Rule 1019.Contents of Pleadings. General and Specific Averments.
Adopted June 25, 1946 · Last amended November 28, 2000 · Last verified June 30, 2026
In one sentenceRule 1019 sets Pennsylvania’s fact-pleading standard, requiring the material facts of a claim or defense to be stated in a concise and summary form, fraud or mistake to be pleaded with particularity, and a writing on which a claim is based to be attached.
(a)The material facts on which a cause of action or defense is based shall be stated in a concise and summary form.
(b)Averments of fraud or mistake shall be averred with particularity. Malice, intent, knowledge, and other conditions of mind may be averred generally.
(c)In pleading the performance or occurrence of conditions precedent, it is sufficient to aver generally that all conditions precedent have been performed or have occurred. A denial of such performance or occurrence shall be made specifically and with particularity.
(d)In pleading an official document or official act, it is sufficient to identify it by reference and aver that the document was issued or the act done in compliance with law.
(e)In pleading a judgment, order or decision of a domestic or foreign court, judicial or administrative tribunal, or board, commission or officer, it is sufficient to aver the judgment, order or decision without setting forth matter showing jurisdiction to render it.
(f)Averments of time, place and items of special damage shall be specifically stated.
(g)Any part of a pleading may be incorporated by reference in another part of the same pleading or in another pleading in the same action. A party may incorporate by reference any matter of record in any State or Federal court of record whose records are within the county in which the action is pending, or any matter which is recorded or transcribed verbatim in the office of the prothonotary, clerk of any court of record, recorder of deeds or register of wills of such county.
(h)When any claim or defense is based upon an agreement, the pleading shall state specifically if the agreement is oral or written.
(i)When any claim or defense is based upon a writing, the pleader shall attach a copy of the writing, or the material part thereof, but if the writing or copy is not accessible to the pleader, it is sufficient so to state, together with the reason, and to set forth the substance of the writing.
End
Plain-English Summary
This rule states the heart of Pennsylvania pleading. The material facts on which a cause of action or defense is based must be stated in a concise and summary form — Pennsylvania is a fact-pleading jurisdiction, stricter than federal notice pleading, so a pleading must give enough fact to let the other side prepare a defense.
Certain matters carry special rules. Averments of fraud or mistake must be pleaded with particularity, while malice, intent, and knowledge may be averred generally; conditions precedent may be averred generally; and time, place, and special damages must be specifically stated.
Documents come with the pleading. When a claim or defense is based on a writing, the pleader attaches a copy of the writing, or the material part of it, and must state whether an agreement sued upon is oral or written.
Frequently Asked Questions
How much detail must a Pennsylvania complaint contain?
The material facts must be stated in a concise and summary form. Pennsylvania uses fact pleading, which is stricter than federal notice pleading: the facts must be specific enough to let the defendant prepare a defense.
Do I have to attach the contract to my complaint?
Usually. When a claim or defense is based on a writing, the pleader must attach a copy of the writing or its material part; if the writing is not accessible, it is enough to say so, give the reason, and set forth the substance of the writing. The pleading must also state whether an agreement is oral or written.
How are fraud and intent pleaded?
Fraud or mistake must be pleaded with particularity, but malice, intent, knowledge, and other conditions of mind may be averred generally.
Official Note
Official Note: : If the agreement is in writing, it must be attached to the pleading. See subdivisioni (i) of this rule.
Amendment History
The provisions of this Rule 1019 adopted June 25, 1946, effective January 1, 1947; amended April 12, 1999, effective July 1, 1999, 29 Pa.B. 2266; amended November 28, 2000, effective January 1, 2001, 30 Pa.B. 6423. Immediately preceding text appears at serial pages (255201) to (255202).
Source & verification. Rule text, the Official Note, and the amendment
history are reproduced verbatim from the Pennsylvania Code, Title 231, the official compilation
of rules adopted by the Supreme Court of Pennsylvania. Last verified June 30, 2026. ·
Official text
Also known as:contents of pleadingsfact pleadingparticularityattach the writingspecificity