Williams, N. v. Espada, S.

Superior Court of Pennsylvania·Decided August 7, 2026·No. 3211 EDA 2025·Unpublished·Murray

Opinion

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

NIKKI WILLIAMS : IN THE SUPERIOR COURT OF : PENNSYLVANIA

Appellant :

:

:

v. :

:

:

SILVERIO ESPADA : No. 3211 EDA 2025

Appeal from the Judgment Entered September 5, 2025 In the Court of Common Pleas of Philadelphia County Civil Division at No(s): 230802482

BEFORE: LAZARUS, P.J., MURRAY, J., and FORD ELLIOTT, P.J.E.* MEMORANDUM BY MURRAY, J.: FILED AUGUST 7, 2026 Nikki Williams (Appellant) appeals, pro se, from the judgment entered against her, and in favor of Silverio Espada (Espada), in this personal injury/negligence action involving a motor-vehicle collision. After careful consideration, we affirm.

On August 23, 2023, Appellant filed a civil complaint against Espada seeking damages that resulted from a motor-vehicle collision. The complaint alleged that on August 2, 2022, at 1:30 p.m., Espada’s vehicle collided with Appellant’s vehicle on the I-676 Vine Street Expressway, in Philadelphia, Pennsylvania. Complaint, 8/23/23, ¶¶ 3, 5. According to the complaint, Espada attempted to change lanes without proper clearance. Id. ¶ 8. As a

* Retired Senior Judge assigned to the Superior Court.

result of the collision, Appellant averred she suffered “serious, severe and permanent bodily injuries, including … upper back and neck pain[.]” Id. ¶ 7. Appellant’s complaint presented one count of negligence against Espada. Id. ¶¶ 8-14.

Following procedural matters not relevant to this appeal, the case proceeded to a jury trial on July 16-18, 2025. On July 18, 2025, the jury returned a verdict in favor of Espada, and against Appellant. In answering interrogatories, the jury determined that both parties were negligent, and that both parties’ negligence caused Appellant’s injuries. Jury Interrogatories, 7/18/25, Questions 1-4. In apportioning negligence, the jury attributed 90% of the negligence to Appellant, and 10% of negligence to Espada. Id., Question 5.

On July 25, 2025, Wanda Brice (Ms. Brice), Appellant’s “Daughter and Trial Observer,” filed a post-trial motion on Appellant’s behalf. 1 The trial court denied the post-trial motion on September 5, 2025, and on September 9, 2025, entered judgment on the jury’s verdict. The certificate of service indicated that a copy of the judgment was served on Appellant’s counsel of record, via the trial court’s electronic filing system. Praecipe, 9/9/25, certificate of service. However, on September 11, 2025, the post office

1 Ms. Brice is not a licensed attorney.

returned the service directed to Appellant, and requested an address correction for Appellant.

Appellant filed a pro se notice of appeal on December 5, 2025.

Appellant’s pro se notice included an email attachment identifying two issues for review: “due process procedural irregularities,” and a judicial conflict of interest. Notice of Appeal, 12/5/25. Appellant also included a “Motion to Reinstate Appeal Rights Nunc Pro Tunc” (Motion to Reinstate), claiming that the trial court failed to notify her of its order denying her post-trial motion. Motion to Reinstate, ¶ 3. Appellant claimed a breakdown of the court’s operations. Id. ¶ 4.

The trial court, on December 11, 2025, filed an order directing Appellant to file a Pa.R.A.P. 1925(b) concise statement of errors complained of on appeal (Rule 1925 Order). The Rule 1925 Order stated it was served on Appellant by first-class mail, at the following address:

Nikki Williams Pro-Se Plaintiff 148 W. Flagstone Drive Newark, DE 19702

Rule 1925 Order, Proof of Service.

On January 5, 2025, Appellant, “by and through her lay representative [Ms.] Brice,” filed an application to amend the record. On January 14, 2025, Ms. Brice, acting as Appellant’s “Trial Observer/Case Advocate,” again filed an application to amend the record. Application to Amend, 1/14/25, at 2. This Application included a purported “Emergency Notice of Continued

Interference” (Emergency Motion), authored by Ms. Brice, claiming the trial court improperly contacted Appellant by sending Appellant a letter requesting a Pa.R.A.P. 1925(b) concise statement. Emergency Motion, 1/14/26, at 1. Appellant claimed the trial court no longer had jurisdiction over the matter, and that its actions could be considered harassment or obstruction of the appellate process. Id. On February 2, 2026, Appellant, through Ms. Brice, filed a third application to amend. Application to Amend, 2/2/26.

On February 2, 2026, this Court entered an order striking Appellant’s applications to amend, stating, in relevant part, the following:

Here, the January 5, 2026[,] and January 14, 2026[,] Applications to Amend were signed by [Ms.] Brice purportedly on behalf of Appellant Nikki Williams. [Ms.] Brice is not a party to this appeal or the underlying action. Importantly, [Ms.] Brice is not a licensed attorney. Because [Ms.] Brice is not a licensed attorney, she cannot file legal papers on behalf of Appellant. David R.

Nicholson, Builder, LLC v. Jablonski, 163 A.3d 1048, 1054 (Pa.

Super. 2017) (setting forth rule that, with very few exceptions, non-attorneys cannot represent parties before Pennsylvania courts and most administrative agencies); see also Bisher v.

Lehigh Valley Health Network, Inc., 265 A.3d 383 (Pa. 2021)

(providing that where [a] court learns that [a] person engaged in [the] unauthorized practice of law, [the] court [is] obligated to take corrective action).

Accordingly, [Ms.] Brice is PROHIBITED from filing any further legal papers with this Court on behalf of Appellant.

The January 5, 2026 “Application to Amend” and the January 14, 2026 “Application to Amend” are STRICKEN.

Order, 2/2/26.

On January 8, 2026, the trial court entered an order deeming Appellant’s issues waived, based on her failure to comply with Pa.R.A.P. 1925(b). Trial

Court Order, 1/8/26. On February 2, 2026, the trial court filed an opinion again deeming Appellant’s issues waived on appeal. Trial Court Opinion, 2/2/26, at 1. In the interim, this Court directed Appellant to show cause why her appeal should not be deemed untimely filed. Order, 2/1/26. Appellant filed a pro se response to this Court’s order. This Court discharged the rule, referring disposition of the issue to the merits panel.

Appellant presents the following issues for our review:

1. Whether defects in notice and mailing of post-trial orders, including returned mail noted on the docket and no evidence of re-sending or alternate notice, fail[] to satisfy Pa.R.C.P. 236 and due-process requirements that notice be reasonably calculated to inform Appellant of critical decisions, thereby prejudicing her ability to seek timely relief[;]

2. Whether Appellant was denied due process and a fair civil trial where the trial court permitted a third-party witness to testify about an alleged prior “accident” at Appellant’s former workplace[,] based on a paper the witness admitted Appellant did not write, whose author and source she did not know, without any police report or authenticated company records, contrary to Pa.R.E. 401 403, 602, and 802, and where that testimony was used to attack Appellant’s character and credibility in a rear-end collision case that [Espada]admitted he caused[;]

3. Whether the verdict should be vacated or a new trial granted where the defense introduced a late, undocumented narrative about an alleged prior “accident” at a former job, and the trial court failed to properly limit or exclude evidence lacking foundation or relevance, resulting in unfair prejudice and confusion of the issues in violation of Appellant’s rights under U.S. CONST. amend. XIV and PA. CONST. art. 15 § 11[;] and

4. Whether Appellant’s right to full and fair post-trial review was compromised where trial counsel withdrew immediately after an adverse verdict, refused to pursue post-trial relief despite substantial trial irregularities, and defense counsel later sent a

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