Judge Minora of Lackawanna County Addresses Proper Scope of Requests for Admissions

In the case of Hand v. DiMauro, No. 2015-CV-4470 (C.P. Lacka. Co. Dec. 12, 2019 Minora, J.), the court addressed the propriety of Requests for Admissions served by a Defendant upon a Plaintiff in a motor vehicle accident case.

At issue before the court in this case were Requests for Admissions served by the defense upon the Plaintiff which essentially sought admissions from the Plaintiff that she had multiple physical ailments that predated the subject accident. 

The Plaintiff objected to these requests, asserting that they improperly sought conclusions of law which were beyond the permissible scope of Requests for Admissions under the Pennsylvania Rules of Civil Procedure. 

In his Opinion, Judge Minora reviewed the law surrounding Requests for Admissions which are permitted under Pa. R.C.P. 4014. 

Judge Minora noted that, in the context of discovery, the relevancy of information sought is more widely considered by the courts when compared to the admissibility of evidence at trial. 

The court ruled that the Defendants’ request for discovery concerning the Plaintiff’s prior medical condition is “plainly relevant.”

Judge Minora went on to find that the subject Requests for Admissions were also within Rule 4014’s directive that a Request for Admissions seek the truth of any matters within the scope of discovery allowed by Rules 4003.1 through 4003.5. As such, the court overruled the Plaintiff’s objections to the Requests for Admissions at issue. 

However, rather than accepting the Defendant’s demand that the court consider the Plaintiffs’ invalid objections to be admissions to the Requests submitted. Rather, as a remedy, the court directed the Plaintiff to answer the Requests for Admissions within a certain period of time. 

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