Brown, M. v. Zhang, T., Brown, M. v. Zhang, T. No. 1399 EDA 2016

Mona Lisa Brown sued Tian Xiao Zhang for negligence after a slip-and-fall on property Zhang owned; complaint filed April 17, 2014.
Zhang proceeded pro se, prevailed at arbitration, but Brown timely appealed; a jury later returned a $175,000 verdict for Brown on April 14, 2015.
Zhang (now with counsel) filed untimely post-trial relief; the trial court dismissed it as untimely and an initial appeal was dismissed for procedural noncompliance.
On November 30, 2015, Zhang moved to dismiss for lack of subject matter jurisdiction, arguing Brown failed to join an indispensable party: Zhang’s wife, whom he contended was a co-owner of the property.
The trial court denied the motion, holding the judgment was in personam and that the nonparty wife’s interests were not sufficiently impacted to render her indispensable; Zhang appealed and this Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court lacked subject-matter jurisdiction because an indispensable party (co-owner) was not joined	Brown implicitly: suit against Zhang individually was proper and judgment could proceed	Zhang: his wife was a co-owner and her absence is a non-waivable jurisdictional defect that nullifies the judgment	Court held no jurisdictional defect; absent wife was not indispensable because judgment was in personam and would not impair her property rights

Sabella v. Appalachian Dev. Corp., 103 A.3d 83 (Pa. Super. 2014) (failure to join indispensable party implicates subject-matter jurisdiction)
Mechanicsburg Area Sch. Dist. v. Kline, 431 A.2d 953 (Pa. 1981) (factors for determining indispensability of absent parties)
Grimme Combustion, Inc. v. [unnamed], 595 A.2d 77 (Pa. Super. 1991) (absent party is not essential if no redress sought against it)
Insilco Corp. v. Rayburn, 543 A.2d 120 (Pa. Super. 1988) (distinction between in rem and in personam judgments)
Johnston the Florist, Inc. v. Tedco Constr. Corp., 657 A.2d 511 (Pa. Super. 1995) (final judgment docketing can perfect appellate jurisdiction)