Allegheny Clarklift v. Woodline Industries (1986)

Citation: 356 Pa. Super. 269, 514 A.2d 606 (1986). Court: Superior Court of Pennsylvania. Full judicial opinion retrieved October 17, 2026. The Caselaw Access Project file is an unofficial complete reporter reproduction.

Source note (2026-10-18):

• Links on this page to https://static.case.law/pa-super/356/cases/0269-01.json, https://static.case.law/pa/555/cases/0021-01.json are an (unofficial Caselaw Access Project copy, retrieved before 2026-10-18; host disallows automated access); no official or otherwise permitted full-text copy was located on 2026-10-18.

A landlord distrained on a forklift leased to its tenant by another owner. The Superior Court affirmed judgment against the landlord, rejecting reliance on the Landlord and Tenant Act’s constitutionally deficient distraint scheme. It examined Flagg Bros., Luria and Lugar, and distinguished private self-help from statutory procedures involving state officials. Extra notice did not cure reliance on the invalidated scheme.

The Pennsylvania Supreme Court later acknowledged this holding in Smith v. Coyne, 555 Pa. 21, 722 A.2d 1022 (1999). Smith’s own holding concerns tenant appeal/supersedeas requirements, so its acknowledgment is not a new merits adjudication of every distress provision.

The full official 1951 Act 20 still prints distress provisions and separately regulates abandoned tenant property in § 505.1. Printed text is not proof that all distress sales are presently valid. The full official United States v. Forrest opinion/order (2025) rejects a landlord’s claimed priority and awards conversion damages for crop sales; its hypothetical compliant-distress discussion does not overrule this state case.

The bodies and identified later treatment are verified. Broader current applications, third-party purchaser effects and comprehensive subsequent history remain needs_verification; no new validated landlord auction power is inferred.

Applies in pennsylvania.

Legal information, not legal advice. Verify current law and later treatment before relying on this decision.