Claypool, L. v. Claypool, O., 616 WDA 2017

Oliver filed a 2011 quiet title action against Lee in Clarion County regarding the 1980 deed to the Property.
The 1980 deed conveyed the Property from Oliver and Elizabeth to Lee; Oliver claimed he used the name Lee Edward Claypool.
Lee contended the 1980 deed transferred the Property from Oliver to Lee, not vice versa.
The 2011 Case was terminated by summary judgment in Lee’s favor on January 4, 2013.
Lee filed a Dragonetti Act action for wrongful use of civil proceedings to recover Lee’s fees from the 2011 Case.
During trial, Oliver sought to read and show Opinions supporting good faith; the court allowed reading portions but not copies to deliberations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the jury should have received the full Opinions during deliberations	Oliver argues jury was prejudiced without copies.	Lee contends court properly exercised discretion.	Discretionary ruling within trial court; no reversible error.
Whether Elizabeth was indispensable; impact on validity of Lee’s judgment	Elizabeth is indispensable to property-ownership interests.	Elizabeth had no surviving interest; not indispensable.	Elizabeth not indispensable; 2011 summary judgment valid; judgment affirmed.

Ratti v. Wheeling-Pittsburgh Steel Corp., 758 A.2d 695 (Pa. Super. 2000) (trial-court evidentiary discretion governs jury deliberations)
Williams v. Lumbermen’s Ins. Co., 1 A.2d 658 (Pa. 1938) (exhibits may or may not be sent to jury; discretion applies)
Kearns v. Clark, 493 A.2d 1358 (Pa. Super. 1985) (admissibility and jury access to exhibits)
D’Ella v. Folino, 933 A.2d 117 (Pa. Super. 2007) (summary judgment finality for purposes of termination)
Orman v. Mortgage IT, 118 A.3d 403 (Pa. Super. 2015) (indispensable-party analysis; subject-matter jurisdiction)
Barnes v. McKellar, 644 A.2d 770 (Pa. Super. 1994) (collateral attack on judgments for lack of jurisdiction)