Gerrow v. John Royle & Sons

*143Justice SAYLOR,

concurring.

Although I agree with the majority’s decision to remand, I am sympathetic to the circumstances of the Philadelphia trial courts, which, as exemplified by this case, have implemented and enforced discovery deadlines as an essential means for controlling their overcrowded dockets. Here, a case management order embodied the relevant schedule and, pursuant to the local administrative rule, an extension was permitted only upon petition for extraordinary relief. See Philadelphia Court of Common Pleas Reg. No. 95-2 (providing the procedure for obtaining relief and precluding the parties from extending the deadlines in a case management order by agreement). Further, the Philadelphia Court of Common Pleas has issued an administrative order outlining the protocol for production of expert reports in civil cases and stating that “[t]he dates set forth in the Case Management Order are deadlines after which, in the absence of extraordinary circumstances, no new expert reports or theories can be identified,” and further noting that “[cjounsel may consider filing summary judgment motions where no critical expert opinion has been provided.” Admin. Doc. No. 3 of 1998, reprinted in 28 Pa. Bull. 2919.

While the actions of the trial court therefore comport with the local procedure as written, rigid adherence to such procedure in these circumstances is in tension with the present, applicable rules of civil procedure and prevailing decisional law. In particular, while the trial courts are authorized to preclude evidence as a sanction for violation of an order of court respecting discovery, such a preclusionary order presently is permissible only “on motion.” Pa.R.C.P. No. 4019(a)(1).1 Further, such a motion implicates the trial court’s discretion, guided by standards established by this Court, which include the requirement to make an assessment for prejudice. See, e.g., Pioneer Commercial Funding Corp. v. *144American Fin. Mortgage Corp., 797 A.2d 269, 287 (Pa.Super.2002); accord Miller v. Brass Rail Tavern, Inc., 541 Pa. 474, 488 n. 5, 664 A.2d 525, 532 n. 5 (1995) (citing Feingold v. SEPTA 512 Pa. 567, 573, 517 A.2d 1270, 1273 (1986)).2 In the absence of an order imposing preclusive sanctions, Civil Procedural Rule 1035.3(b) grants the non-moving party thirty days to supplement the record in response to a summary judgment motion. As the majority notes, Appellants’ supplementary reports were filed within the allotted time.

As local rules of procedure must be consistent with the Rules of Civil Procedure, see Brogan v. Holmes Elec. Protective Co. of Phila., 501 Pa. 234, 239, 460 A.2d 1093, 1095 (1983) (citing 42 Pa.C.S. § 3230), it is apparent that effective enforcement of Philadelphia’s case management scheme can presently be accomplished in individual cases primarily via filing of a Rule 4019 motion by a party, or a determination by the trial judge under Rule 212.2(c), see supra note 2. I am therefore obliged to agree with the majority that, in absence of such a motion or determination, Appellees should not have been precluded from submitting their expert reports in response to the summary judgment motion.3

. The procedure established under the corresponding Federal Rule of Civil Procedure is materially different, in that the federal rules expressly permit a district court to enter an order imposing sanctions where a party fails to comply with a case management time limit, including an order prohibiting the introduction of designated matters into evidence. See Fed.R.Civ.P. 37(b)(2).

. Preclusionary sanctions are also available under the rules for failure to submit an expert witness report as a component of a pre-trial statement. See Pa.R.C.P. No. 212.2(a)(5), (c). Again, however, an assessment of prejudice is an express prerequisite to preclusion on such terms. See Pa.R.C.P. No. 212.2(c).

. I agree in many respects with points made in Mr. Justice Nigro's dissent, but do not believe, respectfully, that I am "putting the cart before the horse,” as he suggests, see Dissenting Opinion, at 789 n. 7. I have merely recognized that the present rules contemplate a separate motion serving as the procedural vehicle to implicate the necessary determination of prejudice as a prerequisite to the imposition of preclusive sanctions prior to trial. See, e.g., Williams v. SEPTA, 741 A.2d 848, 855-56 & nn. 5-6 (Pa.Cmwlth.1999) (addressing a motion to preclude expert testimony and applying a prejudice standard), appeal denied, 563 Pa. 680, 759 A.2d 925 (2000). Such framework manifests no facial incongruity, since the factual predicate for preclusion is the failure to obey an order of court regarding discovery, see Pa.R.C.P. No. 4019(a)(l)(viii), not the particular substance of a disclosed, undisclosed, or yet-to-be-prepared expert report. Moreover, Rules 4003.5(b) and 4019(i) do not in and of themselves control, since those provisions do not address the specific timing of pre-trial disclosure, but rather, concern only the necessity of making a requested disclosure of identity *145on a pre-trial basis. Additionally, as noted, both have been read to incorporate a prejudice requirement, see, e.g., Feingold, 512 Pa. at 573, 517 A.2d at 1273; Williams, 741 A.2d at 855-56 & nn. 5-6, which Justice Nigro acknowledges as precedent contrary to his position. Thus, while my thoughts align in a number of material regards with Justice Nigro's, I believe that the better approach to substantial amendments to the rules is to invoke the orderly process of rulemaking, with the concomitant notice to and opportunity for review and comment by the involved interests. In this regard, the First Judicial District may wish to raise with the Civil Procedural Rules Committee the question of whether the rules should be amended to implement an “extraordinary circumstances” standard for allowing late submission of expert reports.