The Power of Saying “I’m Sorry”.

By saying “I’m sorry” soon and with sincerity, the City did more to rehabilitate its tattered emergency response reputation than any of the excuses made for the horrendous job of snow removal that we all observed with our own eyes.

In Pittsburgh, during the recent snow emergency, Curtis Mitchell needed an ambulance. Beginning Friday evening, as heavy snow began to fall, he was experiencing a heart attack. He and his girlfriend called 911 ten times during the next two days. Three times the paramedics arrived to a location within apparent walking distance but could not get to the house. The emergency operator asked Mitchell’s girlfriend to walk him to the ambulance on more than one trip, but were told that he could not make it. Each time the ambulance left. Curtis died on Sunday morning.

The City of Pittsburgh received a great deal of deserved criticism for the handing of this case. Rather than make excuses, the City’s Public Safety Director apologized to the family and stated flatly that this performance was unacceptable. He followed up by announcing procedures, including deploying fire trucks, in the event that such an emergency happened again.

In this era of litigation, it is refreshing to hear someone admit that the measures taken were not acceptable and implement changes. Public officials, corporate officers and others with something to lose are often counseled by their attorneys to be silent. This might be good instructions for subordinates, but there is little to be gained in the long run when the facts speak, no, scream, for themselves.

By saying “I’m sorry” soon and with sincerity, the City did more to rehabilitate its tattered emergency response reputation than any of the excuses made for the horrendous job of snow removal that we all observed with our own eyes. And of course, the death of Curtis Mitchell was in large part due to the slow and uncoordinated start by snow crews in getting snow off main roads before it was packed into ice. The eventual apology by the Mayor for the snow removal fiasco, which came only after other tactics had failed, was far less effective.

And you thought this post was going to be about Tiger Woods. The web must be full of commentary on that subject by now. Google it.

CLT

Category: Uncategorized

Love Thy Neighbor! Snowmageddon Edition.

SNOWMAGEDDON CREATES OPPORTUNITIES FOR ACTS OF KINDNESS.

We are deep into Phase 2 of Snowmageddon — ice — and I am increasing impressed and thankful for the acts of kindness that I have both observed and received in my own neighborhood.

The most recent example was yesterday, when a mountain of snow, ice and roof tile descended from my roof and buried my more or less cleanly shoveled driveway. My good hearted neighbor, who could easily have just gone from car to house without my even noticing him, grabbed his snow shovel and started digging with a vengeance.

There will be plenty of opportunities for reciprocal charity coming up. The ice phase is not over. Phase 3 — flood — is just beginning.

CLT

Category: Uncategorized

ENCORE POST: Can You Name the Presidents Who Argued Before the US Supreme Court?

TO CELEBRATE OUR NEW LOOK, PITTSBURGH LEGAL BACK TALK IS REPRISING SOME OF THE BEST POSTS FROM THE LAST 18 MONTHS. THIS POST ORIGINALLY APPEARED IN JULY 2009. CONTRARY TO WHAT MANY MIGHT EXPECT, ABRAHAM LINCOLN WAS ONE OF THAT SELECT FEW.

Eugene Volokh, law professor/blogger, asked readers of his heavily-read blog,The Volokh Conpiracy, how many presidents had argued before the US Supreme Court, either before or after being President. Here’s what they came up with:

1. John Quincy Adams in the famous case of US v. Amistad, 40 US 518 (1841), involving slaves aboard a ship that landed in a US port. You may have seen the movie.

2. Abraham Lincoln in Lewis v. Lewis, 48 US 776 (1849). Lincoln, who despite his PR was one of the leading trial lawyers in Illinois, argued this case a few days after his term in the US House of Representatives expired.

3. Richard Nixon in Time, Inc. v. Hill, 385 US 374 (1967).

4. James A. Garfield in Ex Parte Milligan, 71 US 2 (1866), a leading case in US Constitutional Law that held that it was unconstitutional to try a citizen by a military tribunal when a civilian court was available.

5. William Howard Taft, who as Solicitor General between 1890 and 1892, would have had the opportunity to personally argue many cases before the Supremes in behalf of the government. He was also Chief Justice (the only US President to hold both offices)after his presidency, serving until his death in 1930.

Other names were mentioned by Volokh’s readers, but without citing a case or other circumstance to support the claim. I checked biographies of those presidents and could find no mention of argument before the high court. So there may be others. If any reader knows of a president who argued before the US Supreme Court, please let me know.

CLT

Category: Uncategorized

ALERT! pfishing Expedition.

If you have an account on Twitter, take note of this warning, posted on the Mashable website.

Mashable advises that if you think you have been compromised, change your password.

CLT

Category: Uncategorized

ENCORE POST: Landlord-Tenant: Its a New Ball Game when the Case is Appealed to Arbitration.

TO CELEBRATE OUR NEW LOOK, PITTSBURGH LEGAL BACK TALK IS REPRISING A FEW OF THE BEST POSTS FROM THE PAST 18 MONTHS. THIS POST SUMMARIZED WHAT A LANDLORD OR TENANT MIGHT WANT TO KNOW ABOUT STAGE TWO OF A LANDLORD-TENANT LAWSUIT IN PENNSYLVANIA.

THE NOTICE OF APPEAL: SO MUCH TO DO AND SO LITTLE TIME TO DO IT!

When a landlord is awarded possession of the leasehold by the Magisterial District Judge, the tenant may appeal to a board of arbitrators, but there are a few things to know.

Landlords and tenants frequently represent themselves in arbitration proceedings, sometimes effectively. However, too often they don’t because the procedure is a mystery to them and there are limits to the ability and inclination of the prothonotary, the judge or the arbitrators to help out a litigant who is trying to plead or prove a case and doesn’t know how to do it. If you must depend upon the kindness of others to guide you along, you may soon be in big trouble.

First, while judgments for damages may be appealed within 30 days, judgments for possession must be appealed within 10 days. This means that, as a practical matter, the tenant is going be appealing both possession and damages in 10 days, since there is no point in filing one appeal in 10 days and another in 30. However, if the tenant discovers that it is too late to appeal an order of possession, or if he is voluntarily relinquishing possession, he could still appeal the damages if the 30 day period has not run.

For the tenant, who is almost always the defendant, starting the appeal process requires filing of a notice of appeal with the prothonotary (Department of Court Records, Civil Division, in Allegheny County), using a short form which the prothonotary provides. He also files a praecipe for a rule on the landlord-appellant to file a complaint within 20 days, also provided by the prothonotary.

If the tenant meets certain financial guidelines, he/she can qualify to file the appeal without paying the filing fees. Once again, the prothonotary supplies forms, and the tenant-appellant goes to the motions judge, obtains an order of court authorizing the filing in forma pauperis and returns the signed order and other paperwork to the prothonotary.

However, there is one more hurdle for the tenant-appellant to jump. In order to obtain a writ of supersedeas from the order below granting possession, the tenant must agree to place each month’s rent in escrow with the prothonotary as it accrues on a specified date. If the tenant-appellant fails to pay the rent into escrow, the prothonotary revokes the writ of supersedeas and sends a notice authorizing the landlord to proceed under the writ of possession issued by the Magisterial District Judge.

So the tenant gets an opportunity to convince a board of three arbitrators not to grant possession to the landlord, but he/she gets it at a price. He/she must pay rent each month until the hearing and the rent will be available to the landlord to defray the part of the judgment for rent that accrues while waiting for the arbitration hearing.

Once all of this has been accomplished, it is the landlord’s turn.

A WELL DRAFTED COMPLAINT IS MORE THAN A WORK OF LITERATURE, IT IS OFTEN A NECESSITY.

The Landlord is now faced with the task of drafting a complaint. Many self-represented landlords think that this involves merely restating the averments in the complaint before the Magisterial District Judge. The prothonotary has provided a handy form which seems to cover everything. In a simple case, it may. But even in a simple case, things may turn out not to be so simple.

At a minimum, a written lease must be attached to the complaint. Any other writings, such as notices of default, upon which the claim relies, must be attached as well.

The landlord can probably get past the prothonotary by filing a very rudimentary complaint. And he/she may even win the case with one. But if the landlord is unlucky enough to have a tenant that qualifies for Neighborhood Legal Services in Allegheny County or the equivalent in other counties, or hires a lawyer who knows more than the basics about landlord-tenant law, the landlord-plaintiff could be in for a rude surprise.

Instead of immediately filing an answer, the defendant may file preliminary objections. Suddenly, the self-represented plaintiff finds him/herself being required to appear before a judge (in Allegheny County it will be Judge Wettick) to defend the complaint from legal arguments he/she doesn’t even understand. Time to hire a lawyer â€” pronto!

The truth is, the form complaint provided by the prothonotary is not satisfactory to cover the facts of a reasonably complex case and if a plaintiff has one of those, he should hire a lawyer to draft a proper complaint. This lawyer may ultimate pay for him/herself by finding claims the plaintiff has overlooked. For example, does the lease authorize the landlord to collect attorney’s fees?

ANSWER, NEW MATTER, COUNTERCLAIM

Once the complaint is filed and served, the ball is back in the defendant’s court. At minimum, the numbered allegations in the complaint must be answered with specificity within 20 days. Failure to do so could result in default judgment being entered â€” another complete topic too broad to discuss here. However, the defendant may wish to say more than a response to the individual allegations of the complaint. There may be defenses that involve other facts. For example, the lease might contain provisions not mentioned in the complaint which provide a defense or mitigation to the tenant.

But most important, the tenant-defendant may have claims against the landlord-plaintiff. This could take many forms. The premises may have not been habitable during all or a portion of the lease term â€” perhaps due to a non-functioning furnace or broken pipes, toxic mold, roach infestation. Again, this could be a topic for another complete post â€” strike that â€” a dozen posts.

Once again, the mechanics of pleading and proving a counterclaim may be beyond the capabilities of many, maybe most, defendants. There are rules to follow and we’ve already discussed what might happen when a litigant doesn’t know how to follow the rules. If you want to make a counterclaim and can afford to pay a reasonable fee, hire a lawyer.

The Plaintiff must file a reply to new matter and answer the counterclaim. Failure to do so may, quite frankly, lose the case. For example, if the new matter states that the plaintiff did not give mandatory notices and the plaintiff does not reply, the plaintiff will be bound by the statements of fact in the new matter. Thus, even though the plaintiff is prepared to present proof that notices were given, the defendant’s lawyer can successfully object to proof of facts contrary to the unanswered averments and prevent the plaintiff, at least temporarily, from regaining possession.

WHAT A NUISANCE! EVICTING A TENANT TO AVOID PAYING FOR POLICE VISITS

The City of Pittsburgh and at least one other municipality (Etna) have enacted ordinances that enable the municipality to declare properties a nuisance after three police calls. The matters can be relatively trivial, such as loud domestic arguments. If the unruly tenant has a neighbor who likes to call the police to solve noise problems, three strikes or more can accrue before the landlord is even aware that a problem exists.

At that point, the landlord is required to solve the problem or pay a fine every time the police are summoned. The most obvious solution is to terminate the lease.

However, if the landlord wishes to terminate the lease for non-economic reasons, the lease must have a provision that permits such a termination and it must be plead in the complaint. For example, if the rent is being paid by Section 8, there will probably be no arrearage and thus no grounds for early termination unless another lease provision has been violated. Section 8 tenants are often eligible for free representation by Legal Services. These lawyers know their stuff and will make short work of a poorly plead, poorly proven case involving termination on non-economic grounds. Moreover, the landlord is required by statute to give proper notice to Section 8 of the lease violation and failure to do so could put the landlord back at square one, forced to start over.

THE ARBITRATION HEARING

An arbitration hearing is less formal that a trial before a judge, but more formal than a hearing before a Magisterial District Judge. Too many self-represented parties learn this fact for the first time while trying to present their case.

Although the arbitrators may be understanding and even assist bewildered litigants (up to a point), rules of procedure and evidence do apply and a self-represented party may discover that he/she is unable to present the essential elements of the case, even after repeated attempts, and never really comprehend why. For example, under Rule of Civil Procedure 1305, many kinds of documents can be introduced into evidence without the kind of foundation that may be required in a trial before a judge. These can include repair estimates when the party who prepared the estimate is not present to testify and be cross examined. But such documents must be furnished to the opponent at least 20 days prior to the hearing. If the opponent is represented by counsel, a meritorious case can be derailed under Rule 1305 before it even starts.

Be advised that, in Allegheny County, at least one or probably two of the three arbitrators will be lawyers with significant experience in landlord tenant matters and will have heard numerous other cases. They will understand the issues and evidence properly presented, but they are not mind readers. Your case must still be organized, concise and properly presented. If you put them to sleep, obscure the message with irrelevancies or squabbles over small points or make any of the blunders set forth above (or others too numerous to mention), you could turn a winning case into a loser. It happens every day.

SLAMMING THE DOOR ON NO SHOWS.

If the other party doesn’t show up, you may still be required to present the basic elements of your case. When you do, an award will almost certainly be entered in your favor. Then, assuming that the complaint contains certain magic language at the beginning (this language is in the form the prothonotary provides), you will be entitled to close off the possibility of an appeal to common pleas court.

The arbitration staff will provide you with another form which you will take to the motions judge. After hearing some bare bones testimony, the judge will enter a verdict in your favor â€” closing off further appeal.

Now, if the other party shows up later with an excuse, you may be required to appear again before the judge to argue against the other party’s motion to reconsider. Heart attacks or car accidents on the way to court will probably be good enough to get them a new hearing. Poor communication or record keeping will not.

THE COST OF DOING BUSINESS

Representing yourself before a Magisterial District Judge is probably safe enough. Either party can appeal. However, as pointed out above with concrete examples, there are significant risks in being your own lawyer at the arbitration level.

The landlord should expect that, over the course of time, some tenants must be evicted and the cost of performing this function should be factored into the equation, just as some furnaces or pipes will break, requiring the immediate expenditure of funds.

In the tenant’s case, the decision whether to hire a lawyer may boil down to costs versus potential benefits. If the result is inevitable and you need two months (with rent paid in escrow) to find a new place, hiring an attorney will not change the outcome. But if there are real and substantial damages claimed by either party, or if there is a dispute over the distribution of the security deposit, hiring an attorney may make sense.

In addition, after the case is over, a landlord may be entitled to garnish the ex-tenant’s wages. This option is relatively new and is not yet used very often. There are limiting factors to be considered and when the judgment is relatively small or the ex-tenant is receiving modest wages, the economic factors may or may not make garnishment possible or worth doing. Nevertheless, this potential changes the game. A tenant may wish to make a payment arrangement to avoid a potential wage garnishment and a landlord may wish to settle to reduce cost of recovering the judgment amount. Lawyers can help the parties reach a settlement and write an agreement that will accomplish the task.

CLT

Category: Uncategorized

The Buzz About Google Buzz.

The introduction of Google Buzz, a new social media feature of gmail accounts, has raised privacy concerns. A Complaint filed with the FTC and a class action suit filed in California are the first shots fired in the battle.

Unless you are colorblind, you’ve probably noticed that PLBT has installed a button for Google Buzz at the end of each post — even the ones that were written long before Google ever buzzed. If you are a gmail account user, you know by now that you can share the post with your frequent email correspondents. Not being a gmail customer, the author hasn’t tried to use Google Buzz. Moreover, reviewing the latest web gadgets is not the mission of Pittsburgh Legal Back Talk. But there are plenty of on-line venues, such as PC World, who will tell you all that you want to know and will give you the pros and cons of buzzing.

However, there is a legal slant on the Google Buzz phenomenon. Jurist reports that a consumer group has filed a complaint with the Federal Trade Commission claiming that the service invades the privacy of its customers by causing unsuspecting Buzz-users (Buzzers?) to reveal private information to the whole world wide web, like the entries in their gmail address book.

A similar theme appears in a class action suit filed in California reported by the Wall Street Journal Law Blog.

Google reacted quickly to these concerns and added a feature to Buzz enabling customers to opt out or limit the specific entries on the Buzz list even before the FTC complaint was filed. However, the FTC complaint is demanding that Google require gmail users to “opt in” to Buzz. Whether Google may may decide to adopt additional measures remains to be seen.

Of course, privacy is a two sided coin. The recipient’s privacy may be at issue also. Spammers and their robotic slaves are constantly trolling the web for email addresses. Should we hesitate to correspond with gmail accounts in the future? Obviously businesspeople and professionals,especially lawyers, with gmail should opt out of Buzz, just in case.

CLT

Category: Uncategorized

Encore Post: Obscenity Prosecution Tells a Sad Story

TO CELEBRATE OUR NEW LOOK, WE ARE REPRISING SOME OF THE BEST POSTS OF THE PAST 18 MONTHS ON PITTSBURGH LEGAL BACK TALK. THIS POST DREW MANY COMMENTS, INCLUDING NUMEROUS ROBOTIC COMMENTS.

FIRST POSTED ON AUGUST 19, 2008.

The Wall Street Journal Law Blog commented on a Western Pennsylvania Federal Prosecution this past week. From the Pittsburgh Post Gazette account linked to the blog, Karen Fletcher of Donora in Washington County, didn’t sound much like a predatory internet child pornographer. She sounded like a writer. She wrote stories on a for-members-only internet website called “Red Rose Stories” involving brutal sexual crimes against children. Fletcher said she originally wrote them as self-therapy for memories of an abused childhood.

Fletcher plead guilty and received five years probation, with the first six months to be served under house arrest. In her plea agreement, Fletcher admitted that the specified writings in “The Red Rose” were obscene under the test adopted by the United States Supreme Court:

“The defendant, Karen Fletcher, agrees that each of the six
stories (which underlie Counts One through Six of the Indictment),
when each is considered as a separate work, satisfies the following
test for obscenity enunciated in Miller v. United States, 413 U.S.
15, 24 (1973) :
1. An average person, applying contemporary community
standards, would find that the material taken as a whole
appeals to the prurient interest;
2. An average person, applying contemporary community
standards, would find that the material depicts or
describes sexual conduct in a patently offensive way; and
3. A reasonable person would find, taking the material as a
whole, that it lacks serious literary, artistic,
political or scientific value.
The defendant, Karen Fletcher, also acknowledges that the six
charged stories are not the only material, posted to the red-rosestories
web site, which meets the test for obscenity.”

Nevertheless, the arguments made by the prosecution, as reported in the WSJ Law Blog, sound like a case that might have once been made against the writings of D. H. Lawrence or James Joyce. Of course, we will probably never know whether Fletcher’s works had any literary merit. We can’t read them.

Had Fletcher been willing to face the possibility of a serious jail sentence, would she have prevailed, either at trial or on appeal, under the First Amendment? We will never know the answer to that question either. To read the Wall Street Journal Law Blog comment: Click here.

THEN, IN JULY 2009 WE FOLLOWED UP ON THE STORY, WHICH HAD CONTINUED TO DRAW COMMENTS.

Last August, I wrote a post entitled “Obscenity Prosecution Tells a Sad Story.”It is about a woman who wrote stories involving child sexual molestation and posted them on a website known as “Red Rose”, which required a membership fee of $10.00. A summary of the facts appears in a Wikipedia profile of Mary Beth Buchanan, the US Attorney for the Western District of Pennsylvania, which featured the Fletcher case as one of her most controversial prosecutions.

Since then, this post has drawn hundreds of comments. The overwhelming majority were obvious robotic comments, often with embedded links to porno sites. Many others simply stated that it was a good post, but made no substantive comment. They have been increasing in frequency and I have been noticing that more of them seem to be coming from real people, rather than robots.

Today, a member of a social web site (Wolfbook) appears to have sent links to the story to his friends and some of them are sending me messages. Whereas, I had been deleting all comments on this story, I’ve decided to start posting comments that are substantive and not selling something.

After re-reading “Obscenity Prosecution Tells a Sad Story”, I think that the topic is worth revisiting. Moreover, it has been made timely by the accusations of overzealous prosecution by Buchanan’s office that have lately been voiced from many quarters.

Thank you, Wolfbook members, for your compliments on the post, but I’d really like to hear what you (or anyone else) has to say about the outcome of this case.

Back Talk Requested.

CLT

Category: Uncategorized

North Carolina Innocence Commission is a Model to be Followed.

Jurist reports that the North Carolina Innocence Commission, a special panel formed in 2006 as an appeal of last resort when appeals are exhausted, has yielded its first exoneration since its founding in 2006. The panel hears cases with new evidence and can forward a case to a three judge panel of the Superior Court, who must rule unanimously for acquittal.

In Pennsylvania, we have long had the right to post conviction hearings at which new evidence can be raised. However, these appeals go through the common pleas court where the conviction was originally obtained. An independent review commission provides a new perspective, one that is not unconsciously affected by deference to the judge and prosecutors involved and which is especially aware that properly verified DNA evidence can outweigh testimony and circumstantial evidence that appear to be overwhelming.

CLT

Category: Uncategorized

ENCORE POST: Why Blog? 10.5 Good Reasons.

TO CELEBRATE OUR NEW LOOK, PLBT IS REPRISING A FEW OF THE BEST POSTS DURING THE PAST 18 MONTHS.

Lawyers are often advised by marketing professionals to blog because it is good marketing. The AVVO blog recently announced an inexpensive and easy to use blogging vehicle for lawyers. If you have a modest marketing budget, investing in a blog will buy you more effective advertising than any other vehicle, including Google pay per click ads.

But if a lawyer never lands a single new client from blogging, the exercise is still worthwhile. Here are 10.5 reasons why:

1. Self education. In order to write a blog piece you need to read and find out what’s going on in the law and in the world. Doesn’t continuous self-education make a better lawyer?

2. Reinforcement of learning. The best way to remember newly-acquired information is to use it. The best way to really understand a concept is to explain it. Blogging forces you to do both.

3. Getting away from the old me-me-me. The essence of a law firm website is telling potential clients how great you are. That can get tiresome â€” with legal advertising websites rivaling the leading sleep aids for induced drowsiness. A blog looks outward at the world, not inward at the firm.

4. Practice makes perfect. If you wish to be a persuasive and polished writer, you must practice.

5. Busman’s Holiday. It is surprising how relaxing it can be after a day of toil to write something. You may not think so until you start to really get into writing your blog. Meanwhile, you are thinking and writing about work related matters.

6. Making Friends and Influencing People. Through your blog (assuming you are diligent and have good content) I guarantee that you will make the acquaintance of people worth knowing. They will consider you smart, informed and very persuasive â€” otherwise, they wouldn’t be reading your blog.

7. The Bully Pulpit. When you have a gripe, a beef or a strongly-held opinion, shazam! You have a forum!.

8. Developing New Expertise. All that reading and writing, scrounging for topics and keeping your ear to the ground to identify advancing trends, will cause you to develop and expand expertise on new topics. Moreover, you don’t have to tell anyone you know something about a field of the law, your blog does.

9. Developing a Portfolio. All the posts you ever wrote will be on the internet for a long time. You’ll receive comments popping up on posts written many months or even years ago â€” ones you’ve actually forgotten you wrote. You’ll find yourself saying to people: “Read my blog post(s) on the subject.”

10. Self fulfillment. You will feel a sense of accomplishment when you post something really good.

10.5 Strange as it may seem, you could be a force in someone else’s life. Someday, if you are lucky, someone will write to you or tell in person that you helped changed his or her life. Teachers often hear it years later from students. When you blog, you are the teacher and who knows who the student may be?

CLT

Category: Uncategorized

Rate the Professor and Pass the Ammunition.

I spotted this one on Twitter, too good not to share. National Review Online discovered the the rate the professor blog was still up with student ratings of that pistol-packing prof. from the University of Alabama, Huntsville, Amy Bishop. If you hurry, you can even read the student comments before the University takes down the Amy Bishop page.

CLT

Category: Uncategorized

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Welcome

CLIFF TUTTLE has been a Pennsylvania lawyer for over 45 years and (inter alia) is a real estate litigator and legal writer. The posts in this blog are intended to provide general information about legal topics of interest to lawyers and consumers with a Pittsburgh and Western Pennsylvania focus. However, this information does not constitute legal advice and there is no lawyer-client relationship created when you read this blog. You are encouraged to leave comments but be aware that posted comments can be read by others. If you wish to contact me in privacy, please use the Contact Form located immediately below this message. I will reply promptly and in strict confidence.

Pittsburgh Legal Back Talk

Legal topics of interest to lawyers and consumers with a Pittsburgh and Western Pennsylvania focus.

1410 Posts and Counting

Categories

The Power of Saying “I’m Sorry”.

Love Thy Neighbor! Snowmageddon Edition.

ENCORE POST: Can You Name the Presidents Who Argued Before the US Supreme Court?

ALERT! pfishing Expedition.

ENCORE POST: Landlord-Tenant: Its a New Ball Game when the Case is Appealed to Arbitration.

The Buzz About Google Buzz.

Encore Post: Obscenity Prosecution Tells a Sad Story

North Carolina Innocence Commission is a Model to be Followed.

ENCORE POST: Why Blog? 10.5 Good Reasons.

Rate the Professor and Pass the Ammunition.

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