Pennsylvania has long been known as a jurisdiction where wrongful use of civil proceedings is used as a sword, not just as a shield. We even have our own name for it, the Dragonetti Act, named after Joseph Dragonetti, a Philadelphia reporter, public relations consultant and political campaigner. Dragonetti was named as a defendant in a lawsuit to recover a debt by Girard Bank against a textile manufacturer Dragonetti performed public relations work for, even though he was not an employee of the firm, and was not involved in procuring the loan. After the lawsuit against him was dismissed, Dragonetti brought a wrongful use of civil proceedings action against Girard Bank. Dragonetti’s claim failed due to the “English rule” then applicable in Pennsylvania, which required a seizure of person or property in order to succeed in a wrongful use of civil proceedings claim. Dragonetti led a tireless campaign to eliminate the “English rule,” and in 1980, an act bearing his name was signed into law by Gov. Dick Thornburgh, codifying wrongful use of civil proceedings. The statute codified at 42 Pa. C.S.A. § 8351 reads:
“(a) Elements of action. A person who takes part in the procurement, initiation or continuation of civil proceedings against another is subject to liability to the other for wrongful use of civil proceedings:
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