Robinson Coal Co. v. Goodall
72 A.3d 685
| Pa. Super. Ct. | 2013Background
- Robinson seeks replevin for 192,000 tons of coal left at Goodall’s washing facility and breach-of-contract damages for escrow funds under a 1999 agreement.
- Robinson mined Frame Property coal Jan 2000–Aug 2002; 192,000 tons remained at Goodall’s washing facility after mining ceased.
- Agreement required washing of non-saleable coal and payment of $9 per ton washing fee and $1.50 per ton royalty; 50 cents per ton escrow deposit
- Escrow funds were to be divided equally between Goodall and Robinson upon completion of mining and payment of all obligations.
- 1999 contract had been partially litigated in a 2003 breach/conversion action; prior judgment on escrow funds was reversed on appeal; later litigation proceeded as now before the court.
- Trial court held counts barred by statute of limitations and res judicata; Robinson appeals.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether counts are barred by statute of limitations | Robinson argues for application of a longer period | Goodall asserts two-year limit applies | Two-year limit applies to replevin; time expired |
| Which statute governs for the coal left at washing facility | Robinson claims 5530 governs | Court should apply 5524(3) as coal is personal property | Coal is personal property; 5524(3) applies; replevin untimely |
| Whether res judicata bars Robinson’s contract-count claim | Prior litigation was different claim | Escrow ownership already litigated and decided | Res judicata bars contract claim; proper analysis applied |
| Whether illegality defense estoppel precludes defenses | Illegality of washing operation should preclude defenses | Illegality defense unavailable to plaintiff; not raised previously | Illegality defense not available to bar limitations or res judicata; waived |
| Whether abandonment/open, notorious possession established | Robinson abandoned coal but argues facts | No abandonment evidence sufficient | Not decisive; limitations barred replevin; unresolved facts irrelevant to holdings |
Key Cases Cited
- Stoeckinger v. Presidential Financial Corp. of Delaware Valley, 948 A.2d 828 (Pa.Super.2008) (definition of res judicata elements; claim preclusion)
- Dempsey v. Cessna Aircraft Co., 439 Pa.Super. 172, 653 A.2d 679 (Pa.Super.1995) (identity-of-thing, cause, parties; preclusion)
- Chada v. Chada, 756 A.2d 39 (Pa.Super.2000) (res judicata applies to claims that could have been litigated)
- Llewellyn v. Philadelphia & Reading Coal & Iron Co., 308 Pa.497, 162 A.2d 429 (Pa.1932) (coal severed becomes personal property; applies to statute timing)
- Rittenhouse v. Barclay White Inc., 625 A.2d 1208 (Pa.Super.1993) (illegality-of-contract doctrine; limits defenses)