Health Care & Retirement Corp. of America v. Pittas

46 A.3d 719 (Pa. Super. 2012)

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Health Care & Retirement Corp. of America v. Pittas

Pennsylvania Superior Court
46 A.3d 719 (Pa. Super. 2012)

Facts

Health Care and Retirement Corporation of America (HCR) (plaintiff) sued John Pittas (defendant) for payment of outstanding bills incurred by Pittas’s mother. After sustaining injuries in a car accident, the mother had resided in an HCR rehabilitation facility for approximately six months before moving to Greece. The mother had an outstanding bill of over $90,000. HCR claimed that, under Pennsylvania’s filial-support statute, Pittas was liable for the mother’s bill because the mother was indigent and Pittas was financially able to pay the debt. As evidence of the mother’s indigence, HCR presented bank statements showing that her combined monthly income from social security and other resources was only approximately $1,000. As evidence of Pittas’s ability to pay the debt, HCR presented Pittas’s prior tax returns and elicited testimony from Pittas that his annual net income was over $85,000. Pittas contested his liability for the mother’s debt. He argued that the filial-support statute did not render him liable because (1) there was insufficient evidence that his mother was indigent and (2) his own bills rendered him unable to financially support his mother. He did not present evidence of his existing financial commitments. The parties submitted their case to arbitration, and a panel held in Pittas’s favor. However, HCR appealed to a trial court and secured a judgment in its favor, with the court ordering Pittas to pay HCR approximately $92,943. Pittas appealed.

Rule of Law

Issue

Holding and Reasoning (Olson, J.)

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