Pa. Supreme Court Rules On Proper Venue Standards

In Hangey v. Husqvarna, the Pennsylvania Supreme Court recently ruled that the percentage of a corporate defendant's total revenue generated from a forum county alone is insufficient to support the proposition that a defendant does not "regularly conduct business" in the county when analyzing whether a lawsuit's venue is proper. This long awaited decision provides much needed clarity for trial courts that previously wrestled with the question of how much business must a defendant have in the forum for venue to attach. The Hangey Court concluded that proper venue lies in the forum county if "a company maintains a constant physical presence in the forum county." As the Court noted, quoting prior precedents, "[a] corporation may perform acts 'regularly' even though these acts make up a small part of its total activities." This ruling, focusing on the regularity of a defendant's business activity in the forum as opposed to the dollar amount of its business in the county,