Sehl v. Neff, 26 A.3d 1130

Sehl filed a complaint in Philadelphia County against Neff (tort) and State Farm (contract) arising from a Montgomery County car accident.
Neff raised preliminary objections alleging improper venue.
The trial court sustained the venue objection and transferred the case to Montgomery County.
Sehl moved for reconsideration, which the court denied on July 20, 2010.
On appeal, issue was whether Rule 1006(c)(1) permits Philadelphia venue for Neff given potential joint liability with State Farm.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Venue proper under 1006(c)(1) for Neff	Sehl argues joint liability with State Farm makes venue proper	Neff argues claims are separate; no joint liability to justify venue	Venue improper for Neff; affirmed

Forrester v. Hanson, 901 A.2d 548 (Pa. Super. 2006) (abuse-of-discretion standard for venue transfers)
Ro-Med Construction Co., Inc. v. Clyde M. Bartley Co., Inc., 361 A.2d 808 (Pa. Super. 1976) (joint or several liability allows venue in a county where any defendant may be served)
Tarasi v. Settino, 298 A.2d 903 (Pa. Super. 1972) (single action may be brought in county of one defendant if joint liability exists)
Meyer v. Heilman, 469 A.2d 1037 (Pa. 1983) (permissibility of joinder subject to jurisdictional requirements)
Mayer v. Garman, 912 A.2d 762 (Pa. 2006) (joinder rights must comply with venue rules)
Deyarmin v. Consol. Rail Corp., 931 A.2d 1 (Pa. Super. 2007) (venue objections treated as jurisdictional challenges)
Hileman v. Morelli, 605 A.2d 377 (Pa. Super. 1992) (interpretation of joint/joint and several liability for venue)
Glomb v. Glomb, 530 A.2d 1362 (Pa. Super. 1987) (implication of joint liability enabling venue in proper county)