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
Public Policy Alone Will Not Negate an Insurer’s Duty to Defend and/or Indemnify an Insured Accused of Facilitating Sex Trafficking
November 3, 2026
The Pennsylvania Supreme Court, upon certification from the Third Circuit Court of Appeals, determined that, though sex trafficking is criminalized under Pennsylvania law, neither an insurer’s duty to defend nor its duty to indemnify are abrogated solely upon public policy grounds. Four women had alleged that they were sex trafficked when they were minors at a number of Philadelphia-area hotels including the Roosevelt Inn. They sued the hotel among other parties. The hotel was insured through various insurers at the time of the alleged sex trafficking. After defending the hotel in the underlying lawsuits brought by the women pursuant to reservations of rights, the insurers sought declaratory judgment that they did not owe a duty to defend or indemnify the hotel because if the allegations were proven to be true (i.e., the hotel aided or facilitated sex trafficking), it would be against public policy to defend or indemnify the hotel. The Supreme Court declined to extend a holding of its previous plurality decision that, based on public policy grounds, an insurer had no duty to defend or indemnify its insured who had provided heroin to an individual who died as a result of taking the drug. The court refused to “divine an overriding public policy pronouncement by the General Assembly by virtue of its enactment of the Human Trafficking Law.” It further stated that it did not believe that “it is within the purview of this Court to rank the magnitude of the public policy underlying the various crimes defined in the Crimes Code.” As a result, the court invited the insurers to ensure their policies included exclusions which would prevent coverage for the type of criminal actions that had been alleged against the insureds. Finally, the court reiterated that the duty to defend under an insurance policy is analyzed solely from the comparison of the allegations within the complaint to the terms of the insurance policy.
The Tolling Trap: Filing Alone Will Not Toll the Statute Without Good-Faith Service
October 28, 2026
The Eastern District of Pennsylvania recently reinforced a critical limitation on bad faith claims, holding that a timely filing alone will not preserve a cause of action absent a good-faith effort to serve the original process. The plaintiff had presented a claim for underinsured motorist benefits to his auto insurer. The insurer evaluated the claim and determined that the plaintiff’s accident-related damages did not exceed the bodily injury liability insurance limits of the at-fault driver and denied his claim. Among other claims, the plaintiff sought to present a claim for insurance bad faith under 42 Pa. C.S.A. § 8371, to which a two year statute of limitation applies. He first filed a praecipe for writ of summons before the expiration of the statute of limitation. However, the plaintiff did not attempt to serve the praecipe or writ until after the statute of limitations had expired. Additionally, the service failed as the plaintiff had mailed the original process to an incorrect address. Despite receipt of the Postal Service’s failure to deliver the original process, the plaintiff did not attempt to re-serve the writ. Two months later, the plaintiff filed a complaint and then successfully served that complaint. The insurer sought to dismiss the plaintiff’s bad faith claim as time-barred by the statute of limitations. The district court agreed. Though the plaintiff had filed a praecipe for a writ of summons prior to the expiration of the statute of limitations, the statute is only tolled if there is a good faith effort to serve that original process. In this case, the court determined that the plaintiff had failed to perform a “good faith effort to serve the original process”. Additionally, though the filing and service of a complaint can serve as alternative original process when the lawsuit is commenced by the filing of a praecipe for a writ of summons, the plaintiff filed his complaint after the statute of limitations had expired. The plaintiff’s bad faith claim was therefore determined to be barred by the statute of limitations and dismissed by the court, with prejudice. A key takeaway for the defense is not to assume that the statute of limitations has been successfully tolled by a plaintiff merely because a praecipe for a writ of summons or complaint has been filed prior to the expiration of the statute. A filed complaint or writ is only part of the equation. The defense should carefully review the docket and filings to confirm that the plaintiff also performed the requisite good faith effort to serve that original process. A thorough review of the docket may reveal that the plaintiff failed to make the good-faith service efforts necessary to toll the statute of limitations.
