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Christian D. Marquis

Portrait of Christian D. Marquis

Christian's practice includes the defense of professionals, public entities, police officers and public officials. He has handled numerous cases defending public entities and public officials in matters involving general negligence and intentional tort claims, land use and zoning issues including municipal statutory appeals, mandamus and inverse condemnation claims, and administrative regulatory issues. He also defends public entities, public officials and police officers in civil rights actions including land use and zoning denials, unlawful use of force, wrongful arrest and malicious prosecution claims, and also wrongful termination and discrimination claims.

Christian has significant experience representing architects and engineers, construction contractors, home and code inspectors, real estate agents and other professionals in the defense of professional and general negligence, construction injuries and accidents, construction defect and breach of contract claims. He also defends clients in personal injury, commercial, environmental and toxic tort litigation matters, more recently surrounding fracking related to natural gas drilling. Christian has tried and handled cases in state and federal courts.

In 1995, Christian graduated from St. Vincent College with a Bachelor of Arts degree in mathematics. In 1996, he graduated from the Pennsylvania State University with a Bachelor of Science degree in chemical engineering.  He then earned his juris doctor from the New England School of Law, Boston, Massachusetts, in 1999.

    • New England Law | Boston (J.D., 1999)
    • The Pennsylvania State University (B.S., 1996)
    • Saint Vincent College (B.A., 1995)
    • Pennsylvania, 2000
    • U.S. District Court Western District of Pennsylvania, 2000
    • U.S. Court of Appeals 3rd Circuit, 2007
    • AV® Preeminent™ by Martindale-Hubbell®
    • The Best Lawyers in America®, "Lawyer of the Year," Pittsburgh, Personal Injury Litigation – Defendant (2019)
    • The Best Lawyers in America®, Personal Injury Litigation – Defendants (2014-2027)
    • The Best Lawyers in America®, Litigation - Municipal (2014-2026)
    • Pennsylvania Super Lawyer Rising Star (2005-2006)
    • Allegheny County Bar Association
    • Pennsylvania Bar Association
    • “Taking vs. Tort: Which Is It in Relation to Sanitary Sewer Overflows?,” Defense Digest, March 2021, Vol. 27, No. 2
    • "The First Amendment's Protection Applies To Certain Comments Directed Toward Police Officers," Defense Digest, Vol. 13, No. 4, December, 2007
    • "Nanty-Glo Rule Applies to Preliminary Objections Raising Issues of Fact," Defense Digest, Vol. 10, No. 1, March, 2004
    • After the completion of discovery, successfully obtained settlement of less than $42,000 on behalf of a police department and its officer arising out of a family dispute where seven family members filed Section 1983 civil rights claims alleging malicious and retaliatory prosecution where the initial demand was over $750,000.
    • In a case where a plaintiff filed a Section 1983 civil rights claim based on alleged unlawful excessive use of force where a police canine, upon the command of its controlling officer, grabbed the plaintiff's abdomen, taking him to the ground and resulting in puncture wounds. Obtained a settlement of $20,000 where the plaintiff's demand was $250,000.
    • Currently handling a case on behalf of a roofing contractor where the plaintiff school district is alleging against multiple parties that the roof was improperly constructed, resulting in roof leakage associated damages in excess of $600,000.
    • Currently handling a case on behalf of a civil engineering and surveying firm resulting from an allegedly improperly designed storm water management system associated with a land development plan. Decedent's estate has raised claims against multiple parties that storm water drainage formed ice on a state road, causing decedent's accident.
    • Obtained summary judgment in favor of a municipal authority wherein plaintiffs claimed damages in excess of $75,000 as a result of a landslide that impacted their property allegedly as a result of a defective sanitary sewer line and corresponding trenching.
    • Obtained summary judgment in favor of a township wherein a plaintiff alleged that she sustained various personal injuries as a result of a motor vehicle versus tractor trailer accident that was allegedly caused by a defective traffic signal.
    • Successfully obtained a favorable decision on appeal before the Commonwealth Court in a reported decision on behalf of a borough and its council on the basis of high public official immunity wherein a plaintiff sought damages as a result of being debarred during a public meeting by the council from bidding on public works contracts.
    • Obtained a jury defense verdict on behalf of a township wherein a plaintiff alleged that he sustained a foot fracture after stepping into an uncovered utility trench.
    • Obtained a non-jury defense verdict on behalf of a city wherein a plaintiff alleged that his rental property sustained damages as a result of a sanitary sewer back-up.
    • Obtained a decision in favor of a home inspector after binding arbitration wherein a plaintiff alleged that the inspector was negligent for failing to discover the existence of mold during a home inspection.
    • Obtained a non-jury defense verdict on behalf of a police officer wherein a plaintiff alleged unlawful use of force during the course of an arrest.
    • Successfully negotiated a favorable settlement in the amount of $15,000 on behalf of a township wherein a police officer who demanded $75,000 alleged wrongful termination from the township police department in violation of his equal protection rights.
    • Osiris Enterprises v. Borough of Whitehall, 877 A.2d 560 (Pa. Cmwlth. 2005)
    • Osiris Enterprises v. Borough of Whitehall, 398 F. Supp. 2d 400 (W.D. Pa. 2005)

Results

Summary Judgment Obtained for School District in Slip-and-Fall Case

We secured summary judgment on behalf of a school district in Fayette County, Pennsylvania. The plaintiff alleged he sustained a concussion as a result of a fall from a loading dock when making a delivery to a middle school in the school district. He argued that the loading dock was dangerous due to inappropriate depth, causing boxes on his hand truck to strike a wall, thus pushing him off of the loading dock. The court concluded that, because of the plaintiff’s prior uneventful encounters with the loading dock, the plaintiff was aware of the intricacies of the loading dock. Additionally, the court concluded that the plaintiff was an experienced delivery driver who, as indicated, was in the best position to perceive whether conditions were dangerous or not, and was, thus, in the best position to take appropriate precautions for his safety. Therefore, the court held that the defendants had no duty to warn or otherwise act to protect the plaintiff.

Successful Appeal of Summary Judgment in Favor of Insurer

We successfully appealed a summary judgment in favor of an insurance client that had been sued by another insurance carrier for more than $1.6 million in damages arising out of a fire loss to an insured auto repair facility. The opposing insurance company had paid $1.6 million in damages and intended to pursue a product liability claim against a vehicle manufacturer, alleging a defectively manufactured vehicle had caused the fire. Our client insured the vehicle that was allegedly defective. After the insurance companies conducted a preliminary expert evaluation, the vehicle was destroyed by a salvage yard in the normal course of business. A claim was made against our client for promissory estoppel where it was alleged the vehicle was destroyed despite a promise to preserve. The Pennsylvania Superior Court affirmed the Court of Common Pleas of Erie County’s rejection of the claims against our client and agreed with our contention that the promissory estoppel claim was a disguised claim for negligent spoliation, which the Supreme Court of Pennsylvania does not recognize. 

Thought Leadership

Defense Digest

Taking vs. Tort: Which Is It in Relation to Sanitary Sewer Overflows?

March 1, 2021

Key Points: To constitute a taking, purposeful and deliberate action is required. A corrective action plan with the aim of reducing inflow and infiltration in a sanitary sewer system is evidence against the finding of a taking with respect to overflows. The failure to replace piping in an aging sanitary sewer system due to the lack of sufficient public funding does not constitute deliberate and purposeful action. In Matter of Franklin Township Sewage Authority, 233 A.3d 1014 (Pa. Cmwlth. 2020), the Commonwealth Court clarified the standard to distinguish whether a landowner damaged by repeated sanitary sewer overflows may claim that his property has been “taken” in the context of an inverse condemnation under the Pennsylvania Eminent Domain Code or whether the landowner is limited to a common law tort claim. Often this issue presents a dilemma to attorneys on both sides of the “v” in determining the legal theory applicable to the prosecution or defense of a case. Given the aging sanitary sewer infrastructure in most urban and suburban areas of Pennsylvania, coupled with the lack of sufficient public funding, this problem frequently presents itself in civil actions when damages are alleged that, if proved, might amount to the full-value level of a “taking,” although a common law tort theory such as negligence has been pleaded. In Franklin Township, the landowner commenced an inverse condemnation action by filing a petition for the appointment of a board of viewers against the Franklin Township Municipal Sanitary Authority (Authority), contending that a de facto taking of his property had resulted from repeated sanitary sewer overflows that occurred in November 2003, August 2007, and October 2012. The Authority filed preliminary objections, asserting that the petition was barred because the landowner’s proper redress was by way of a tort action. After an evidentiary hearing in the trial court, the preliminary objections were sustained, and an appeal to the Commonwealth Court followed. It was agreed that the sanitary sewer overflows onto the landowner’s property were caused by significant rainfalls that resulted in inflow and infiltration into the aging sanitary sewer system, which primarily consisted of terra cotta piping. Because the Authority attempted to reduce inflow and infiltration through a corrective action plan that involved inspections and repairs that did not intend to allow inflow and infiltration into its system, it was determined that the Authority had made a good faith attempt to fix the problem. The evidence also demonstrated that the problem could not have been eliminated unless the Authority had spent approximately $245 million to replace over 245 miles of piping. However, as with most local agencies owning aging infrastructure, the Authority did not have sufficient funding to upgrade its system. The court noted the following standard to prove a de facto taking: (1) [the] condemnor has the power to condemn the land under eminent domain procedures; (2) exceptional circumstances have substantially deprived the [landowner] of the use and enjoyment of the property; and (3) the damages sustained were the immediate, necessary, and unavoidable consequences of the exercise of the power of eminent domain. Franklin Township, 233 A.3d at 1021 (citation omitted). The court also stated that a “de facto taking must result from the governmental body’s actual exercise of the power of eminent domain.” Critical to whether a taking occurs, the court also stated, “[t]he injury complained of [must] [be] a direct result of intentional action by an entity incidental to its exercise of its eminent domain power.” In affirming the trial court, the court in Franklin Township indicated that the facts were more akin to those considered in the Commonwealth Court’s unreported opinion of In re Condemnation by the Youngwood Borough Authority, 2014 WL 10298904 (Pa. Cmwlth. Dec. 5, 2014) rather than those found in the case of In re Mountaintop Area Joint Sanitary Authority, 166 A.3d 553 (Pa. Cmwlth. 2017). The latter case, cited by the landowner, was found to involve a taking, primarily because the authority chose to operate its system in a manner that would result in sanitary sewer overflows due to the design of its system. Therefore, the overflows resulted from a purposeful and deliberate drainage plan. However, the court in Franklin Township essentially adopted the holding in the unreported Youngwood Borough Authority opinion, in essence making it precedential based on similar facts. The original sewer system of the Authority operated as intended when it was first constructed in 1968-69, utilizing terra cotta pipes. Since 2003, the landowner’s property had flooded as a result of inflow from illegally connected downspouts and infiltration due to cracks, breaks and separations that are natural to aging terra cotta pipes. The Authority had not intended to have inflow and infiltration in its system and had a corrective action plan that included a lateral inspection program to identify and repair problems. Furthermore, the Authority had even installed a check valve on the landowner’s property that stopped basement flooding, although sewage still flowed into a retention pond on the property a few times a year. Therefore, the court held that a de facto taking had not occurred because the landowner’s injury had not resulted from a purposeful or deliberate action by the Authority with respect to the manner in which it chose to operate its system. Of particular significance with respect to Pennsylvania’s aging sanitary sewer infrastructure was the court’s consideration of the evidence related to the cost to remediate the Authority’s terra cotta pipe sewage system. The trial court addressed this issue through the landowner’s argument that the Authority’s failure to replace the terra cotta piping was a deliberate and purposeful action amounting to a de facto taking. The court disagreed with the landowner, holding that, because of the lack of adequate funding, the choice to replace the entire system was not even on the table to consider. The choice would only have been available if the funding existed, and, only then, could the court have potentially found that the failure to replace the system was deliberate and purposeful so as to constitute a de facto taking.  *Christian is a shareholder and works in our Pittsburgh, Pennsylvania office. He can be reached at 412.803.1142 or cdmarquis@mdwcg.com. Defense Digest, Vol. 27, No. 2, March 2021 is prepared by Marshall Dennehey Warner Coleman & Goggin 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. © 2021 Marshall Dennehey Warner Coleman & Goggin. 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

Thought Leadership

The Ohio Supreme Court Extends Sham-Affidavit Rule to Contradictory Expert Reports

Legal Roundup: Ohio In its June 23, 2026, decision in Moore v. Mercy Medical Center, the Ohio Supreme Court upheld a trial court’s decision to strike an expert witness’s affidavit that contradicted the opinions expressed in the expert’s prior report. This case pertains to allegations of medical malpractice after plaintiff Cheri Moore gave birth to an infant in respiratory distress who required intubation. Moore alleged that a delay in ordering an emergency cesarean section resulted in the need for intubation, causing her child’s injuries. Specifically, Moore sued Dr. Meniru, who completed his first shift at 7:00 a.m. on May 28, 2015, and did not resume treating Moore until 7:00 a.m. on May 29, 2015. One of Moore’s expert witnesses authored a report stating that the doctors, including Dr. Meniru, deviated from the standard of care by not advocating for a cesarean section in the evening of May 28, 2015. Based on this report, Dr. Meniru moved for summary judgment, arguing that the alleged breach occurred during a period when he was not on duty. In response to the summary judgment motion, the plaintiff filed an affidavit from the same expert. Although the expert expressly incorporated his previous report into his affidavit, he also offered an additional opinion: that Dr. Meniru breached the standard of care by failing to begin a cesarean section within 30 minutes of receiving reports of fetal distress. Dr. Meniru filed a motion to strike the expert’s affidavit, arguing that it contradicted the opinions set forth in his prior report in violation of the sham-affidavit rule. The sham-affidavit rule applies to “a contradictory affidavit that indicates only that the affiant cannot maintain a consistent story, or is willing to offer a statement solely for the purpose of defeating summary judgment”. Moore, supra, at ¶ 19, citing Pettiford v. Aggarwal, 126 Ohio St.3d 413, 2010-Ohio-3237. The trial court granted both the motion to strike and the motion for summary judgment, and the Fifth District affirmed. The Ohio Supreme Court accepted two questions of law: (1) whether the sham-affidavit rule applies when the sworn testimony contradicts prior unsworn statements; and (2) whether an inconsistency within the affidavit goes to credibility or admissibility, justifying an order striking the affidavit. Previous rulings by the Ohio Supreme Court regarding the sham-affidavit rule have pertained to contradictions between an affidavit and sworn deposition testimony. See, e.g., Byrd v. Smith, 2006- Ohio-3455, 110 Ohio St.3d 24, 850 N.E.2d 47. However, here, the Court was asked to apply the same rule to contradictions between a sworn affidavit and an unsworn expert report. The Court held that, because Moore’s expert incorporated his prior report into his affidavit, he effectively adopted the report as part of his sworn testimony.

Result

No-Cause Jury Verdict Secured in Wrongful Death Trial

We successfully obtained a no-cause jury verdict in a 13-day wrongful death trial. The decedent, a 59-year-old man, was admitted to the emergency room on February 15, 2019, with complaints of abdominal pain, decreased appetite, and constipation, despite the use of laxatives. The patient did not complain of any nausea, vomiting, or diarrhea. He had a significant medical history including diabetes, hypertension, prior coronary artery stenting, morbid obesity (with past gastric bypass surgery), longstanding ventral hernia, and back pain. A CT scan revealed multiple hernias and a potential closed-loop bowel obstruction, leading to a surgery consultation. Our client, an emergency general surgeon, interpreted that the patient did not have a closed loop or any significant obstruction and recommended non-surgical management. The patient was approved to have clear liquids, and had a vomiting incident shortly after, but our client was not notified. The patient was returned to NPO status, and after improving overnight, he was returned to “clears” and additional medical and renal consults were ordered. Our client did not receive any communications from the residents/nurses of any changes in the patient’s condition. On February 18, 2019, two rapid responses were called due to increased heart rate and vomiting. It is believed that the vomiting resulted in aspiration, causing sepsis, ultimately leading to the patient’s death. During the trial, the plaintiff’s sole medical expert highlighted imaging on the wrong hernia, which called into question all of his opinions in the case. We made key objections related to the expert testimony, limiting what the allegations were, and preventing new allegations from being made. After approximately two and a half hours of deliberating, the jury returned a no-cause verdict. 

News

106 Marshall Dennehey Attorneys Recognized in the 2027 Editions of The Best Lawyers in America® and the Best Lawyers: Ones to Watch® in America

Marshall Dennehey is proud to highlight the firm’s 106 attorneys who have been recognized in the 2027 editions of The Best Lawyers in America® and the Best Lawyers: Ones to Watch® in America. Less than 6% of all practicing lawyers in the U.S. were selected by their peers for this recognition. Additionally, four of the firm’s attorneys received the Best Lawyers® 2027 “Lawyer of the Year” awards in their respective practice areas and demographic regions. Since it was first published in 1983, Best Lawyers® has become universally regarded as the definitive guide to legal excellence. Best Lawyers lists are compiled based on an exhaustive peer-review evaluation. For more information, please visit https://www.bestlawyers.com/. OUR 2027 LAWYERS OF THE YEAR Harrisburg, PA Christopher Reeser, Personal Injury Litigation - Defendants Kacey Wiedt, Workers Compensation Law - Employers Roseland, NJ Justin F. Johnson, Medical Malpractice Law - Defendants Leonard Leicht, Personal Injury Litigation - Defendants   OUR 2026 BEST LAWYERS IN AMERICA Philadelphia, PA Nicholas D. Bowers, Personal Injury Litigation - Defendants Josh J. T. Byrne, Professional Malpractice Law - Defendants Jefferey J. Chomko, Insurance Law James H. Cole, Insurance Law John J. Delany III, Personal Injury Litigation - Defendants Laurianne Falcone, Personal Injury Litigation - Defendants John P. Gonzales, Employment Law - Management John Hare, Appellate Practice Daniel D. Krebbs, Personal Injury Litigation - Defendants Michele Punturi, Workers' Compensation Law - Employers Bradley D. Remick, Product Liability Litigation - Defendants Andrea Cicero Rock, Workers' Compensation Law - Employers Robin M. Romano, Workers' Compensation Law - Employers Daniel J. Ryan, Jr., Personal Injury Litigation - Defendants Gary M. Samms, Professional Malpractice Law - Defendants Christopher N. Santoro, Personal Injury Litigation – Defendants; Product Liability Litigation -Defendants Josh D. Scheets, Personal Injury Litigation - Defendants Robert P. Schenk, Workers' Compensation Law - Employers Robert E. Smith, Insurance Law Robin Snyder, Litigation - Health Care Michael L. Turner, Commercial Litigation; Criminal Defense: White-Collar; Mass Tort Litigation / Class Actions - Defendants Claire Breaux Ventola, Product Liability Litigation - Defendants Pittsburgh, PA Melissa Devich Cochran, Commercial Litigation; Mass Tort Litigation / Class Actions – Defendants; Product Liability Litigation - Defendants  John F. Deasy, Personal Injury Litigation – Defendants; Product Liability Litigation - Defendants Daniel W. Deitrick, Workers' Compensation Law - Employers Douglas C. LaSota, Litigation - Construction; Mass Tort Litigation / Class Actions - Defendants Joseph V. Lesinski, Product Liability Litigation – Defendants   Christian D. Marquis, Personal Injury Litigation - Defendants Patricia A. Monahan, Insurance Law; Litigation - Insurance Patrick T. Reilly, Commercial Litigation; Mass Tort Litigation / Class Actions – Defendants; Product Liability Litigation - Defendants Brett C. Shear, Medical Malpractice Law - Defendants Teresa O. Sirianni, Education Law; Employment Law – Management; Litigation - Labor and Employment Stuart Sostmann, Product Liability Litigation – Defendants Danielle M. Vugrinovich, Mass Tort Litigation / Class Actions - Defendants Scranton, PA Sarah E. Argo, Litigation - Insurance Michael J. Connolly, Personal Injury Litigation – Defendants; Professional Malpractice Law - Defendants Matthew Keris, Litigation - Health Care; Medical Malpractice Law - Defendants John T. McGrath, Jr., Insurance Law; Medical Malpractice Law – Defendants; Product Liability Litigation - Defendants William J. McPartland, Insurance Law John R. Nealon, Product Liability Litigation - Defendants Victoria Scanlon, Health Care Law; Litigation - Health Care; Medical Malpractice Law - Defendants Michael A. Sebastian, Workers' Compensation Law - Employers Thomas A. Specht, Insurance Law; Litigation - Insurance Suzanne Tighe, Litigation Insurance Harrisburg , PA Casey Alan Coyle, Administrative/Regulatory Law; Appellate Practice; Commercial Litigation Brittany E. Bakshi, Personal Injury Litigation - Defendants Shannon P. Fellin, Workers' Compensation Law - Employers Allison Krupp, Insurance Law John R. Ninosky, Litigation – Insurance; Personal Injury Litigation - Defendants Christopher Reeser, Personal Injury Litigation - Defendants Kacey Wiedt, Workers' Compensation Law – Employers King of Prussia, PA  Michael L. Detweiler, Construction Law Joseph L. Hoynoski III, Medical Malpractice Law - Defendants Gregory J. Kelley, Construction Law, Litigation - Construction Anthony Natale III, Workers' Compensation Law - Employers Francis X. Wickersham, Workers' Compensation Law - Employers A. Judd Woytek, Workers' Compensation Law – Employers Erie, PA Patrick M. Carey, Personal Injury Litigation - Defendants Joel M. Snavely, Health Care Law; Insurance Law New Haven, CT Michael Wrona, Commercial Litigation, Litigation - Bankruptcy  Mount Laurel, NJ David D. Blake, Litigation - Insurance Barbara Davis, Personal Injury Litigation - Defendants Lynne Nahmani, Litigation - Health Care John H. Osorio, Personal Injury Litigation - Defendants John L. Slimm, Legal Malpractice Law – Defendants; Professional Malpractice Law – Defendants Roseland, NJ Robert T. Evers, Medical Malpractice Law - Defendants Justin F. Johnson, Medical Malpractice Law - Defendants Julia Klubenspies, Medical Malpractice Law - Defendants Leonard C. Leicht, Personal Injury Litigation - Defendants Patricia M. McDonagh, Appellate Practice Sunny Sparano, Litigation - Construction Randall S. Watts, Health Care Law New York, NY Tonya M. Lindsey, Medical Malpractice Law - Defendants Tampa, FL Michael Archibald, Personal Injury Litigation - Defendants Lindsay G. McCormick, Litigation – Construction Orlando, FL Thomas F. Brown, Personal Injury Litigation - Defendants Dante C. Rohr, Commercial Litigation Fort Lauderdale, FL Kimberly Kanoff Berman, Appellate Practice Patrick M. Delong, Personal Injury Litigation – Defendants Jacksonville, FL  Heather Byrer Carbone, Workers' Compensation Law - Employers Linda Wagner Farrell, Workers' Compensation Law - Employers Elizabeth B. Ferguson, Litigation - Construction James P. Hanratty, Personal Injury Litigation – Defendants Wilmington, DE Sarah B. Cole, Litigation - Insurance Benjamin K. Durstein, Workers' Compensation Law - Employers Maria R. Granaudo, Medical Malpractice Law - Defendants  Keri L. Morris-Johnston, Workers' Compensation Law - Employers Cincinnati, OH Timothy B. Schenkel, Personal Injury Litigation - Defendants David E. Williamson, Personal Injury Litigation - Defendants Cleveland, OH Vincent E. Cononico, Litigation – Insurance, Personal Injury Litigation - Defendants Jillian L. Dinehart, Personal Injury Litigation - Defendants David J. Fagnilli, Insurance Law Jason P. Ferrante, Health Care Law, Litigation - Health Care Andrew H. Isakoff, Transportation Law Leslie M. Jenny, Litigation - Health Care; Medical Malpractice Law – Defendant OUR 2026 BEST LAWYERS: ONES TO WATCH Jacksonville, FL Sean J. Reeves, Personal Injury Litigation – Defendants; Product Liability Litigation - Defendants Orlando, FL Carolin A. Pacheco, Insurance Law Mount Laurel Stacey Gorin, Insurance Law Melville, NY Kimberly Gitlin, Personal Injury Litigation – Defendants Matthew A. Gray, Insurance Law; Personal Injury Litigation - Defendants Philadelphia, PA Holli K. Archer, Health Care Law; Medical Malpractice Law – Defendants; Professional Malpractice Law Emily Pritchyk, Commercial Litigation; Product Liability Litigation – Defendants Pittsburgh, PA Taylor E. Kosko, Mass Tort Litigation / Class Actions – Defendants; Personal Injury Litigation - Defendants Alana Staniszewski, Workers' Compensation Law - Employers Michael D. Winsko, Product Liability Litigation – Defendants; Transportation Law King of Prussia, PA Richard Lechette, Commercial Litigation; Insurance Law, Personal Injury Litigation – Defendants

Thought Leadership

Pennsylvania Superior Court Reaffirms Liberal Pleading Standard in Medical Malpractice Actions

Legal Roundup: Pennsylvania The Pennsylvania Superior Court has reinforced a broader fact-pleading approach that may make it more difficult for health care defendants to obtain dismissal at the preliminary objection stage. In DaSilva v. Abington Memorial Hospital, the court held that the plaintiffs’ second amended complaint satisfied Pennsylvania’s fact‑pleading requirements despite the absence of individually named negligent actors. In DaSilva, the plaintiffs filed a second amended complaint alleging that Abington Memorial Hospital was directly and vicariously negligent after the patient, who was experiencing a mental health crisis, was left unattended by hospital staff, exited the emergency department, and was struck by a vehicle, suffering serious injuries. The trial court sustained the hospital’s preliminary objections and dismissed the complaint with prejudice, stating plaintiffs “failed to plead any material factual allegations in support of their claims of negligence [and] set forth vague allegations of negligence and unidentified agency.” Id. at *5. The plaintiffs appealed. On appeal, the Superior Court reversed, holding that the complaint sufficiently pled negligence and vicarious liability claims under Pa.R.C.P. 1019(a). The court concluded that allegations describing the patient’s condition, the hospital’s awareness of that condition, and the alleged failure to monitor or prevent elopement were adequate to satisfy Pennsylvania’s pleading requirements. Significantly, the court rejected the hospital’s argument that the complaint failed because it did not identify the specific employees responsible for the alleged negligence. Instead, the court found that generalized references to “emergency room staff” were sufficient to place the hospital on notice of the claims because “the names of those who performed services for the plaintiff are known to the defendant or can be ascertained during discovery.” Id. at *12 (citing Est. of Denmark ex rel. Hurst v. Williams, 117 A.3d 300, 307 (Pa. Super. 2015)). The effect of DaSilva is that plaintiffs may proceed past the pleading stage with relatively generalized allegations, particularly in cases involving institutional defendants where relevant details are uniquely within the defendant’s control. As a result, health care defendants should anticipate that challenges to claim sufficiency may be resolved in the later stages of litigation, including discovery and summary judgment.