Christopher is a member of the Professional Liability Department where his practice is focused on insurance coverage and bad faith litigation. As an experienced litigator, he has developed a deep understanding of insurance policy and coverage issues arising from commercial, personal, and specialty property and casualty policies, professional liability policies, health/life policies and workers’ compensation policies.
Prior to joining Marshall Dennehey, Christopher worked as a senior claims examiner where he dealt with coverage issues and the management of professional liability lawsuits with a focus on municipalities. This experience has provided Christopher with a unique perspective in understanding the tactics utilized by plaintiffs to leverage settlement issues both before and during litigation, as well as analyzing available coverage, responses to civil remedy notices, pre-suit investigations and coverage evaluations. Christopher also presents seminars to clients about issues in the insurance coverage and bad faith practice area.
In 2009 Christopher graduated from Penn State University, earning a Bachelor of Arts degree in English. He later attended Widener University School of Law where he earned his juris doctor, magna cum laude, in 2013.
During his time in law school, Christopher was a senior staff member of the Widener Law Journal, which published his survey analyzing a Pennsylvania Supreme Court administrative law decision in its Spring 2013 issue. Christopher also held an internship for the Pennsylvania Medical Care Availability and Reduction of Error Fund and clerked for the local staff defense counsel of a national insurance company.
Results
Thought Leadership
Case Law Alerts
Court Finds Fatal Shooting “Arises Out of” Vehicle Use for UIM Coverage
April 1, 2026
In this tragic case, James Hunt was stopped at a red light while driving a vehicle owned by his employer when he was accidentally shot and killed by the operator of another vehicle stopped at the red light, heading in the same direction. The accidental shooter was attempting to unload a firearm which he kept in his glove compartment. The employer-owned van that Hunt was operating at the time of his killing was insured by Allmerica Financial Benefit Insurance Company with non-stacked underinsured motorist limits of $1,000,000.00. Hunt’s family reached a settlement with the shooter’s auto insurer and demanded the UIM policy limits from Allmerica. Allmerica disclaimed the Hunts’ UIM claim and filed a declaratory action. The Eastern District was then tasked with Allmercia’s motion for judgment on the pleadings wherein it argued that Hunt’s death did not result from the ownership, maintenance, or use of an underinsured motor vehicle, which is required for Allmerica to pay UIM benefits, per their policy. Allmerica argued that “result from” is a proximate causation standard for the payments of UIM benefits. In response, the Hunts argued that Pennsylvania’s Motor Vehicle Financial Responsibility Law codified a “but for” causal standard for the payment of UIM benefits where it requires UIM coverage “provide protection for persons who suffer injury arising out of the maintenance or use of a motor vehicle . . .” Determining that the Allmerica policy language directly contradicts the MVFRL mandate, the Eastern District applied a “but for” standard to determine if UIM coverage applied. After an extensive review of precedent, the Eastern District determined that, since the shooter’s vehicle was being used to transport himself and the firearm to and from work, and since the discharge of his weapon was the result of negligent and unintentional conduct, the shooter’s use of his vehicle was the “but for” cause of the death of Hunt.
Case Law Alerts
Court Confirms UIM Claimants Must Qualify as an ‘Insured’ Under the Policy Insuring Their Employer’s Vehicles in Order to Stack Their Personal Auto UIM Policy
January 1, 2026
While in the course and scope of his employment and while operating a vehicle owned by his employer, Russo was injured in a motor vehicle accident. He submitted a claim for and obtained underinsured motorist (UIM) benefits from the insurer of his employer’s vehicle. Russo next submitted a claim for UIM benefits under his personal auto insurance policy, issued by Erie. Erie denied the claim based upon the regular use exclusion. Litigation ensued, with the trial court ultimately finding in Erie’s favor as a result of the Pennsylvania Supreme Court’s decision in Rush v. Erie Ins. Exch., where the court found that the regular use exclusion remained valid and enforceable. Russo appealed to the Superior Court, which upheld the trial court’s ultimate conclusion that Russo was owed no UIM coverage under his personal auto policy issued by Erie, albeit on different grounds. The court first reiterated that Section 1738 of Pennsylvania’s Motor Vehicle Financial Responsibility Law (regarding the stacking of uninsured and UIM benefits) states: “[w]hen more than one vehicle is insured under one or more policies providing uninsured or underinsured motorist coverage, the stated limit for uninsured or underinsured coverage shall apply separately to each vehicle so insured. The limits of coverages available under this subchapter for an insured shall be the sum of the limits for each motor vehicle as to which the injured person is an insured. Russo argued that he was an “insured” of the auto policy issued to his employer, which provided coverage for the vehicle he was operating at the time of the accident. Erie argued that “insured” is a term of art and is limited to only “class one insureds,” who are the named insureds, resident relatives of the named insured and, if the named insured is a corporation, officers of the corporation. The court reiterated that a claimant must be an insured under both policies implicated in a stacking situation in order to effectuate inter-policy stacking of UM/UIM insurance. The Superior Court ultimately held that Russo was not an insured under the policy issued to his employer and, therefore, was unable to stack his personal auto policy and no benefits were owed by Erie. In its conclusion, the court stated: “[s]imply receiving UIM coverage for injuries sustained as an occupant in a first priority vehicle does not make one an ‘insured’ under the vehicle’s policy who is then entitled to stack one’s personal auto policy UIM coverage.” UIM stacking cases often involve claimants operating or occupying their employers’ vehicles. This case is a reminder to confirm that the claimant qualifies as an insured under the employer’s policy and as statutory defined by Section 1738 before stacking of their personal policies can apply. This reminder should also extend to claimants operating or occupying any non-owned motor vehicle.
