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Defense Digest

On the Pulse…Marshall Dennehey Is Happy to Celebrate Our Recent Appellate Victories*

Defense Digest, Vol. 27, No. 4, September 2021

September 1, 2021

Kimberly Berman (Fort Lauderdale, FL) succeeded in obtaining a dismissal by the Fourth District Court of Appeal of an appeal of an order denying emergency relief in our client’s action to foreclose a claim of lien and for damages and breach of contract against a former condominium unit owner. The appellant attempted to revive an untimely appeal of a prior order by obtaining a new order to the same effect, but the appellate court dismissed the appeal and granted the association its motion for entitlement to appellate attorney’s fees. Sawyers v. Lakeside Manor North Association, No. 4D21-225 (Fla. 4th DCA Apr. 7, 2021).

Kimberly, Shaggy Nowroozpour and Michael Packer (Fort Lauderdale, FL) obtained an affirmance by the Fourth District Court of Appeal of a final judgment entered for an insurance carrier. The case involved an alleged assignment of benefits for a water loss, where the county court found the plaintiff lacked standing to sue. Empire v. United Property & Casualty Company, No. 4D21-65 (Fla. 4th DCA Apr. 14, 2021).

Kimberly and Craig Hudson (Fort Lauderdale, FL) succeeded in the Fourth District Court of Appeal. In this case, the court affirmed a final dismissal order of third-party claims for tortious interference with an advantageous business relationship, civil conspiracy to commit tortious interference with a contract, aiding and abetting tortious interference with a contract, and vicarious liability against a law firm and its lawyers who filed the underlying lawsuit against the appellant. Jallali v. Zhou, 4D20-5 (Fla. 4th DCA Apr. 22, 2021).

Kimberly and Stephen Poljak (Fort Lauderdale, FL) obtained the Fourth District Court of Appeal’s affirmance of a final judgment in favor of an insurance carrier in an insurance coverage dispute. The trial court found that there was no coverage under a CGL policy for the vicarious liability of an insured when its employee had committed an intentional act in the course and scope of his/her employment; the Fourth District agreed. Slocomb v. Old Dominion Insurance Company, 4D20-1515 (Fla. 4th DCA May 6, 2021).

Kimberly, James Hanratty and Robert Williams (Jacksonville, FL) convinced the First District Court of Appeal to affirm a final summary judgment for a restaurant/bar owner in a slip and fall case. The appellant argued that a restaurant/bar owner should have warned a patron about the barstool being a dangerous condition and of the slippery dance floor, but presented no evidence that the owner was in a superior condition than the appellant. Aljuni v. Blackfinn Jax, LLC, No. 1D20-946 (Fla. 1st DCA Apr. 20, 2021).

Kimberly and Ryan Burns (Fort Lauderdale, FL) persuaded the Fifth District Court of Appeal to affirm a final dismissal order of a wrongful death product liability action. The Estate had filed the lawsuit two years after the statute of limitations expired. The Estate claimed the limitations period was tolled due to the alleged adverse interest of the child’s mother, who had been abused by the deceased prior to the accident on an agricultural production site. The trial court dismissed the case, with prejudice, after giving the Estate five attempts to amend. The Fifth District affirmed the dismissal and dispensed with oral argument that same day. Rude v. Morbark, Inc., Case No. 5D20-976 (Fla. 5th DCA Apr. 20, 2021).

Audrey Copeland (King of Prussia, PA) persuaded the Commonwealth Court to dismiss the claimant’s untimely appeal where the claimant did not allege any basis for relief nunc pro tunc. King v. Olympic Tool and Machine Corp. (WCAB), No. 48 CD 2021 (Pa. Cmwlth., May 18, 2021).

Audrey and Estelle McGrath (Pittsburgh, PA) won an appeal where the Pennsylvania Supreme Court denied a newspaper delivery person’s petition for allowance of appeal on March 30, 2021. The claimant had filed a claim petition in 2018, alleging that he suffered serious injuries to his right leg after slipping and falling on ice when he was delivering newspapers. The newspaper asserted the claimant was an independent contractor. The case was bifurcated to determine whether the claimant was an employee. After fully litigating the issue, the Workers’ Compensation Judge found in favor of the newspaper and found that the case was not so different than the seminal case of Johnson v. WCAB (DuBois Courier Express), 631 A.2d 693 (Pa. Cmwlth. 1993). The Johnson court had held that a newspaper carrier was an independent contractor because the newspaper did not exercise substantial control over his activities. The claimant appealed to the Workers’ Compensation Appeal Board. After hearing argument and reviewing the parties’ briefs, the Board affirmed the judge’s decision and order. The claimant appealed to the Commonwealth Court, urging the court to consider the evolving nature of the newspaper delivery business in rendering its decision. The court refused to do so and highlighted the lack of control by the newspaper because there was no prohibition on delivering competing newspapers or enlisting a substitute without prior notice or permission. The Commonwealth Court’s decision, which was issued as a non-precedential opinion, is the latest in an unbroken line of similar cases holding that newspaper carriers are independent contractors. The claimant’s suit ended when the Pennsylvania Supreme Court denied the petition for allowance of appeal.

Walter Kawalec (Mount Laurel, NJ), of our appellate group, and Leonard Leicht and Michelle Michael (Roseland, NJ) were successful before the the New Jersey Appellate Division. The plaintiff filed suit against her employer, a governmental agency, alleging she was subject to discrimination under the New Jersey Law Against Discrimination based upon her disability and that she was subject to retaliation for filing a previous discrimination suit. She further asserted aiding-and-abetting claims against fellow employees. The case was dismissed via summary judgment, and the plaintiff appealed. The Appellate Division accepted our argument that the failure to move the plaintiff to a position she desired did not constitute an adverse employment action or failure to accommodate as she suffered no adverse effect on her salary or benefits, and did not materially alter her working conditions. Further, the court addressed the concerns plaintiff’s physician had expressed when she sought the accommodation, even though she was not transferred to a position in which she preferred to work, and agreed these claims were properly rejected by the trial Judge.

Walt, Howard Mankoff and Michelle Michael (Roseland, NJ) were successful before the New Jersey Appellate Division. The plaintiff is a former employee of a non-profit agency that provides services to disabled individuals. She filed suit against her former employer and its manager, alleging gender discrimination and retaliation for filing a workers’ compensation claim. As discovery progressed, thousands of pages of discovery were exchanged, which demonstrated that legitimate, long-standing performance deficiencies were the actual basis for her termination. The defendants filed for summary judgment prior to the end of the discovery period, and the Law Division granted the motion, finding no reason not to grant the immediate dismissal, especially as the plaintiff failed to even respond to the statement of material facts. On appeal to the Appellate Division, the court affirmed the dismissal, rejecting the plaintiff’s arguments that the motion judge engaged in a subjective analysis of the facts and thereby made factual findings on disputed issues, and that the motion judge erred by granting the motion before discovery was complete. The court found that the plaintiff failed to demonstrate, with any degree of particularity, that further discovery would supply the missing elements to her cause of action. The court further found that the plaintiff failed to demonstrate a prima facie case of gender discrimination or workers’ compensation retaliation given the unrebutted facts provided by the defendants.

Walt and Lynne Nahmani (Mount Laurel, NJ) successfully obtained a reversal of a trial court’s denial of our motion to file a third-party action. We represented a nursing home who is alleged to have caused significant injury to a former patient, and we sought to bring a third-party action against other medical providers who could potentially be liable for the alleged injury. The trial judge rejected the motion on the grounds that it should have been brought earlier and that the third-party action would cause a delay in the litigation. On an interlocutory appeal granted by the Appellate Division, the appellate court reversed. It held that because the COVID-19 pandemic caused a closure of the courts and created a massive backlog of cases, the delay was inevitable, so it could not support a denial of the request to add the third parties to the action. As such, the Appellate Division found an abuse of discretion and remanded with instructions to permit the third-party action.

Walt and Walter Klekotka (Mount Laurel, NJ) successfully obtained and affirmance in the Appellate Division of a grant of summary judgment. The case involved a plaintiff who, on a dark and rainy night, slipped and allegedly injured himself while walking quickly on a grassy alleyway between two buildings toward the entrance to his apartment. Our clients were a construction company and its owner who were doing work in one of the buildings. In his answers to interrogatories and depositions, the plaintiff failed to identify anything that caused the slip other than wet grass. On the motion for summary judgment, the plaintiff sought to introduce an affidavit that placed blame for the fall on an unidentified “tar-like substance” and construction debris. The Law Division judge disregarded the affidavit based on the “sham affidavit” doctrine and found no basis to find liability against any defendant because the plaintiff failed to identify the cause of his alleged fall. The Appellate Division affirmed the Law Division judge’s decision, finding no error in the analysis or in rejecting the plaintiff’s affidavit.

Karen Grethlein and Shane Haselbarth (Philadelphia, PA) obtained a dismissal of a consumer fraud class action. Our clients, a national firm and its principal, specialize in identifying and reclaiming lost property for consumers who are unaware that such lost property exists. The plaintiff brought claims under the Pennsylvania Unfair Trade Practices Consumer Protection Law (UTPCPL) and for fraudulent inducement, arguing that the business model was deceptive because consumers could recover their own property without paying for the ease and convenience of having the defendant business work on their behalf. Not surprisingly, the district court found that the plaintiff’s serial complaints failed to allege anything “more than Defendants’ expertise,” and that there was no factual basis to support the notion that consumers are unduly influenced or misled. On appeal, the Third Circuit affirmed the dismissal, expressly noting that the defendants made no misrepresentation at any time, and the UTPCPL and fraud claims were dismissed without merit. DeSimone v. U.S. Claims Servs., Inc., 2020 WL 2556949 (E.D. Pa. May 20, 2020), aff’d 2021 WL 1662779 (3d Cir. Apr. 28, 2021).

 

Defense Digest, Vol. 27, No. 4, September 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

Legal Update for Special Education Law: Recent Positive Outcomes From the Group

Hearing Officer Confirms District Acted Appropriately Under IDEA and Section 504 William J. McPartland (Scranton) obtained a finding in favor of our client, a school district, on all issues following a due process hearing. The parent had filed a due process complaint alleging that the school district had breached its child find duty under the IDEA and Section 504, that the school district had discriminated against the student on the basis of disability in violation of Section 504, and that the school district had denied a free and appropriate public education to the student both by developing inadequate IEPs and via an actionable procedural violation.  Specifically, the student had received a Section 504 evaluation in October 2023, after a number of behavioral infractions culminating in a fight in September 2023, was identified as having anxiety and a sleep disorder, and received appropriate Section 504 accommodations. The student had never previously demonstrated signs of a learning disability, and the parent denied the school district permission to evaluate the student for special education needs in November 2023, and January 2024. The parent granted the district permission to evaluate the student in October 2024, after a private psychologist diagnosed the student with Attention Deficit Hyperactivity Disorder, possible Oppositional Defiance Disorder, a learning disorder, and anxiety. The school district issued a special education evaluation report in December 2024, finding that the student had an emotional disturbance and other health impairment, and an IEP providing an itinerant level of emotional support, as well as instruction in academics and social skills, was issued in January 2025, and amended in February, March, and April 2025. The student withdrew from the school district in April 2025, to attend a cyber charter school. The hearing officer determined that the school district had not violated its child find duty to the student in violation of either the IDEA or Section 504 where the district developed a Section 504 plan for the student within a month and a half of the parent’s first request for a Section 504 evaluation and where the parent repeatedly denied consent to conduct an IDEA evaluation of the student. The hearing officer noted that the student’s sporadic record of behavioral infractions prior to September 2023, did not suggest that the student had a disability prior to the parent’s initial request for an evaluation. The hearing officer further determined that no evidence had been produced to suggest that the student was discriminated against on the basis of disability in violation of Section 504. Additionally, the hearing officer determined that the IEP offered to the student was substantively adequate and that, to the extent the social and emotional programming offered by the school district was not received by the student, this resulted from the parent’s refusal to accept the same. The hearing officer finally determined that the school district did not commit an actionable procedural violation by delaying development of an IEP for the student where the parent repeatedly denied consent to evaluate the student. Court Dismisses Three of Four Claims Against School District Christopher J. Conrad and Daniel P. McGannon (Harrisburg) achieved a significant early victory on behalf of a school district client in. The team successfully obtained dismissal of three of the four claims asserted in the plaintiff’s amended complaint. The former district superintendent brought multiple claims arising out of his alleged “forced resignation,” including age discrimination under the ADEA, a Section 1983 Equal Protection claim, a Pennsylvania Whistleblower claim, and breach of contract. On behalf of the district, the defense team moved to dismiss the complaint in part, arguing: The plaintiff failed to plead sufficient facts to support a prima facie case of age discrimination. The equal protection claim was barred because the ADEA provides the exclusive federal remedy for age-based employment claims. The breach of contract claim could not stand because the underlying employment agreement had expired prior to the alleged breach. The court agreed, dismissing the ADEA, equal protection, and breach of contract claims in their entirety. As a result, only a single claim under the Pennsylvania Whistleblower Law remains pending. This outcome substantially narrows the scope of the litigation and positions the client for a more efficient defense moving forward.

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. 

Thought Leadership

Featured Conversations... Key Takeaways from A.M. Best’s Webinar on the Misuse Defense in Product Liability Claims, Featuring Michael Salvati

Michael Salvati, shareholder in our Philadelphia office, was a panelist for the April A.M. Best webinar, “The Misuse Defense: Strategic Approaches to Defending Product Liability Claims for Insurers.” During the program, Michael and his fellow panelists offered practical, jurisdiction‑specific guidance on how misuse and failure‑to‑warn theories intersect in modern product liability litigation. Michael emphasized the unique challenges these claims present—particularly in states like Pennsylvania, where evidentiary rules diverge sharply from those applied in many other jurisdictions. Failure to Warn as the “Flip Side” of Misuse Salvati explained that failure‑to‑warn allegations often arise as a direct counter to a misuse defense. As he noted, “If our misuse defense is that the plaintiff didn't use a product properly or safely, then the failure to warn claim is that we didn't tell them how to use it properly.” He emphasized that these claims can stem from either the absence of warnings or criticisms of existing warnings, such as insufficient specificity or lack of clarity about risks. Pennsylvania’s Unique Evidentiary Landscape One of Salvati’s most notable points was the stark difference in how Pennsylvania treats evidence of compliance with industry standards. He highlighted that Pennsylvania is “one of the only states…where that evidence is not admissible” in strict liability cases. Manufacturers cannot rely on compliance with ANSI, UL, ISO, or even federal safety standards to defend the product against a strict liability claim—because the focus is solely on the product itself, not the manufacturer’s conduct. Salvati acknowledged the challenge this creates for defense counsel and clients who expect such compliance to carry weight. Understanding the Three Defect Theories Salvati also walked through the three primary defect theories recognized in many jurisdictions: - Design defect – a flaw in the product’s intended design - Manufacturing defect – a deviation affecting a specific unit - Failure to warn – inadequate instructions or warnings He noted that warnings claims are increasingly significant and sometimes stand alone when design or manufacturing theories are weak. As he put it, plaintiffs often default to warnings claims because “the default position seems to be, ‘If I got hurt, there must be something wrong.’” Warranties and State‑by‑State Variations Salvati addressed how breach‑of‑warranty claims fit into the broader framework, explaining that implied warranties—such as merchantability—often overlap with strict liability in Pennsylvania. He emphasized the importance of understanding local nuances, as warranty law and admissibility rules vary widely across states. Looking Ahead: The Growing Importance of Warnings In his closing remarks, Salvati stressed that warnings should never be treated as an afterthought in product liability defense. He observed that warnings‑only claims are becoming more common and urged manufacturers and insurers to continually evaluate the clarity and completeness of their instructions and warnings. His takeaway: “We should always be talking about what are the instructions that come with our products…to bolster a misuse defense.” Listen to the complete webinar here: https://www3.ambest.com/conferences/events/eventregister.aspx?event_id=WEB1074.