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
Superior Court Upholds Stacking Waiver Despite Substituted‑Vehicle Policy Amendment
July 21, 2026
In this non-precedential decision, the Pennsylvania Superior Court confirmed the precedent set by prior decisions of the Pennsylvania Supreme Court that substitution of an automobile on an insurance policy does not require that a new waiver of stacked underinsured motorist coverage in order for the previously, valid stacking waiver to remain valid. In this case, Erie had issued an insurance policy to Beutler insuring four vehicles and Beutler had signed a waiver of stacked UIM coverage. Later, Beutler had purchased a new vehicle, replacing one of the four previously listed on the policy. Erie issued an amended policy indicating that the prior auto had been “deleted” and the new auto had been “added.” Beutler later died in a motor vehicle accident and his estate made a claim for stacked UIM benefits under the Erie Policy. Erie brought a declaratory judgment action asking the court to confirm that Beutler’s estate was not entitled to stacked UIM coverage. The court affirmed the trial court’s grant of summary judgment in favor of Erie where the trial court had held that the original stacking waiver signed by Beutler remained in effect on the date of the accident because when he had substituted the new auto, no new UIM coverage was purchased and a new waiver was not required. The estate argued that Erie’s usage of “deleted” and “added” on the amended declarations page rendered the amendment a purchase of new UIM coverage and not a substitution, requiring Erie to obtain a new executed stacking waiver. However, the Superior Court noted, “[r]egardless of the language used by the amendment, the policy covered four vehicles prior to the amendment and covered four vehicles after the amendment, with exactly the same amount of monetary coverage.” The Superior Court also affirmed the trial court’s granting of a protective order in favor of Erie, protecting Erie from discovery sought by the estate that would “answer the question of why the . . . amendment indicated ‘AUTO 3 DELETED. AUTO 5 ADDED’ as opposed to using the word ‘replacement’ or ‘replaced’.” While the estate argued that such discovery was reasonably calculated to lead to the discovery of admissible evidence, the Superior Court disagreed and noted that the estate failed to explain how Erie using the word “replacement” would constitute a purchase of UIM coverage and thereby requiring a new stacking waiver. While this decision of the Superior Court has been marked as “non-precedential,” it is nonetheless available to be cited as persuasive authority. The decision here confirms that the relevant analysis as to whether a new UIM stacking waiver required is the amount of UIM coverage at issue, and whether there has been an expansion or not. What the Superior Court makes clear, however, is that the language used in the policy amendments has no bearing on this analysis.
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.
