In Hangey v. Husqvarna Prof’l Products, Inc., the plaintiffs filed a complaint as a result of injuries sustained when Mr. Hangey was maimed when he fell off his lawnmower, and the lawnmower ran over his legs while the blades were still engaged. The trial court sustained the defendant’s preliminary objections to venue. In finding venue in Philadelphia was not proper, the court found the defendant’s contacts satisfied the quality prong of the venue analysis but did not satisfy the quantity prong. An en banc panel of the Superior Court of Pennsylvania reversed. The Court concluded that the trial court erred in relying almost exclusively on evidence of the percentage of the defendant’s business in Philadelphia when addressing the quantity prong of the venue analysis. Further, based on the totality of the evidence, the defendant’s contacts satisfied the quantity prong of the venue test. The contacts with Philadelphia–including having an authorized dealer in Philadelphia and selling $75,310 worth of products through that dealer in 2016 in Philadelphia–were “sufficiently continuous so as to be considered habitual.”
