Knight v. Springfield Hyundai
81 A.3d 940
| Pa. Super. Ct. | 2013Background
- Knight bought a used Hyundai Sonata Feb. 19, 2008 from Springfield Hyundai, financed by DFS, documents included Buyer’s Order with an arbitration clause and a separate RISC.
- RISC contained an integration clause stating it was the entire agreement; arbitration clause appeared only in the Buyer’s Order, not in the RISC.
- Car had prior rental history, multiple owners, inaccurate mileage, prior undisclosed damage, and title/registration fees were not properly addressed by the dealer.
- Knight canceled the RISC in Feb. 2009 due to dealer misconduct but retained the vehicle as security; DFS repossessed the vehicle in Feb. 2009 without notice.
- Knight filed a multi-claim Amended Complaint in Feb. 2010; trial court granted preliminary objections and compelled arbitration; arbitration award favored Knight but the trial court denied vacatur; Knight appealed to challenge arbitration and related rulings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Arbitration enforceability under MVFSA | Knight argues no valid arbitration agreement exists | Appellees contend the Buyer’s Order arbitration clause is enforceable and controls | No enforceable arbitration agreement; RISC subsumes all, making arbitration clause unenforceable under MVFSA |
| Trial court jurisdiction after ruling to arbitrate | Even if arbitration exists, trial court lacked authority to decide non-arbitrable issues | Trial court reserved jurisdiction to handle Preliminary Objections | Trial court erred by enforcing arbitration while attempting to decide non-arbitrable issues; remand proper |
| UTPCPL claims and economic gist | UTPCPL claims are viable and not barred by gist of the action or economic loss doctrine | Gist of the action and economic loss doctrine bar UTPCPL claims | UTPCPL claims not barred; they arise from deceptive practices independent of contract |
| Assignee liability of DFS under Beemus limits | Knight can recover beyond amounts paid under RISC | Assignee liability limited to amounts paid under RISC per Beemus | Knight’s recovery limited to amounts paid under the RISC; DFS not liable for excess |
Key Cases Cited
- Pisano v. Extendicare Homes, Inc., 11 A.3d 651 (Pa. Super. 2013) (two-part test for arbitration enforceability; scope and existence of agreement)
- Gaffer Ins. Co., Ltd. v. Discover Reinsurance Co., 936 A.2d 1109 (Pa. Super. 2007) (arbitration as a threshold jurisdictional question)
- Beemus v. Interstate Nat. Dealer Servs., Inc., 823 A.2d 979 (Pa. Super. 2003) (assignee liability limits to amounts paid under the contract under FTC regulation)
- Mirizio v. Joseph, 4 A.3d 1079 (Pa. Super. 2010) (gist of the action doctrine—tort vs. contract distinction)
- Excavation Technologies, Inc. v. Columbia Gas Co. of Pennsylvania, 604 Pa. 50, 985 A.2d 840 (Pa. 2009) (economic loss doctrine—no pure economic damages in negligence; UTPCPL exception noted)