Gussom, R., Aplt. v. Teagle, M., 247 A.3d 1046

July 25, 2016: motor-vehicle accident between Gussom (plaintiff) and Teagle (defendant).
April 26, 2018: Gussom filed a negligence complaint within the two‑year statute of limitations.
May 4, 2018: plaintiff’s initial attempt to serve at a Philadelphia address failed; affidavit of non‑service filed May 9, 2018; plaintiff took no further documented steps before the limitations period expired.
August 22, 2018: plaintiff filed a praecipe to reinstate the complaint (after the limitations period would have run); defendant’s counsel entered appearance Aug. 13, 2018; defendant filed preliminary objections Sept. 10, 2018 asserting improper service.
Trial court dismissed the complaint with prejudice on Oct. 3, 2018 for failure to prove a good‑faith effort to effectuate service; plaintiff’s motion for reconsideration was denied; Superior Court affirmed; the Pennsylvania Supreme Court granted review and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plaintiff made the required "good‑faith" effort to effectuate service so that the timely filing tolled the statute of limitations	Gussom: Lamp/McCreesh require excusing technical missteps where there is no intent to stall and no prejudice; her attempts (initial attempt, affidavit of non‑service, later certified mail and service on a relative) show good faith	Teagle: plaintiff bore the evidentiary burden to prove diligent, timely service efforts; she failed to present evidence and did not give him actual notice before the limitations deadline	Court: plaintiff failed to meet her evidentiary burden to show diligent, good‑faith efforts and produced no proof of actual notice; dismissal within trial court’s discretion was proper

Lamp v. Heyman, 366 A.2d 882 (Pa. 1976) (writ/complaint tolling limited by requirement that plaintiff not "stall the judicial machinery")
Farinacci v. Beaver County Indus. Dev. Auth., 511 A.2d 757 (Pa. 1986) (plaintiff bears evidentiary burden to show good‑faith efforts to notify defendant)
McCreesh v. City of Philadelphia, 888 A.2d 664 (Pa. 2005) (clarifies that technical defects may be excused when defendant had actual notice and was not prejudiced; courts should dismiss only for intent to stall or prejudice)
Cintas Corp. v. Lee’s Cleaning Servs., Inc., 700 A.2d 915 (Pa. 1997) (proper service is prerequisite to personal jurisdiction)
Englert v. Fazio Mech. Servs., Inc., 932 A.2d 122 (Pa. Super. 2007) (intermediate‑court application requiring diligence in service efforts)
Devine v. Hutt, 863 A.2d 1160 (Pa. Super. 2004) (plaintiff’s neglect or mistake can indicate lack of good faith)
Bigansky v. Thomas Jefferson Univ. Hosp., 658 A.2d 423 (Pa. Super. 1995) (discusses plaintiff’s burden to show reasonable efforts to serve)