contribution claim in Pennsylvania

1990Swartz, 403 Pa. at 225 , 169 A.2d at 291 . 3 *500 We also agree with Automated’s assertion that the statute of limitations applicable to Oviatt’s underlying claim against the additional defendants has no effect on Automated’s ability to enforce a contribution claim against them.

1990Swartz, 403 Pa. at 225 , 169 A.2d at 291 . 3 *500 We also agree with Automated’s assertion that the statute of limitations applicable to Oviatt’s underlying claim against the additional defendants has no effect on Automated’s ability to enforce a contribution claim against them.

2015Oviatt, 583 A.2d at 1227 .

2014Id. at 204 .

2014This concern is not present where a timely joinder has occurred, as the liability of the defendant and the additional defendant are adjudicated in the same case. 2 Plaintiffs also cite to Hileman v. Morelli, 605 A.2d 377 (Pa. Super. 1992), for the proposition that their contribution claim is not premature.

2001Wkly, March 17,1997, at 12, 13: “In conclusion, given the fact that the pro tanto release is so clearly favorable to the plaintiffs, the only reasonable explanation that such releases are not seen more often is that defendants refuse to enter into them, given the subsequent risk of exposure to defendants.” I recognize that the opinion of the Pennsylvania Supreme Court in Baker v. ACandS, supra, 562 Pa. at 297 , 755 A.2d at 667 , contains the following dicta: “Thus, in Pennsylvania, the UCATA contemplates three separate scenarios.

2001Wkly, March 17,1997, at 12, 13: “In conclusion, given the fact that the pro tanto release is so clearly favorable to the plaintiffs, the only reasonable explanation that such releases are not seen more often is that defendants refuse to enter into them, given the subsequent risk of exposure to defendants.” I recognize that the opinion of the Pennsylvania Supreme Court in Baker v. ACandS, supra, 562 Pa. at 297 , 755 A.2d at 667 , contains the following dicta: “Thus, in Pennsylvania, the UCATA contemplates three separate scenarios.

1997In the case of Department of Environmental Resources v. Bryner, 149 Pa. Cmwlth. 59, 613 A.2d 43 (1992), Judge Palladino, in granting summary judgment to the Department on liability, held that where the administrative record clearly demonstrated that the defendants contributed to causing the release of hazardous substances, the acts or omissions of a third party were not a defense under Section 703(a)(8) of the HSCA, 35 P.S. § 6020.703(a)(3), which requires that the release of such substances be caused solely by the acts or omissions of a third party.

1990In the case of Charles v. Giant Eagle Markets, 513 Pa. 474 , 522 A.2d 1 (1987), our supreme court discussed the definition of "voluntary settlement” in the context of a contribution claim under the UCATA. *500 In their briefs, the additional defendants direct our attention to Chief Justice Nix’s observation that a settling tortfeasor who elects to pay consideration for a release enjoys no contribution rights.

1990In the case of Charles v. Giant Eagle Markets, 513 Pa. 474 , 522 A.2d 1 (1987), our supreme court discussed the definition of "voluntary settlement” in the context of a contribution claim under the UCATA. *500 In their briefs, the additional defendants direct our attention to Chief Justice Nix’s observation that a settling tortfeasor who elects to pay consideration for a release enjoys no contribution rights.

1964Bearing in mind that "equity [is] the keynote of the doctrine of contribution" ( Mong v. Hershberger, 200 Pa. Superior Ct. 68 , 186 A. 2d 427 ), the provisions of § 2(2) require that, until Buterbaugh, as a joint tortfeasor, has satisfied the alternative provisions of the act he is not entitled to any contribution from Daly.

1964Bearing in mind that "equity [is] the keynote of the doctrine of contribution" ( Mong v. Hershberger, 200 Pa. Superior Ct. 68 , 186 A. 2d 427 ), the provisions of § 2(2) require that, until Buterbaugh, as a joint tortfeasor, has satisfied the alternative provisions of the act he is not entitled to any contribution from Daly.