Already have an account? Sign in instead.
You stay signed in for 30 days on this browser.
Continue with Google Continue with MicrosoftNo account yet? Create a free one.
We sent a six-digit code.
It expires in ten minutes, works once, and only in this browser. Five wrong tries void it. Send another code.
Your account is live and the Cloudflare checks are off for this browser.
17 Pennsylvania opinions name it 3 courts 1990–2025 8 in the last five years
The cases below were cited by Pennsylvania courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Zampana-Barry v. Donaghuegreen2 sentences2022“In determining whether venue is proper under this rule, courts employ a quality-quantity analysis.” Id. (citation and quotation marks omitted); see also Zampana-Barry v. Donaghue, 921 A.2d 500, 503 (Pa Super. 2007) (“A business entity must perform acts in a county of sufficient quality and quantity before venue in that county will be established.”). 2021In determining whether venue is proper under this rule, courts “employ a quality-quantity analysis.” Zampana-Barry, 921 A.2d at 503 . | 4 | 8 |
Purcell v. Bryn Mawr Hospitalgreen2 sentences2024For an example of the application of the quality-quantity analysis, in Purcell v. Bryn Mawr Hospital, 579 A.2d 1282 (Pa. 1990), the trial court determined that venue was proper in Philadelphia County pursuant to Rule 2179(a)(2) based upon the fact that the defendant hospital, which was located in Montgomery County: (a) ha[d] contractual affiliations with residency programs of teaching hospitals in Philadelphia. . .; (b) recruit[ed] and employ[ed] medical residents from the aforementioned Philadelphia teaching hospitals for the performance of services to patients of Bryn Mawr Hospital in Montgo 2023The court below erroneously sustained the additional defendant’s preliminary objections.”); Purcell, 579 A.2d at 1286-87 (reversing the lower courts to hold “venue was improper in Philadelphia County on the grounds that the hospital did not meet the quality-quantity test”). | 3 | 6 |
Shambe v. Delaware Hudson R. R. Co.green2 sentences2025Co., 288 Pa. 240, 246-47 , 135 A. 755, 757 (1927)]: -9- J-S38029-25 [T]he business engaged in must be sufficient in quantity and quality .... 2025Co., 288 Pa. 240, 246-47 , 135 A. 755, 757 (1927)]: -9- J-S38029-25 [T]he business engaged in must be sufficient in quantity and quality .... | 2 | 4 |
Monaco v. Montgomery Cab Co.green2 sentences2023They stress quality and quantity are two independent prongs and that under Monaco, the quantity prong requires the acts be “so continuous and sufficient to be termed general or habitual.” Appellants’ Brief at 24, quoting Monaco, 208 A.2d at 256 (emphasis in original). 2022“The term ‘quality of acts’ means those directly, furthering, or essential to, corporate objects; they do not include incidental acts.” Monaco, 208 A.2d at 256 (quoting Shambe v. Delaware & Hudson R.R. | 1 | 6 |
Law v. Atlantic Coast Line Railroadgreen2 sentences2023See id. at 255 . 2023Addressing the quality prong first, the Court explained “[c]learly, the acts of driving into Philadelphia County at the request of customers and collecting fares there were acts directly essential to and in furtherance of corporate objects and, therefore, were of sufficient quality.” Id. | 1 | 2 |
Canter v. American Honda Motor Corp.green1 sentence2023See 231 A.2d at 142 . | 1 | 1 |
Hangey, R. v. Husqvarna Professional Productsgreen2 sentences2022“In determining whether venue is proper under this rule, courts employ a quality-quantity analysis.” Id. (citation and quotation marks omitted); see also Zampana-Barry v. Donaghue, 921 A.2d 500, 503 (Pa Super. 2007) (“A business entity must perform acts in a county of sufficient quality and quantity before venue in that county will be established.”). 2022“The term ‘quality of acts’ means those directly, furthering, or essential to, corporate objects; they do not include incidental acts.” Hangey, 247 A.3d at 1141 (citation omitted). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Burdett Oxygen Co. v. I. R. Wolfe & Sons, Inc.
green
1 sentence2023Wolfe & Sons, Inc., 249 A.2d 299 (Pa. 1969), established a different “substantial relationship” test for evaluating whether a corporation regularly conducts business in a particular county. | 1 | 2023–2023 |
Battuello v. Camelback Ski Corp.
green
1 sentence2023But “[a] finding by an appellate court that it would have reached a different result than the trial court does not constitute a finding of an abuse of discretion.” Id., quoting Harman ex rel. | 1 | 2023–2023 |
Hausmann, E. v. Bernd, R.
green
1 sentence2022Hausmann, supra, at 496-97 . | 1 | 2022–2022 |
Fritz v. Glen Mills Schools
green
1 sentence2018See Purcell 579 A.2d at 1285 ; Fritz, 840 A.2d at 1022-23 . | 1 | 2018–2018 |
Masel v. Glassman
green
2 sentences2011The case of Masel v. Glassman, 689 A.2d 314 (Pa. Super. 1997), provides further clarification concerning acts that are deemed to be of insufficient quality and quantity to establish venue in Philadelphia County, The court in Masel found that advertisements in Philadelphia publications, contracts with Philadelphia hospitals, the purchase of equipment from Philadelphia vendors, and educational affiliations with Philadelphia institutions could not constitute sufficient contacts to establish venue against defendant St. 2011(Plaintiffs? response to defendants’ preliminary objections ¶ 11) Additionally, plaintiff argues that various schools located in Philadelphia County have held reunions hosted by defendant CDC Catering, Inc. Id. | 1 | 2011–2011 |
Purcell v. Bryn Mawr Hospital
green
1 sentence1990By contrast, the Superior Court held that Burdett’s language “relates to subdivision (a)(2) of Rule 2179 by requiring that the corporation which has been sued have sufficient connection to the county, rather than that the particular corporate acts which directly relate to the underlying cause of action have a sufficient nexus to the county.” 550 A.2d at 1327 . | 1 | 1990–1990 |