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Christin L. Kochel

Portrait of Christin L. Kochel

Christin is a member of the Casualty Department where she defends clients in the areas of amusement, sports, and recreation matters. Christin routinely represents and defends a wide range of clients in this space, including sports and recreation facility owners, coaches, instructors, youth athletic organizations, professional athletes, educational institutions, and college fraternities against various claims and suits brought against them.

Christin also has significant experience handling a wide variety of cases in the areas of insurance defense, coverage matters and civil litigation, with a focus on automobile liability and uninsured/underinsured motorist claims. She has also represented and defended clients in premises liability, homeowner's insurance, minor's compromise, and other general liability claims and suits brought against them.

Throughout her legal career, Christin has litigated cases in almost every county in the eastern portion of Pennsylvania as well as the federal courts. She has also resolved countless cases for her clients via arbitration and mediation.

In 2007, Christin earned her juris doctor from Widener University Delaware Law School. While in law school, Christin was a member of the Moot Court Honor Society and Moe Levine Trial Advocacy Society. In 2004, she graduated cum laude from Bloomsburg University.

Christin is admitted to practice in Pennsylvania as well as the United States District Courts for both the Middle and Eastern Districts of Pennsylvania. She is also a member of the American Bar Association, Pennsylvania Bar Association and the Berks County Bar Association, where she served as the past president of the Young Lawyers Section.

    • Widener University Delaware Law School (J.D., 2007)
    • Commonwealth University - Bloomsburg (B.A., cum laude, 2004)
    • New Jersey, 2008
    • Pennsylvania, 2008
    • U.S. District Court Middle District of Pennsylvania, 2012
    • U.S. District Court Eastern District of Pennsylvania, 2015
    • Pennsylvania Super Lawyers Rising Star (2019-2023)
    • American Bar Association
    • Berks County Bar Association, Young Lawyers Division, Past President
    • Pennsylvania Bar Association
    • Obtained a successful defense award involving a significant claim. Plaintiff and his wife filed a claim against their insurer for underinsured motorist benefits after Plaintiff was struck as a pedestrian by a drunk driver. Plaintiff sustained several fractures of his body and also claimed neck and back injuries and significant damages, including future medical expenses. The case proceeded to a high/low Binding Arbitration. The Arbitrator awarded the low on the case, showing that Christin and the insurer properly evaluated the claim. 
    • Obtained a favorable defense verdict at a Philadelphia Common Pleas Arbitration. Plaintiff, a healthcare provider, filed suit against the insurance company for unpaid medical bills, punitive damages, interest and attorney’s fees, for treatment it rendered to the insured’s daughter. At the Arbitration, Christin argued that the insurance company properly evaluated the claim based on whether the insured’s daughter was entitled to benefits as it had not been determined that the daughter was residing with her mother at the time of the accident. Therefore, Christin argued that Plaintiff was not entitled to punitive damages, interest and attorney’s fees. The Arbitrators agreed and only awarded the Plaintiff health provider its past medical expenses, which Christin and the insurance company stipulated to. The Plaintiff was not awarded punitive damages, interest or attorney’s fees.
    • Settled a case at Mediation for less than a third of the settlement authority. The case involved a Plaintiff allegedly slipping and falling on a slippery substance in a parking lot in Philadelphia. After Christin obtained favorable defense opinions from both liability and medical experts, Plaintiff significantly reduced the value of her claim and settled the case.
    • Obtained a favorable decision dismissing all claims and cross-claims against her client in a motor vehicle accident case in Philadelphia via a Motion for Judgment on the Pleadings. The plaintiff filed a Complaint on April 1, 2022 alleging several injuries due to a motor vehicle accident. Plaintiff sued several defendants, including the rental car company that owned one of the vehicles involved in the accident. Citing to the rental agreement and the policies covering the rental vehicle, Christin argued that the rental driver was not authorized to operate the vehicle as he rented the vehicle under false pretenses, permitted an unauthorized driver to operate the vehicle, and operated the vehicle for hire in violation of the policies. The Court ruled in the rental company’s favor finding there was no coverage under the policies pursuant to Pennsylvania case law and the policy language cited by Christin in the Motion. All claims and cross-claims were dismissed against the rental company. 
    • Obtained a favorable jury trial award in Lehigh County, Pennsylvania in a motor vehicle accident case in which the plaintiff was claiming a low back injury with almost $1 million in claimed past and future damages. Liability was admitted. The jury awarded the plaintiff just $20,000 in future medical expenses and pain and suffering. The plaintiff's counsel tried to have the jury's decision dismissed, but the court denied the request.
    • Obtained a defense verdict in Berks County, Pennsylvania following an underinsured motorist coverage jury trial. Following the motor vehicle accident, the plaintiff sustained an injury to her left heel and foot consisting of a fracture that required a plate and screws to be placed in her foot. The plaintiff was requesting a significant amount for past and future pain and suffering and future medical expenses, including a future left foot surgery. The jury returned an award in favor of the plaintiff totaling $28,000. After applying the third-party credit, the jury award was reduced down to $0.
    • Motion for Summary Judgment granted in a Declaratory Judgment action in which the plaintiff was claiming his vehicle damage was covered by his insurance policy. At the time of the loss, the plaintiff did not have collision coverage on his vehicle, only comprehensive coverage. The plaintiff argued that his vehicle was still covered by the comprehensive portion of his auto insurance policy, claiming the vehicle that rolled down a hill and struck his parked vehicle was considered a "falling object." After arguing that Pennsylvania case law and the insurance policy language did not cover the plaintiff's losses, the court agreed and granted the insurance company's Motion for Summary Judgment.
    • Obtained a defense verdict in a jury trial in Philadelphia County, Pennsylvania in which the plaintiff was claiming a neck and low back injury after being involved in a rear end motor vehicle accident. Liability was admitted. Although the plaintiff had no prior history of neck or back injuries, the jury returned an award in favor of the defesne, finding that the plaintiff failed to prove he sustained an injury that was caused by the accident. The defense expert testified that the plaintiff's MRI films from after the accident showed pre-existing findings that were not caused by the accident. Further, although the jury did not have to reach a decision on the limited tort issue, the jury also found that the plaintiff's injuries did not breach limited tort.
    • Have obtained many favorable decisions granting Motions for Summary Judgment on limited tort throughout Pennsylvania, which decisions have been affirmed on appeal to the Pennsylvania Superior Court.

Results

Summary Judgment Secured in a Case Involving a Trampoline Park Injury

We obtained summary judgment in a lawsuit arising from an injury suffered at an indoor trampoline park. During the deposition, the plaintiff admitted that there are inherent risks of engaging in trampoline activities, including the risk of being injured. Under the no-duty rule, a defendant owes no duty of care to warn, protect, or insure against risks which are common, frequent, expected and inherent in an activity. In the motion for summary judgment, it was argued that a trampoline park has no duty to protect patrons from the inherent risks of injury when jumping from a trampoline. The court opined that the no-duty rule was implicated and granted summary judgment in favor of all defendants.

Defense Verdict Obtained in Case Involving Motor Vehicle Accident

We obtained a defense verdict after a bench trial in the Philadelphia Court of Common Pleas, which found the plaintiff did not meet the definition of an insured entitled to underinsured motorist (UIM) coverage. The case arose out of a motor vehicle accident in which the plaintiff was a back seat passenger in a vehicle that was struck by the tortfeasor. After settling his bodily injury claim with the tortfeasor and with the underlying UIM carrier that insured the vehicle he was a passenger in, the plaintiff submitted a UIM claim seeking UIM benefits under his alleged sister’s UIM policy with our client. There was no dispute the plaintiff was living with his “sister” at the time of the accident. Therefore, the only issue was whether the plaintiff could show he was an insured and entitled to coverage by proving he was related to his “sister” by blood, adoption or marriage to meet the definition of a “family member” under the policy. She testified during discovery and at trial that she is not related to the plaintiff by blood, adoption or marriage. As a result of this testimony, the judge found the plaintiff failed to meet his burden of proof and entered a defense verdict for our client. 

Thought Leadership

Defense Digest

PA Superior Court Upholds Household Vehicle Exclusion in Favor of Erie When Stacking Was Not Implicated

June 30, 2026

Key Points: A household vehicle exclusion was upheld under an Erie Policy when the estate of deceased insureds sought UIM coverage when the insureds were occupying a motorcycle owned by the insureds, but the motorcycle was not covered by Erie’s Policy. The PA Superior Court distinguished Gallagher v. GEICO, in which Gallagher, unlike the Erie insured, had recovered UM/UIM, thus rendering the "household exclusion" an impermissible waiver of stacking. Here, with no UIM recovery from any source, the issue of stacking, much less impermissible waiver of stacking, never arose. In sum, the household vehicle exclusion is a valid exclusion when stacking is not implicated. In the Pennsylvania Superior Court case of Erie Ins. Exchange v. Estate of Kennedy, 350 A.3d 219 (Pa. Super. 2025), the court upheld Erie’s denial of coverage under the household vehicle exclusion in the Erie Policy when the insureds were occupying a motorcycle not covered under the policy. Dennis and Elissa Kennedy, Erie insureds, died in a single-vehicle motorcycle accident, with Dennis driving. Dennis insured the motorcycle with Progressive, which paid its liability limits to Elissa, after which Elissa sought household stacked Erie UIM coverage. Erie denied coverage under its "household exclusion" applicable to vehicles owned by insureds, but not covered by Erie's policy. The trial court granted judgment in favor of Erie on the ground that such benefits were barred by an exclusion applicable when an insured has suffered damages while occupying a vehicle owned by a relative and not covered under the policy, i.e. the household vehicle exclusion. Finding that the exclusion was valid, the PA Superior Court affirmed. The court found the facts of the case and policy exclusion analogous to the case of Erie Ins. Exchange v. Mione, 289 A.3d 524 (Pa. 2023). In Mione, a motorcyclist was injured in an accident with another vehicle whose driver was both at fault and underinsured. The motorcyclist's insurance policy did not include UM/UIM coverage. However, the motorcyclist had two household policies covering other vehicles, including stacked UM/UIM coverage, as well a household vehicle exclusion. UM/UIM benefits were therefore denied, and the motorcyclist argued that the exclusion was invalid because it did not comport with the statutory waiver requirements of Section 1738. The PA Supreme Court rejected the argument, explaining that UM/UIM coverage could not be procured in the "first instance" under the motorcyclist's household policies as “[F]or a household vehicle exclusion to be acting as an impermissible de facto waiver of stacking, the insured must have received UM/UIM coverage under some other policy first, or else is not implicated at all.” The motorcyclist had not received any UM/UIM benefits under his own motorcycle policy, so there was nothing for the UM/UIM benefits of the household policies to "stack on" to, and as such, Section 1738 was not implicated. The court also distinguished the case from Gallagher v. Geico, 201 A.3d 131 (Pa. 2009), in which a motorcyclist was injured in an accident caused by another driver who was underinsured. The motorcyclist had purchased two policies, each of which provided stacked UM/UIM benefits. The first policy covered only the motorcycle; the second covered two automobiles, while also containing a "household exclusion," which precluded UM/UIM benefits. The PA Supreme Court held that the exclusion was invalid because the resulting waiver of UM/UIM coverage did not comport with the statutory requirements of Section 1738. The court distinguished the Kennedy’s case from Gallagher as the Kennedy’s were attempting to stack UM/UIM coverages from (a) the Progressive Motorcycle Policy under which Dennis Kennedy was the only insured, and (b) the Erie Policy under which Dennis Kennedy and Elissa J. Kennedy were the insureds. Crucially, the court found that the party from whom the right to stack UM/UIM benefits under the Erie policy was derived (Elissa J. Kennedy) was not an insured under the motorcycle policy. In other words, no one paid for Elissa J. Kennedy to receive UM/UIM benefits under the motorcycle policy, so that policy afforded her no contractual right to such coverage in the first instance. The court further reasoned that the "miscellaneous vehicle" exclusion in the Erie Policy was valid because the insured, Elissa J. Kennedy, had not first received UM/UIM coverage under Dennis Kennedy's Motorcycle Policy. In conclusion, the Court found Gallagher inapposite, and Mione compelled the affirmance of the trial court's ruling upholding Erie’s denial of coverage pursuant to the household vehicle exclusion. Christin is a Shareholder in our King of Prussia, Pennsylvania, office. She can be reached at 610-354-8279 or clkochel@mdwcg.com.

Firm Highlights

Thought Leadership

Two Tracks, No Preclusion: Ohio Supreme Court Preserves Separate Damages Claims After Chapter 2506 Appeals

The Supreme Court of Ohio has clarified that an administrative appeal under Ohio Revised Code Chapter 2506 does not bar a separate action for damages and declaratory relief that could not have been pursued in the administrative appeal. The Ohio Supreme Court considered Sheetz, Inc. v. Centerville (2026-Ohio-3531) as a result of a certified question from the Southern District of Ohio. The question was whether Sheetz, the gas station/convenience store brand, was barred from seeking damages in a separate action since damages were not sought in their administrative appeal. Ultimately, the Ohio Supreme Court ruled that res judicata does not bar a separate action for damages after ruling on an administrative appeal because R.C. Chapter 2506 is limited to judicial review and cannot grant affirmative relief. The case arose after Centerville’s city council rejected a site plan proposed by Sheetz, Inc. that had received unanimous approval from the City’s planning commission. Sheetz filed an administrative appeal pursuant to R.C. 2506 in the Montgomery County Court of Common Pleas, and two months later filed a complaint for damages and declaratory relief under 42 USC § 1983 as a takings action with the city, city council, and other objectors as improper takings and a violation of due process, as well as interference with business and contractual relationship. The city and city council removed the § 1983 action for damages to federal court. Montgomery County Court of Common Pleas reversed the city council’s denial, and allowed the Sheetz project to move forward. Upon that ruling, the federal court issued a show-cause order questioning whether the § 1983 action was barred by the doctrine of res judicata via claim preclusion (which includes all theories of recovery).  Sheetz argued that Ohio courts of common pleas do not have authority to award damages or declaratory relief as party of the R.C. Ch. 2506 appeal, therefore res judicata could not be triggered to apply to the § 1983 action. Additionally, Sheetz moved to certify the issue to the Ohio Supreme Court, citing differing results between the second and sixth districts on this same issue. Centerville approached the question, not from a claim preclusion standpoint, but from the holding in Grava v. Parkman, Twp which states that a final judgment rendered on the merits bars all subsequent action based on the same transaction or occurrence.  In yet another approach, an objector argued that claim preclusion was satisfied because Sheetz could have raised its damages claims in the administrative appeal – Sheetz disagrees. In their analysis, the Supreme Court of Ohio broke down the elements of a claim preclusion analysis: 1) a prior final, valid decision on the merits by a court of competent jurisdiction; (2) a second action involving the same parties, or their privies, as the first; (3) a second action raising claims that were or could have been litigated in the first action; and (4) a second action arising out of the transaction or occurrence that was the subject matter of the previous action. The Court held that R.C. Ch. 2506 does not permit a party to argue damages as R.C. Ch. 2506 limits the common pleas jurisdiction as if it were sitting on appeal, and therefore can only affirm, reverse, vacate, or modify the appealed order, or can remand the case to the administrative body. Further, the Court held that Grava’s conclusion that a final judgment precludes additional litigation for different relief is inapplicable under this fact pattern because it was meant only to apply to those matters in which the plaintiff brings the exact same case twice, but for new relief. The Court found Grava was inapplicable because Sheetz could have requested damages or declaratory relief in the R.C. 2506 appeal. Therefore, Grava would be nothing more than dicta if it even did apply. Going further, the Ohio Supreme Court disavowed Sixth Circuit precedent which, in reliance on Grava and other district court decisions, permitted an owner to seeking relief under 42 U.S.C. § 1983 alongside an administrative appeal. See Moore v Hiram Twp., 988 F.3d 353 (6th Cir.2021). The Ohio Supreme Court found that the Sixth Circuit had disregarded a critical decision in Community Concerned Citizens, Inc. v. Union Twp. Bd. of Zoning Appeals, 1993-Ohio-115, which clearly held that a R.C. Ch. 2506 appeal cannot be combined with a complaint seeking other claims for relief. Id. at ¶ 11. To that end, the Ohio Supreme Court has determined that the decisions Moore relied on (outside of Grava) are no longer good law, and that Moore was wrongly decided. The decision draws a clear procedural boundary: Chapter 2506 provides judicial review of an administrative decision, not a forum for independent claims seeking affirmative relief. Although Grava may place claims arising from a single transaction within the potential scope of claim preclusion, those claims are not barred unless the complete claim-preclusion test is satisfied. Because Sheetz could not have pursued damages or declaratory relief in its Chapter 2506 appeal, the separate action was not precluded. The remaining question for practitioners looking to apply or defend against this exception is when does the statute of limitations begin to run on damages and declaratory relief claims related to an administrative decision on appeal? A takings action in federal court has a 2-year statute of limitations, or as a state claim, 4 years (like the other tortious claims raised therein). Correlating this case with others, an administrative appeal will not likely toll the statute of limitations on claims based on a final decision by a municipal authority. Therefore, practitioners should look for these cases to be brought simultaneously.

Thought Leadership

Pennsylvania Supreme Court to Review Whether Legal Malpractice Claims May Be Recast as Breach of Contract Claims

The Pennsylvania Supreme Court recently granted allowance of appeal to consider whether a plaintiff may pursue a breach of contract claim against an attorney based on allegations that the attorney failed to provide competent legal services. The issue is significant in professional liability litigation because it concerns whether a plaintiff may avoid the statute of limitations applicable to professional negligence claims by characterizing the alleged misconduct as a breach of contract. Antoine Poteat retained attorneys Gary Asteak and Nino V. Tinari to represent him in a criminal matter. After his conviction was subsequently overturned through a Post Conviction Relief Act proceeding, Poteat filed suit against his former attorneys alleging that they breached their retainer agreements by failing to provide competent legal services. The attorneys argued that the claims sounded in professional negligence, rather than breach of contract, and were therefore time-barred. The trial court dismissed Poteat’s complaint, but the Superior Court, sitting en banc, reversed. The Superior Court held that the gist-of-the-action doctrine did not bar Poteat’s breach of contract claim because the alleged failure to provide competent legal services could constitute a breach of the parties’ agreement. The Court further held that a legal-services agreement contains an implied duty requiring an attorney to provide competent legal services, even where the agreement does not contain an express provision requiring such services. The Pennsylvania Supreme Court granted review in July 2026 and will consider whether the Superior Court’s decision conflicts with Pennsylvania precedent distinguishing contract and tort claims, including Bruno v. Erie Insurance Co. The Supreme Court will also address whether a plaintiff may maintain a breach of contract claim based on an implied duty to provide competent legal services without identifying a specific contractual provision that was breached. The Supreme Court’s decision could have significant implications for professional liability litigation in Pennsylvania, particularly where plaintiffs seek to characterize claims arising from alleged professional negligence as contractual claims.

Thought Leadership

The Search-Incident-to-Arrest Doctrine Does Not License Strip Searches

In Beatty v. Gardner, No. 25-2860 (3d Cir. Sept. 16, 2026), Kyle Beatty sued police officers Clinton Gardner and Calvin Irvin under 42 U.S.C. § 1983 after they stopped, arrested, and searched him three times during a drug investigation in Williamsport, Pennsylvania. The officers initially smelled marijuana coming from the car in which Beatty was sitting and observed marijuana residue, giving them probable cause to arrest him. Beatty consented to the first pat-down, and the second search was conducted incident to his lawful arrest; neither search uncovered weapons or contraband. The officers then transported Beatty to the police station solely to strip-search him, but the strip search also revealed nothing. The District Court granted the officers summary judgment, concluding that the initial stop, arrest, and first two searches were reasonable and that qualified immunity protected the officers from liability for the strip search. The Third Circuit affirmed, but held that the strip search itself violated the Fourth Amendment. The court concluded that the search-incident-to-arrest doctrine does not automatically permit officers to strip-search an arrestee outside the jail or prison setting. Because strip searches are highly intrusive and the traditional justifications for searches incident to arrest (officer safety and preservation of evidence) did not justify the search of Beatty, the officers generally needed either the arrestee’s consent, exigent circumstances, or a warrant supported by probable cause to believe that a search beneath the clothing would reveal weapons, contraband, or evidence. Here, the officers had none of those justifications. Nevertheless, the court held that qualified immunity barred damages liability because, at the time of the search, the right against a warrantless strip search of an arrestee outside the institutional setting was not clearly established by Supreme Court or Third Circuit precedent. The court likewise upheld qualified immunity on Beatty’s First Amendment retaliation claim and affirmed summary judgment for the officers.