.

Ashley is an associate in the Casualty Department, handling matters involving special investigations (SIU), NY labor law 240, admiralty and maritime litigation, and aviation litigation.

As part of the Special Investigation practice group, Ashley’s experience is in defending cases where we assert allegations of fraud and exaggerated injuries against Plaintiffs. These fact-intensive cases involve fraud rings, staged accidents and exaggerated injuries, in addition to improper and fraudulent medical provider billing and reporting.

As part of the New York Labor Law practice group, Ashley handles complex construction site accident cases throughout the state. These include claims involving the use of scaffold systems, demolition and heavy machinery in industrial, commercial and residential projects

As part of the Maritime practice group, Ashley handles maritime personal injury defense cases, marine construction cases, cases involving the Jones Act and Longshore and Harbor Workers’ Compensation Act, and maritime product liability matters.

As part of the Aviation practice group, Ashley handles matters representing airports, and pilots in airplane and helicopter crashes.

Ashley is admitted to practice in New Jersey, Pennsylvania, Maryland, and New York. Outside of her work at Marshall Dennehey, she stays active through hiking, running, working out, and traveling.

    • Widener University Delaware Law School (J.D., 2023)
    • Kutztown University of Pennsylvania (B.A., 2018)
    • Kutztown University of Pennsylvania (Paralegal Certificate, 2018)
    • New Jersey, 2024
    • Pennsylvania, 2024
    • U.S. District Court District of New Jersey, 2024
    • Maryland, 2025
    • New York, 2025

  • Obtained summary judgment in a construction site accident matter in which the plaintiff alleged he was injured after lifting a cover and falling into a hole at an active worksite. Our client was the owner of the building under construction at the time of the accident. Based on the contractual agreements and testimony of the parties involved, we successfully argued that the subcontractors and the plaintiff’s employer were solely responsible for worker safety, supervision, and site conditions. We further argued that our client could not be held liable for the alleged negligence of independent contractors. The court agreed, finding that our client owed no duty to the plaintiff, and dismissed all claims against our client.

    Obtained summary judgment in a breach of contract matter involving 41 separate small claims actions filed against our client arising from travel protection policies. The court consolidated the actions into a single matter. The plaintiff, acting by assignment from insureds, sought recovery under the policies’ rental car damage provisions for alleged vehicle damages incurred by his rental car company. We successfully argued that the majority of the assignments were invalid, depriving the plaintiff of standing to sue. We further argued that, even if the assignments were deemed valid, the plaintiff failed to comply with the policies’ terms, conditions, and claim submission requirements, including conditions precedent to coverage. The court agreed and dismissed all claims against our client.

    Successfully obtained summary judgment in a slip-and-fall matter in which the plaintiff alleged she slipped and fell on snow and ice in a parking lot while entering her vehicle. Our client owned property adjacent to that of a co-defendant, and based on the accident report, plaintiff’s testimony, and expert findings, we successfully argued that the incident did not occur on our client’s property and that our client therefore owed no duty to the plaintiff. The court agreed and dismissed all claims against our client.

    Successfully obtained summary judgment in a breach of contract claim against our client in the Eastern District of New York. The case involved a rental car company attempting to recover from a credit card company based on credit cardholders’ assignment of Collision Damage Waiver benefits to the plaintiff. We argued that there were no contracts between the credit cardholders and our client, but that the contracts were between the cardholders and the non-party banks. The Court dismissed the case in its entirety.

    Successfully won a dismissal of a New York Labor Law case before the Supreme Court, New York County. ​Plaintiff's counsel withdrew from this case after potential fraud issues were raised by the defense. The plaintiff proceeded pro se and then did not appear at further court conferences. The judge later dismissed the case entirely. 

    • “Enforceability of Choice-of-Law Provisions in Maritime Contracts,” Defense Digest, Vol. 30, No. 4, December 2024

Results

View all

Summary Judgment Secured in Slip-and-Fall Case

We were granted summary judgment in a slip-and-fall case where the plaintiff claimed to have slipped and fell on snow/ice in a parking lot when getting into her car. Our client and one of the co-defendants had property lines next to each other. Based on the accident report, the plaintiff’s testimony and our expert report, we argued that the plaintiff did not fall on our property and, as a result, we owed her no duty. The judge agreed and dismissed all claims against our client.

Thought Leadership

View all

Defense Digest

Enforceability of Choice-of-Law Provisions in Maritime Contracts

December 1, 2024

Key Points:  Choice-of-law provisions in maritime contracts are enforceable. The U.S. Supreme Court decision in Great Lakes Ins. SE v. Raiders Retreat Realty Co., LLC helps with the uniformity of federal maritime law. This decision helps save on costs and time if there is a future dispute to the contract. General Overview A choice-of-law provision is a contractual provision that would be used to specify what law will govern the contract should a future dispute arise. Choice-of-law provisions have been known to be an issue when it comes to insurance contracts. A dispute arises when there are two different states’ laws that may be applicable to a contract and the parties do not agree on which one should be applied. If the parties do not agree and cannot decide which state’s law to apply, the court must then decide. These issues ultimately arise when the parties to the contract are in different jurisdictions. In many maritime contracts, the parties are from different jurisdictions, so this issue is one that comes up frequently. Enforceability of a choice-of-law provision is governed by federal maritime law.  The Supreme Court of the United States recently applied federal maritime law in Great Lakes Ins. SE v. Raiders Retreat Realty Co., LLC, 144 S. Ct. 637, 642 (2024). Their decision has streamlined this issue by holding, when there is a choice-of-law provision in a maritime contract, the court must enforce it, except if one of the two exceptions applies. Further, the Supreme Court stated that a “[l]ongstanding precedent establishes a federal maritime rule: Choice-of-law provisions in maritime contracts are presumptively enforceable.” Before this case, the Court had not addressed this issue, but other lower courts had.  Rule on Choice-of-Law Provisions  In its unanimous decision, the Supreme Court determined that choice-of-law clauses in maritime contracts are presumptively enforceable under federal maritime law, subject to two narrow exceptions: (1) when the chosen law would contravene a controlling federal statute or an established federal maritime policy; or (2) when the contracting parties cannot show any reasonable basis for the chosen jurisdiction. With regard to the second exception, the court must apply “substantial deference to the contracting parties.”  Advantages of Rule on Choice-of-Law Provision  The Supreme Court stated: “By identifying the governing law in advance, choice-of-law provisions allow parties to avoid later disputes—as well as ensuing litigation and its attendant costs.” Great Lakes Ins. SE v. Raiders Retreat Realty Co., LLC, 144 S. Ct. 637, 644 (2024). Further, by allowing a choice-of-law provision to be enforceable in a contract, it will save time and money that would be expended on motions and hearings to determine which state’s law should apply to the dispute. If a maritime contract has a provision with the choice-of-law already agreed upon, there would be no dispute as to what law the court would apply to the case. Moreover, determining the choice-of-law in advance helps maritime shippers to decide on the front end “what precautions to take” on their ships (American Dredging Co. v. Miller, 510 U.S. 443, 454 (1994)) and enable[s] marine insurers to better assess risk (see Brief for American Institute of Marine Underwriters et al. as Amici Curiae, at pp. 12–13). Choice-of-law provisions, therefore, can lower the price and expand the availability of marine insurance. Should a dispute between parties arise, the court would then turn to the choice-of-law provision in the contract as the law to be applied, unless the contract falls within one of the two exceptions listed above.  The Future The Supreme Court did not discuss the “issue of federalism in admiralty and the scope of application of state law in maritime cases...” Great Lakes Ins. SE, 144 S. Ct. at 642 (quoting 1 T. Schoenbaum, Admiralty and Maritime Law § 4:4, p. 268 (6th ed. 2018). As stated above, this rule on choice-of-law provisions applies to federal maritime law. However, if a state court is hearing a maritime case, it can apply its state laws, as long as they do not conflict with the federal maritime law. Conclusion This decision is favorable for insurers as these provisions will generally be upheld in future contracts. Also, by having these provisions in maritime contracts going forward, insurers will be saving time and costs on disputing these issues pre-trial. Lastly, knowing what law will apply to the contract gives the contracting parties the advance opportunity to determine what protections/precautions they should take. *Ashley is an associate in our Casualty Department and works in our Mount Laurel, New Jersey, office.    Defense Digest, Vol. 30, No. 4, December 2024, is prepared by Marshall Dennehey to provide information on recent legal developments of interest to our readers. This publication is not intended to provide legal advice for a specific situation or to create an attorney-client relationship. ATTORNEY ADVERTISING pursuant to New York RPC 7.1. © 2024 Marshall Dennehey. All Rights Reserved. This article may not be reprinted without the express written permission of our firm. For reprints, contact tamontemuro@mdwcg.com.

Firm Highlights

Result

Summary Judgment Secured, Preserving $750,000 in Coverage for Insured in Major Trucking Liability Dispute

Ray Freudiger and Michael A. Roberts (both of Cincinnati) successfully obtained summary judgment on behalf of their client in a coverage dispute arising from a May 19, 2022, motor vehicle accident. A permissive driver operated a box truck for an interstate trucking company and caused severe injuries to two tort victims. Prior to the accident, the insured had procured a commercial auto policy for the trucking company with stated limits of $1,000,000. Following the accident, the insurer initiated a declaratory judgment action asserting that only reduced bodily injury limits of $25,000/$50,000 applied and later counterclaimed, alleging it would not have insured the driver had he been properly submitted for approval under the policy. After extensive discovery, briefing, and oral argument, the court rejected the insurer’s attempt to shift responsibility for the $750,000 in coverage it was legally required to provide for permissive drivers under Ohio law, granting summary judgment in favor of the insured and preserving $750,000 in liability exposure.

Portrait of Carolyn Schweizer, with text below: Philadelphia Office Managing Attorney

News

Marshall Dennehey Names Carolyn Schweizer New Philadelphia Office Managing Attorney

Thought Leadership

Commonwealth Court Holds That a Claimant Who Was Struck By a Car While Crossing the Street During an Unpaid Break Was In the Course and Scope of Employment

This case involved a claim petition filed by a claimant who sustained injuries after being struck by a vehicle while crossing the street in front of the employer’s premises. The employer denied the claim based on course and scope, as the accident occurred during one of two mandatory fifteen (15) minute breaks provided to the claimant. The claimant would punch out at the beginning of a break and punch back in when the break was over.  On the date of the incident, the claimant punched out and left the building to get lunch at a restaurant, which required her to cross the employer’s parking lot, and then a public street, where the injury occurred. The Workers Compensation Judge (WCJ) dismissed the petition, noting that that during the two mandatory fifteen-minute breaks per shift allowed by the employer, the claimant was free to leave the employer’s premises, and during breaks, permitted to engage in whatever activity she desired. The WCJ found that at the time of the accident, the claimant was on her own time, in the middle of the street, and going to get lunch.   The claimant filed an appeal with the Worker’s Compensation Appeal Board (Board), and the Board reversed.  According to the Board, the claimant’s location was still on the employer’s premises, as the claimant was taking her customary route while using a reasonable ingress/egress from the employer.  Further, the Board found that the “Personal Comfort Doctrine” applied, as the claimant was on a momentary departure to take care of her personal comfort, within the window of time she was allotted for her break.  The Board remanded the case, and a WCJ granted the claim petition.  The Board affirmed, and the employer appealed to the Commonwealth Court. Before the Court, the employer argued that the claimant was not in the course and scope of her employment, because the injury did not occur on its premises, and the claimant was outside the bounds of the Personal Comfort Doctrine. The Court, however, rejected these arguments, and dismissed the employer’s appeal.  The Court noted that the break given to the claimant was so cursory, when she set out to relieve her hunger for her own personal comfort,  she remained in the course of her employment when she sustained her injuries.  A Petition for Allowance of Appeal in the Supreme Court has been filed by the Employer, Giant Eagle.

Jason Banonis Holds PDI Attorney of the Year Award with the PDI President

News

Jason Banonis Named Attorney of the Year by the Pennsylvania Defense Institute

Thought Leadership

New Jersey Workers’ Compensation Legislation Updates

Since June 1, 2026, there have been no new New Jersey workers’ compensation related cases from the Appellate or Supreme Courts. As such, below will highlight any new legislative updates since February. A1023 | S3984 - Medical Use of Cannabis Under Certain Circumstances This requires workers’ compensation, PIP, and health insurance coverage for the medical use of cannabis under certain circumstances. It was introduced on January 13, 2026 and referred to the Assembly Financial Institutions and Insurance Committee. It was also introduced on March 19, 2026 and referred to the Senate Commerce Committee. A1045  - Certain Injuries to Volunteer and Professional Public Safety and Law Enforcement Personnel This revises workers’ compensation coverage for certain injuries to volunteer and professional public safety and law enforcement personnel. It was introduced on January 13, 2026 and referred to the Assembly Labor Committee. A1384 | S2757 - Reduce Statute of Limitations in Medical Fee Disputes This reduces statute of limitations from six years to two years in medical fee disputes in workers’ compensation matters. It was introduced on January 13, 2026 and referred to the Senate Labor Committee. It was also introduced on the same day and referred to the Assembly Labor Committee. A1870 | S1379 - Workers' Compensation Benefits For Certain Workers Due to September 11, 2001 Terrorist Attacks This provides workers’ compensation benefits for certain public safety workers who developed illness or injury as result of responding to September 11, 2001 terrorist attacks. It was introduced on January 13, 2026 and referred to the Assembly Labor Committee. It was also introduced on the same day and referred to the Senate Labor Committee. On February 5, 2026, it was reported from the Senate Committee, 2nd Reading, and referred to the Senate Budget and Appropriations Committee. A2779 | S1521 - Excludes Certain Illegal Aliens This excludes certain illegal aliens from workers’ compensation and temporary disability benefits. It was introduced on January 13, 2026 and referred to the Senate Labor Committee. It was also introduced on the same day and referred to the Assembly Labor Committee. A2792 | S1555 -  Prevent Intoxicated Employees from Workers’ Compensation This prevents intoxicated employees from receiving workers’ compensation. It was introduced on January 13, 2026 and referred to the Senate Labor Committee. It was also introduced on the same day and referred to the Assembly Labor Committee. A3167 | S2372 - Workers’ Compensation Insurance Requirements for Certain Corporations and Partnerships This concerns workers’ compensation insurance requirements for certain corporations and partnerships. It was introduced on January 13, 2026 and referred to the Senate Labor Committee. It was also introduced on the same day and referred to the Assembly Labor Committee. A3548 | S3571 – Maximum Benefits for Certain Volunteers This provides certain volunteer and other workers with maximum compensation benefit for workers' compensation claim regardless of outside employment. It was introduced on January 13, 2026 and referred to the Senate Labor Committee. On March 2, 2026, it was reported from the Senate Committee, 2nd Reading, and referred to the Senate Budget and Appropriations Committee. It was also introduced on the same day and referred to the Assembly Labor Committee. On May 7, 2026, it was reported and referred to Assembly State and Local Government Committee. A3724 - Personal Liability to Employer Officers for Failure to Pay for Coverage This provides personal liability for owner, executive officer, or executive director of employer for failure to pay for workers' compensation coverage. It was introduced on January 13, 2026 and referred to the Assembly Labor Committee. On May 7, 2026, it was reported and referred to Assembly Judiciary Committee. A4617  - Certain Workers' Compensation Supplemental Benefits and Funding Method This concerns certain workers' compensation supplemental benefits and funding method. For a permanently and totally disabled worker or surviving dependents after December 31, 1979, with some exceptions, this bill provides for an annual cost of living adjustment in the weekly workers’ compensation benefit rate. It was introduced on March 10, 2026 and referred to the Assembly Labor Committee. S241 - Inclusion in Database of Appointed Officials This requires that workers’ compensation judges and administrative law judges be included in database of appointed officials. It was introduced on January 13, 2026 to the Senate, Referred to Senate State Government, Wagering, Tourism & Historic Preservation Committee. S2290 -  Mandatory Retirement Age This increases statutory mandatory retirement age for Supreme Court Justices, Superior Court Judges, Tax Court Judges, Administrative Law Judges, and Workers’ Compensation Judges from 70 to 72. It was introduced on January 13, 2026 and referred to the Senate Judiciary Committee. S3144 - Testimony in Workers’ Compensation This concerns submission of testimony in workers’ compensation claims. It was introduced on January 13, 2026 and referred to the Senate Labor Committee. S3342  - Increase Mandatory Retirement Age This increases statutory mandatory retirement age for Supreme Court Justices, Superior Court Judges, Tax Court Judges, Administrative Law Judges, and Workers’ Compensation Judges from 70 to 75. It was introduced on February 5, 2026 and referred to the Senate Judiciary Committee.

blue facade of a hospital sign against blue sky

Result

Defense Verdict in Complex Medical Malpractice Trial

Thought Leadership

Appellate Court Rejects Horizontal Immunity Defense to Company Not Acting as Statutory Subcontractor

The First District Court of Appeal held that a property management company was not entitled to horizontal immunity under section 440.10(1)(e), Florida Statutes, in a negligence action brought by an employee of another company working on the property. The claimant was injured while servicing a swimming pool at an apartment complex. His employer had contracted with the property owner to maintain the pool. Following the accident, the claimant received workers' compensation benefits through his employer’s carrier. The claimant subsequently filed a negligence action against the property management company, alleging that it failed to maintain the premises in a reasonably safe condition and failed to warn him of a dangerous condition that caused his injuries. The property management company had been retained by the property owner to maintain the complex in good operating condition and to perform routine maintenance and repair work. The property management company argued that it was immune from suit under section 440.10(1)(e) of Florida’s Workers’ Compensation Law. That provision grants immunity to a subcontractor providing services in conjunction with a contractor on the same project or contract work from civil actions brought by employees of another subcontractor, subject to limited exceptions. According to the property management company, it qualified as a subcontractor working on the same project as the claimant’s employer and was therefore entitled to horizontal immunity. The trial court agreed and entered summary judgment in its favor. On appeal, however, the claimant argued, and the appellate court agreed, that horizontal immunity applies only when a contractor has sublet work arising from a contractual obligation owed to a third party. The court noted that prior decisions consistently held that an entity acting solely on its own behalf as the owner of property, rather than pursuant to a contract with a third party, is not a “contractor” under section 440.10(1), even when it hires other companies to perform work on the property. In Teed, the property management company could not establish that the property owner had a primary contractual obligation to a third party to maintain either the apartment complex or the swimming pool, which it then delegated to the claimant’s employer or the property management company. As a result, the property owner did not qualify as a statutory contractor, and the property management company was not a subcontractor entitled to horizontal immunity under section 440.10(1)(e). The First District therefore reversed the lower court’s ruling and remanded the case for further proceedings on the claimant’s negligence claim.

empty courtroom photo

Result

Summary Judgment Secured for Life Insurance Agent

Marshall Dennehey Announces 2026 Ohio Super Lawyers and Rising Stars

News

Marshall Dennehey Announces 2026 Ohio Super Lawyers and Rising Stars

Event

Pennsylvania Appellate Update 2025-2026

On August 21, 2026, Casey will serve as a panelist for the live webcast program, “Pennsylvania Appellate Update 2025-2026” presented by the Appellate Advocacy Committee of the Pennsylvania Bar Association and Pennsylvania Bar Institute. The program is divided into three parts—Criminal, Civil, and Administrative. Casey will serve as a panelist for the Civil portion, along with Christina McKinley of Blank Rome, Ben Baer of Injury Law Partners, John Masslon of Keller Postman, Jonathan Bruno of Bruno Litigation LLC, and moderator, Ezza Ahmed of Buchanan Ingersoll.  Registration and more information: https://www.pbi.org/product/pennsylvania-appellate-update-2025-2026/