Loyle v. Hertz Corp.

DISSENTING STATEMENT BY

McEWEN, P.J.E.:

¶ 1 While the majority provides a cogent expression of its view, I am compelled to this dissent since I remain convinced that the trial court was correct in granting summary judgment in favor of the Hertz Corporation. It bears emphasis that, as described below, the authorities relied upon by the majority in support of its decision to reverse the decision of the trial court are not binding precedent in Pennsylvania, and that the facts of those cases are distinguishable from the case at bar:

-The 1978 decision rendered by the United States Court of Appeals for the Third Circuit, Drexel v. Union Prescription Centers, Inc., 582 F.2d 781 (3rd Cir.1978), addressed a situation involving a franchisee whose relationship with the franchisor was governed by a detailed agreement that raised factual question concerning the degree of control exercised by the franchisor over the franchisee. Moreover, the over-the-counter transaction between the franchisee and the plaintiff was not governed by the terms of a signed contract between them.
-The 1986 decision rendered by the United States District Court for the Eastern District of Pennsylvania, Matthews v. KFC National Management Co., No. 86-1181, 1986 WL 13296 (E.D.Pa.1986), also arose from the conduct of a franchisee toward a customer in a transaction that was not governed by a written contract.
-The 1988 decision rendered by the Appeals Division of the State of New York, Fogel v. Hertz International, 141 A.D.2d 375, 529 N.Y.S.2d 484 (N.Y.App.Div.1988) is distinguishable for the reasons that (1) that there was no apparent contract disclaimer language, as there is here, and (2) that Hertz International *409owned a 75% interest in the putative “agent” company. It bears further emphasis that the New York Court itself did not apply this precedent in the situation where a “car rental voucher issued to plaintiff clearly indicated that [the rental agency] was an independent contractor.” See: Travalja v. Maieliano Tours, 213 A.D.2d 155, 622 N.Y.S.2d 961 (N.Y.App.Div.1995).
-The 1971 decision in Gizzi v. Texaco, Ind.[Inc.], 437 F.2d 308 (3rd Cir.1971), cert. denied, 404 U.S. 829, 92 S.Ct. 65, 30 L.Ed.2d 57 (1971), which was also rendered by the United States Court of Appeal for the Third Circuit, is distinguishable on the grounds (1) that the exchange between the parties was based primarily on an oral transaction, and (2) that there was no written contract provision or disclaimer identifying the proper parties.

¶ 2 I am also concerned that the analysis of the Majority accepts as a cognizable fact the assertion by appellants that “Defendant also does business in Canada as The Hertz Corp.” Opinion, p. 405. This allegation, which was contained in paragraph 2 of appellants’ original Complaint, was denied in the Answer filed by appellee, thus placing the burden upon appellants to prove their assertion — an apparently impossible burden given the record in this case.4

¶ 3 It is also particularly noteworthy that the rental agreement signed by appellants contained on the signature page a logo with the explicit identification language “Hertz Canada Limited” prominently displayed, as well as a contract paragraph that read, “You [lessee] understand and agree that it is improper for You to file a lawsuit concerning this Agreement against any business entity other than the one with which You have this agreement as identified on the Rental Record.” Exhibit E ¶ 12 to Plaintiffs’ First Amended Complaint. Thus, there is no basis upon which to accept appellants’ claim that they had a reasonable belief that they were renting a ear from the American corporation known as the Hertz Corporation.5

¶ 4 It is thus that I dissent.

. As noted by the trial court,

In order to withstand a motion for summary judgment, a non-moving party must adduce sufficient evidence on which he bears the burden of proof such that a jury could return a verdict in his favor, and failure to adduce this evidence establish that there is no genuine issue of material fact and the moving party is entitled to judgment as a matter of law. Keystone Aerial Surveys, Inc. v. Pennsylvania Property & Casualty Insurance Guaranty Association, 777 A.2d 84 (Pa.Super.2001), [affirmed 574 Pa. 147, 829 A.2d 297 (2003)].

Trial Court Opinion, May 4, 2007, p. 5.

. While I have proceeded to this dissent, I am troubled that an American corporation conducting international operations can pursue profits from around the world, but seize the benefits of restricted liability imposed by international boundaries and clauses of contractual adhesion.