Manufacturers & Traders Trust Co. v. Greenville Gastroenterology, SC, 108 A.3d 913

Background

In 2007 Greenville Gastroenterology and Peter and Angela Kim (Illinois residents) leased a laser hair‑removal machine from De Lage Landen (now M&T Bank); M&T sued for lease default.
Appellants filed preliminary objections asserting lack of personal jurisdiction in Pennsylvania and that the attached lease copy was illegible; the trial court sustained the objections and dismissed the case on May 23, 2011.
On day 29 after dismissal, M&T filed a motion for reconsideration and a notice of appeal; the trial court said it could not grant reconsideration because §5505’s 30‑day period had expired and asked the Superior Court for leave.
M&T discontinued its appeal; 85 days after dismissal the trial court granted reconsideration, vacated the dismissal, overruled the preliminary objections, and the case proceeded to a non‑jury trial resulting in judgment for M&T.
Appellants challenged the late reconsideration as void; the Superior Court held the trial court lacked authority to grant reconsideration after 30 days, vacated M&T’s judgment, and remanded with instructions to enter judgment for Appellants.

Issues

Issue	Plaintiff's Argument (M&T)	Defendant's Argument (Kims/Greenville)	Held
Whether trial court could grant reconsideration more than 30 days after final order	Filing and then discontinuing an appeal removed §5505’s 30‑day limit; equitable/inherent powers allowed late reconsideration	Court lost jurisdiction after 30 days; untimely reconsideration is void except for narrow extraordinary causes	Trial court lacked authority; late reconsideration and ensuing proceedings void — judgment vacated
Whether "extraordinary cause" or equitable relief justified untimely reopening	Court’s statement reasonably induced discontinuance; equitable relief should apply	No extraordinary cause shown; any reliance on court statement was not reasonable; mistakes by counsel or ordinary neglect insufficient	No extraordinary cause or equitable basis; prior precedents distinguishing true court‑notice errors control; relief denied
Whether trial court’s inherent authority permitted substantive reversal after 30 days	Inherent power to correct court mistakes allowed reversal of its prior ruling	Inherent authority limited to patent/technical record errors, not substantive changes after §5505 period	Inherent authority did not permit substantive reversal; only obvious clerical errors may be corrected anytime
Legibility of contract and damages (raised but not decided)	M&T argued lease copy and damages evidence supported recovery	Appellants argued illegible contract and challenged damages measure	Not reached — Superior Court resolved case on jurisdictional ground and declined to address these issues

Key Cases Cited

Simpson v. Allstate Ins. Co., 504 A.2d 335 (Pa. Super. 1986) (finality rule: trial court loses power to alter contested final judgments after appeal period absent extraordinary cause)
Great Am. Credit Corp. v. Thomas Mini‑Mkts., 326 A.2d 517 (Pa. Super. 1974) (court oversight that deprived party of notice may justify opening final judgment)
First Union Mortgage Corp. v. Frempong, 744 A.2d 327 (Pa. Super. 1999) (judgment procured by fraud may be opened at any time)
Estate of Gasbarini v. Medical Center of Beaver County, Inc., 409 A.2d 343 (Pa. 1979) (attorney suspension that deprived party of appellate rights can justify reopening)
Luckenbaugh v. Shearer, 523 A.2d 399 (Pa. Super. 1987) (ordinary counsel neglect or postal mishaps generally not "extraordinary cause")
Manack v. Sandlin, 812 A.2d 676 (Pa. Super. 2002) (inherent authority permits correction of patent clerical errors but not substantive post‑judgment changes)
ISN Bank v. Rajaratnam, 83 A.3d 170 (Pa. Super. 2013) (enumerating limited circumstances permitting modification of final orders after 30 days)
Commonwealth v. Holmes, 933 A.2d 57 (Pa. 2007) (inherent power cannot be used to swallow statutory limits like §5505)