DeAngelis v. Commonwealth Land Title Insurance (1976)
Citation: 467 Pa. 410, 358 A.2d 53 (1976). Court: Supreme Court of Pennsylvania. Full majority and concurrence retrieved October 17, 2026. The Caselaw Access Project file is an unofficial complete reporter reproduction.
Source note (2026-10-18):
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https://static.case.law/pa/467/cases/0410-01.jsonare 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.
After a creditor levied on ceramics and antique furnishings and the sheriff took possession, other judgment creditors obtained a liquidating receiver, a sheriff-sale stay and orders moving the goods to New York for sale. The Supreme Court vacated the appointment and ordered the goods returned to the sheriff. The majority held that the requesting judgment creditors had not acquired a personal-property lien through execution before seeking the receiver.
Justice Roberts’s concurrence, joined by Justices Nix and Manderino, agreed with vacatur but disputed that prerequisite. It instead emphasized the existing levy creditors’ superior rights, procedural defects and inadequate protection against moving the goods into another jurisdiction. The concurrence is not the majority’s rule or a separate holding authorizing the contemplated sale.
For pennsylvania, the decision is actual chattel receivership and competing-claim authority: appointment and a proposed higher-value sale cannot simply be treated as erasing an existing creditor’s rights. No completed purchaser-title adjudication or universal current free-and-clear/confirmation rule follows.
The complete decision is verified. Current prerequisites and comprehensive later treatment remain needs_verification; text retrieval is not good-law certification.
Legal information, not legal advice. Verify current law and later treatment before relying on this decision.