothonotaiy of Beaver County on June 26,1986, at no. 785 of 1986 DSB.

Both the original process issued by District Justice Loschiavo and the notice of judgment by the prothonotary of Beaver County were mailed to Sperduti at 100 Grand Avenue, Aliquippa, PA. The prothonotary of Beaver County mailed a certification of the nonpayment of [398]*398the judgment to the Commonwealth of Pennsylvania, Department of Transportation, Bureau of Driver Licensing on October 17, 1986. (See record of proceedings at no. 785 of 1986 DSB.) That agency suspended Sperduti’s operator’s license, effective January 9, 1987, for nonpayment of the judgment. Notice thereof was mailed to Sperduti on December 5, 1986. Although the address to which the notice was mailed is unknown, the records of the bureau indicate that Sperduti’s operator’s license was received by the bureau on January 19, 1987. (P. 3, exhibit G to Sperduti’s brief filed May 26, 2005.)

Thereafter, nothing occurred until February 18,1998, when Sperduti, pro se, filed a praecipe for a writ of certiorari directed to District Justice, now Magisterial District Judge, James F. DiBenedetto. (The former District Justice Peter J. Loschiavo retired and later died. James F. DiBenedetto was elected to replace him.) The praecipe claimed lack of jurisdiction over Sperduti and such gross irregularity of procedure as to make the judgment void. The writ was issued the same day and, on February 19, 1998, District Justice DiBenedetto filed a return of the writ in which he reported that the records in the case had been destroyed after seven years. The only record remaining was a “Civil case progress record,” a copy of which was forwarded in further response to the writ. That record is in the nature of docket entries and discloses the docket number, the names of the plaintiff and the defendant, the date filed, a code for “action in trespass,” the filing costs, the dates of hearing and judgment and, under “comments,” “Def. Jud.” No other record was available to submit in response to the writ of certiorari, in-[399]*399eluding, significantly, the type and manner of service of process.

After the writ was returned, Sperduti did nothing until January 26, 2005, when Sperduti, through counsel, presented a petition to open or strike judgment to the court. That petition was filed at the same number as had been given to the praecipe for writ of certiorari instead of no. 785 of 1986 DSB. On the same date, the court issued a rule in accordance with Pa.R.C.P. 206.5, directing that an answer be filed, depositions be taken and scheduling argument thereon for April 26, 2005. Argument had to be rescheduled and was held on June 2, 2005. At that time, we improvidently treated Sperduti’s petition as a petition for leave to appeal nunc pro tunc from the judgment of the district justice. We now recognize our error and will treat Sperduti’s petition as exceptions or specifications of error to the record of District Justice Loschiavo.

In his petition, Sperduti alleges the following: He was not involved in the motor vehicle accident upon which Smith’s suit was based; he was never served with a copy of the complaint; he never received notice of the hearing before District Justice Loschiavo or the judgment entered by him; at the time the suit was instituted, he did not reside at either address listed on the police accident report; and he did not learn of the judgment until 1997 when he attempted to renew his drivers’ license.

The Rules of Civil Procedure governing actions before district justices authorize an aggrieved defendant to file a praecipe for a writ of certiorari claiming that the judgment should be set aside for several reasons: lack of [400]*400jurisdiction over the parties or the subject matter; improper venue, or such gross irregularity of procedure as to make the judgment void. See Pa.R.C.P.D.J. 1009(A). That rule goes on to provide

“If lack of jurisdiction over the parties or the subject matter is claimed, the praecipe may be filed at any tune after judgment. Otherwise, it shall be filed within 30 days after the date of the judgment.” Pa.R.C.P.D.J. 1009(B). (emphasis added)

This rule codifies decisional law that a time limit prescribed for the issuance of a writ of certiorari to a judgment of a former justice of the peace does not apply to a judgment which is void for want of jurisdiction. Atkins v. Flaherty, 189 Pa. Super. 550, 152 A.2d 280 (1959). That case also announced the rule that, on a writ of certiorari, the court is bound by the facts as set forth in the transcript and cannot consider other testimony. 189 Pa. Super, at 550, 152 A.2d at 281.

If we were limited to the rule in Atkins v. Flaherty, supra, both parties and the court would be in a dilemma. This is for the reason that, because the record of the district justice had been properly destroyed by the time the praecipe for the writ of certiorari was filed, there is no record for us to review. Thus, there is seemingly irreconcilable conflict between Pa.R.C.P.D.J. 1009(B), which permits a praecipe for a writ of certiorari anytime after judgment where lack of jurisdiction is claimed, and the record retention and disposition schedule of our Supreme Court. Our choices would be limited to a quashing of the writ as untimely filed, notwithstanding Pa.R.C.P.D.J. 1009(B) because there is no record to review.

[401]*401However, in a more recent opinion, our Superior Court has modified the rule of Atkins v. Flaherty, sub silentio. In Anzalone v. Vormack, 718 A.2d 1246, 1249 (Pa. Super. 1998), the Superior Court observed that an extrinsic attack on the constable’s return of service can be made, restricted to those facts in the return that are matters of which the constable presumptively had no personal knowledge. In other words, evidence can be produced to attack the record as to matters not within the personal knowledge of the process server. Thus, if appropriate to do so, we can consider evidence beyond the record of the district justice to determine the issue with regard to those facts not within the personal knowledge of the district justice. The record of the judgment at no.

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Related

Anzalone v. Vormack
718 A.2d 1246 (Superior Court of Pennsylvania, 1998)
Atkins v. Flaherty
152 A.2d 280 (Superior Court of Pennsylvania, 1959)

Cite This Page — Counsel Stack

Bluebook (online)
74 Pa. D. & C.4th 395, 2005 Pa. Dist. & Cnty. Dec. LEXIS 108, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-sperduti-pactcomplbeaver-2005.