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Defense Digest

On the Pulse…Important and Interesting Litigation Achievements…We Are Proud of Our Attorneys for Their Recent Victories*

Defense Digest, Vol. 28, No. 12, December 2022

December 1, 2022

CASUALTY DEPARTMENT

Ray Freudiger and Donielle Willis (Cincinnati, OH) obtained summary judgment in favor of our client in a personal injury action for injuries that occurred on municipal property. The plaintiff was knocked unconscious by a falling tree at a local park and alleged her injuries should be covered under the theory of negligence. Ray and Donielle successfully argued that any injuries were not covered due to Ohio’s immunity statute, R.C. 2744, and the recreational user statute. The court reiterated the recreational user statute language, which states that no owner, lessee, or occupant of premises owes any duty to a recreational user to keep the premises safe for entry or use. R.C. §1533.181(A). Further, “Premises” includes land owned by municipalities and the state. Thus, the court awarded summary judgment in favor of our insured.

Ray and Donielle also won summary judgment in a Hamilton County slip and fall case where the plaintiff alleged severe injuries and damages against a retail grocery store because she slipped and fell on an unknown wet substance in the store. Ray and Donielle argued there was no evidence that the plaintiff knew what caused her fall, that the store created the hazard, or that the store had actual or constructive notice of the hazard. The court agreed and granted summary judgment in favor of our client.

Finally, Ray and Donielle obtained a complete summary judgment in favor of our client in a slip and fall case against a liquor store. The plaintiff alleged her damages should be covered after she stepped into the store’s entrance doorway and slipped and fell. At best, the plaintiff related the cause of her fall to be rain tracked in from the outside. Ray and Donielle successfully wrote and argued that rain is an open an obvious condition. The court determined that plaintiff had not presented any contrary evidence and, thus, awarded summary judgment in favor of our insured.

Harold Moroknek and Ephraim Fink (Westchester, NY) obtained a defense verdict in a trial in a case against Greyhound for alleged for breach of contract. The plaintiff claimed he and his family were subjected to many alleged unsavory conditions and ordeals during their trip from Tennessee to Connecticut when they had to purchase public transportation tickets after their car broke down. The plaintiff claimed the bus depots along the way were unsafe, failed to enforce mask mandates and exposed his children to people exhibiting odd behavior. The plaintiff asserted this was a violation of the terms that Greyhound promised customers when they purchased tickets, by what is contained on their website, and by what their customer service department orally promised over the phone. The plaintiff eventually refused to ride the bus to Connecticut by getting off in North Carolina. Harold and Ephraim argued, and presented client testimony, that the plaintiff had used Greyhound many times before, had purchased non-refundable tickets, and was not permitted to claim emotional damages from a breach of contract claim. They also maintained, absent provisions in the contract language of the ticket or elsewhere, Greyhound could not be held responsible for breach of any customer travel condition promises that were beyond its control, including unavoidable COVID-19 pandemic issues, which caused limited depot hours, crowding of non-customers into depots, and difficulty with 100% compliance with mask mandate enforcement—it has been common for the public to pull down masks below their nose from time to time. Magistrate Moyher of the Superior Court in Middletown, Connecticut, ruled for the defendants on the same day as the hearing.

Christopher Power (Long Island, NY) won a summary judgement motion in New York County. The plaintiff was an employee at a restaurant in the Empire State Building. As he exited a freight elevator on the 28th floor, he slipped and fell on a foreign substance on the cement floor. The plaintiff sued the Empire State Building and LinkedIn, which leased office space on the 28th floor. LinkedIn impleaded our client, ISS, the cleaning service for the premises. The plaintiff and the Empire State Building then impleaded ISS as well. Chris argued that ISS was only responsible for cleaning the leased space of LinkedIn, and he proved that where the plaintiff fell was not within that leased space. LinkedIn then voluntarily let ISS out of the case. The plaintiff and the Empire State Building failed to put in any opposition papers to Chris’s motion. The court granted summary judgment, dismissing the complaint against ISS.

Christopher Power also obtained a voluntary discontinuance from a plaintiff’s attorney after taking the plaintiff’s deposition and subpoenaing an investigator who took physical evidence from the insured’s premises. The plaintiff was a corporate attorney for an affiliate of our client. While standing in the lobby of her office during a hurricane, a piece of metal flew off an adjacent building and through the plate glass window of the lobby, shattering the glass and severely cutting the plaintiff on her face and body. She sued our client and the landlord of the building. Before the plaintiff’s deposition, Chris’s client advised him that a few weeks after the incident, the plaintiff had an investigator come to their office, take photographs and measure the window. The investigator was also taken to a utility room (with the plaintiff present) and was given possession of the piece of metal that struck the window. At her deposition, the plaintiff testified she didn’t know what caused the window to break. Chris asked her many questions about this piece of metal and even showed her a photo of it. She denied any knowledge of it. Chris’s last question to the plaintiff was, “Is it your sworn testimony that the private investigator did not take this piece of metal from my client’s premises?” The plaintiff’s answer, “That’s correct.” Because of the COVID pandemic, the client was logging everyone that came into their office. The client had the name and a copy of the investigator’s driver’s license. Chris served a subpoena on the investigator. The following day, the plaintiff’s attorney called Chris and asked him to withdraw the subpoena, or he was filing a motion to quash it. Chris offered some advice to the plaintiff attorney: “You have too much of a good reputation. Pack up this file, give it back to the plaintiff, and tell her you are not representing her.” Two hours later, Chris received a call from the plaintiff’s attorney: “I’m taking your advice. I’m discontinuing the lawsuit.” A stipulation of discontinuance was received and filed with the court. The file was closed with no payment.

 

HEALTH CARE DEPARTMENT

Dean Aronin (New York, NY) obtained dismissal in New York Supreme Court, Westchester County, on behalf of a distributor of a medical product. An individual sued various medical facilities and physicians for medical malpractice, alleging the treatment fell below the standard of care. A rehabilitation facility filed a third-party complaint against the distributor, seeking common law indemnification and contribution. The rehabilitation facility claimed the distributor distributed a recalled product containing bacteria that contributed to the individual’s injuries. Prior to the deposition of his client, Dean filed a motion for summary judgment to dismiss the third-party complaint based on an affidavit from the distributor attesting to the fact that it did not distribute the recalled product to the injured party. After the motion was fully briefed, the court granted Dean’s motion for summary judgment, dismissing the distributor from the case. The court determined there was no admissible evidence that the distributor distributed the recalled product to the individual.

 

PROFESSIONAL LIABILITY DEPARTMENT

Brigid Alford and Christopher Woodward (Harrisburg, PA) obtained a dismissal via summary judgment of an auto coverage lawsuit that had challenged a client’s denial. The insured purchased a vehicle and obtained insurance from our client/insurance carrier. The insured later discovered the vehicle was stolen, and he was unable to register the vehicle with PennDOT. The insured then made a claim for “theft or larceny” under his auto policy, which was denied by the client carrier.

Josh Byrne (Philadelphia, PA) obtained the successful dismissal of a Disciplinary Board complaint against an attorney who had been involved in a complex and messy family dispute regarding the creation and operation of a brewery and events venue.

Josh Byrne (Philadelphia, PA) was successful in obtaining the dismissal of a complaint filed in the Middle District of Pennsylvania against a New York attorney. The complaint alleged malfeasance regarding the appointment of a guardian of an elderly woman that is alleged to have resulted in the dissipation of $2.2 million in assets.

Yaël Dadoun and Ed Schwart (Harrisburg, PA) obtained a dismissal of a Disciplinary Board complaint filed against a York County attorney by a sitting judge on the Court of Common Pleas of York County. This matter was related to the attorney’s representation of a client in an underlying hostile divorce action.

Ray Freudiger (Cincinnati, OH) won a defense verdict after a six-day jury trial in U.S. District Court for the Southern District of Ohio. Ray defended a public housing authority accused of discrimination against disabled persons under the ADA and FHA when it did not apply to HUD for VASH vouchers as requested by a developer. It took the jury less than 45 minutes to deliberate.

Howard Mankoff (Roseland, NJ) won summary judgment in a case involving a dispute between a religious denomination and one of its local churches. We represented a religious denomination that invoked its judicial process, allowing it to assume control of a local church due to declining membership. The pastor of the local church refused to vacate the parsonage. The local church asserted the denomination lacked the authority to assume control over it and argued it was never actually part of the larger denomination. The issues involved First Amendment case law, which addressed whether and to what extent the courts can decide ecclesiastical disputes, and whether the religious denomination was a hierarchical church or a congregational church. The court accepted our argument that the local church was part of the denomination, that the denomination was hierarchical, and that the First Amendment allowed the court to decide the dispute. The court granted our request to allow the denomination to assume control of the local church.

Howard also won dismissal of a sexual assault claim against a small college in North Carolina. We represented the college which was being sued in New Jersey under the revival statute, which provides a window during the statute of limitations for sexual assault claims to be waived. The plaintiff claimed that 20 years ago, when she was 15, she was a participant in the Upward Bound program and was sexually assaulted by a counselor during a class trip in New Jersey. The plaintiff also filed suit in North Carolina. We successfully argued that the court should dismiss the New Jersey case based on forum non conveniens, comity and lack of jurisdiction, resulting in a dismissal on the pleadings.           

Michelle Michael (Mount Laurel, NJ) and Leonard Leicht (Roseland, NJ) had a whistleblower claim dismissed that had been filed against the New Jersey State Police and eight individual defendants (current and retired members of the State Police). The ruling was especially satisfying as the court had ruled on a prior summary judgment motion that a fact issue existed, and we had to convince the new motion judge not to follow the “Law of the Case” Doctrine and to decide the case based on the record presented in this motion.

Jack Slimm and Jeremy Zacharias (Mount Laurel, NJ) obtained a dismissal of an ethics grievance filed against their client, who was facing alleged ethics violations in connection with the formation of an LLC. This LLC was for a company formed by a family friend. Allegations of ethics violations included the purported self-dealing of the client with the LLC, transferring the LLC to his wife’s name, and stealing the company from the grievant. After a formal interview and response to the grievance, the ethics investigator found that there was a lack of clear and convincing evidence to prove any ethics violations and dismissed the matter. In the ethics grievance response, Jack and Jeremy argued, per the Rules of Professional Conduct, the allegations against their client did not rise to the level of an ethics violation by clear and convincing evidence. There was enough evidence in the record to show that the grievance held no merit and should be dismissed.

Carol VanderWoude (Philadelphia, PA) and Scott Dunlop (Pittsburgh, PA) successfully moved for dismissal, with prejudice, of all claims asserted against the City of New Castle in a lawsuit filed in the U.S. District Court for the Western District of Pennsylvania. The plaintiff, a rental property owner, alleged that from approximately 2006 through January 2019, the City of New Castle: (1) deprived him of his right to rent his units located in New Castle for a period of approximately 30 to 90 days at a time; (2) subjected his properties to “numerous additional, non-permit related inspections” without explanation; and (3) issued to him and/or his realty company at least 50 separate violations of the International Property Maintenance Code. According to the plaintiff, this “radical code enforcement” prevented or discouraged him from renting housing to minorities. The plaintiff further alleged that in or around March 2020, New Castle restricted his ability to purchase property from the Lawrence County repository by refusing to take up the matter at City Council meetings. A second amended complaint that included six counts was subsequently filed. The District Court agreed with New Castle’s argument that all of the claims based on code enforcement decisions, citations and inspections were barred by the relevant statutes of limitations. As for the issue with the repository property, the District Court agreed with New Castle that Pennsylvania law provides no enforceable property right to the highest bidder, such that the U.S. Constitution’s Fourteenth Amendment did not apply to support a procedural due process claim. Because the plaintiff had two previous opportunities to amend the complaint, the District Court dismissed the second amended complaint with prejudice and entered judgment in favor of the City of New Castle.

Jeremy Zacharias (Mount Laurel, NJ) obtained summary judgment on behalf of his client, an amateur baseball league located in Monmouth County, New Jersey. In this matter, the plaintiff, an umpire assigner, filed a lawsuit alleging improper breach of contract, tortious interference and conspiracy to cut this assigner out of his company. The plaintiff also maintained a cause of action for emotional distress and punitive damages. On summary judgment, Jeremy argued that due to discovery deficiencies, as well inadequacies with the substantive claims alleged, the plaintiff could not state any material facts necessary to avoid summary judgment. The court agreed with the defense, holding that the plaintiff failed to properly oppose the summary judgment motion and had not stated any facts in discovery that would support the claims of breach of contract or tortious interference, among other claims. The damages exposure of this case, prior to the dismissal, has been approximately $10 million, especially considering the punitive damage potential in this matter.

 

WORKERS’ COMPENSATION DEPARTMENT

Michael Duffy (King of Prussia, PA) won on a reinstatement petition filed by the claimant. The claimant alleged he was entitled to reinstatement of indemnity benefits after he voluntarily stopped working due to hand pain. Mike argued the light-duty position available and offered to the claimant was a one-handed position, and he presented employer fact witness testimony and video of the light-duty job in rebuttal.

Tony Natale (Philadelphia, PA) successfully defeated a claim petition filed against a medical device fabrication company located in Chester County. The claimant alleged both pulmonary and physical injuries as a result of workplace exposure to chemicals and heavy lifting of product. Upon cross examination the claimant admitted that her treating physicians found her symptoms to be psychosomatic. Evidence presented by a nationally renowned pulmonary expert and a board certified orthopedic surgeon demonstrated by a preponderance of the evidence the claimant sustained no identifiable work-related injuries of any kind. The claim petition was summarily dismissed.

Tony successfully defeated a fatal claim petition filed against a national trucking company. The decedent died of a heart attack after a three-day over-the-road run for the trucking company. The decedent’s dependents argued the heart attack was caused by the rigors of the job. Although the decedent died as he was about to execute paperwork denoting his employment status as an independent contractor—he never signed the document. The case, therefore, proceeded to litigation in the workers’ compensation forum. Expert evidence was presented on the issue of whether the decedent’s job duties had any contribution to his death. The court concluded, based on the evidence presented, that the work duties had no relationship whatsoever to the demise of the decedent. The fatal claim was dismissed in its entirety.           

Tony defended a Berks County mushroom facility in a high-exposure alleged amputation/loss-of-leg case. The claimant sustained a severe laceration and tissue loss to one of his legs while inappropriately performing his job duties. Work was made available to the claimant after the injury, which he flat-out refused. The claimant then alleged he lost his leg for all intents and purposes and demanded the court award specific loss benefits. Tony defended this case on factual and medical grounds. The court held that the claimant did not lose his leg, and no specific loss benefits were awarded. Further, the court suspended indemnity benefits for the claimant’s failure to accept the job offer made to him after the injury. Significant exposure was totally eliminated.

Tony successfully prosecuted a termination petition on a 10-year-old back claim with open medical liability. The claimant had been treating with excessive use of narcotic medication. An orthopedic expert examined the claimant and found him fully recovered from the work injury and noted that the use of narcotic medication was unrelated to the injury. During the litigation, the claimant presented a medical expert who opined he was still suffering from the work injury. On cross examination, the expert admitted he was aware his treatment was made the subject of a utilization review and found to be unreasonable and unnecessary. He further admitted his intent to continue the claimant on narcotic medication, despite the UR Determination, and charge the insurer for his services. Additionally, he admitted to moving the claimant to other doctors in his office who were not subject to the UR Decision as a means of continuing the treatment cycle. The court found the claimant’s medical expert not to hold a scintilla of credibility. The court then terminated the claimant’s benefits.

Tony successfully defended a claimant’s appeal of a judge’s decision to terminate benefits based on a full recovery after a horrific trucking accident. The claimant’s attorney argued to the Appeal Board that his litigation costs should have been awarded since the claimant was successful in amending the nature of injury during the litigation and, therefore, earned reimbursement of costs. Tony argued, and the Board agreed, that the amendment to the nature of injury was stipulated to before the termination petition was prosecuted, and no fees or costs were due and owing.

Kristy Salvitti and Adam Huber (Mount Laurel, NJ) successfully argued that the petitioner was not prosecuting his workers’ compensation claim as evidenced by his failure to respond to repeated discovery requests. The judge agreed that the petitioner was not complying with the New Jersey Workers’ Compensation Rules, granted the respondent’s request for dismissal, and entered an order for dismissal without prejudice.

Kacey Wiedt (Harrisburg, PA) successfully defended a claim petition in a case where the claimant was struck by a forklift and alleged the accident caused a back injury. Through employer witness testimony and medical testimony, Kacey was able to show that the claimant did not sustain a back injury and that her medical issues were pre-existing and unrelated to the accident. The judge found the evidence presented by the employer established that, even though the claimant was involved in a forklift incident, the claimant did not sustain a work injury and her ongoing medical issues were unrelated to the forklift accident.

Judd Woytek (King of Prussia, PA) won a favorable decision from the District Director on a Federal Black Lung claim. The claimant had filed an application for benefits alleging 20+ years of coal mine employment and exposure to coal dust. The District Director found that the claimant had only proven four years of qualifying coal mining employment. The District Director also found that the claimant was unable to prove he had developed coal workers’ pneumoconiosis or a totally disabling respiratory impairment.

Judd won a favorable decision from an Administrative Law Judge on a Federal Black Lung claim. The judge credited the claimant with 11 years of qualifying coal mining employment but found that the claimant had failed to prove a totally disabling respiratory impairment and, therefore, denied the claim. Judd presented evidence from our medical expert that the claimant did not contract coal workers’ pneumoconiosis as the result of his work in the coal mines and that he was not disabled by a respiratory impairment. The judge addressed the issue of total respiratory disability first and found the claimant failed to meet the burden of proof with a pulmonary function study, an arterial blood gas study, and medical opinion evidence. The judge credited the opinions of our medical expert over those of both of the claimant’s expert and the independent expert retained by the Department of Labor. The judge found no respiratory disability and, therefore, denied the claim.

Judd received a favorable decision denying the claimant’s claim petition. The claimant alleged hip, back, and leg pain after slipping and falling on his back while going down a flight of steps. The judge found that the claimant failed to present medical evidence to substantiate a work-related injury or any disability. The claim petition was denied and dismissed.

*Results do not guarantee a similar result.

 

Defense Digest, Vol. 28, No. 12, December 2022, is prepared by Marshall Dennehey 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. © 2022 Marshall Dennehey. 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

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

Florida Supreme Court Adopts Traditionally More Expansive Concept of Occupational Causation

The Florida Supreme Court issued a significant decision rebuking the First District Court of Appeal (1st DCA) in the high-profile case of Bouayad v. Normandy Insurance Co., a case addressing the compensability of workplace injuries resulting from assaults by third-party tortfeasors. The Judge of Compensation Claims (JCC) found the claimant was entitled to workers' compensation benefits, relying in part on the Florida Supreme Court's earlier decision in Strother v. Morrison Cafeteria from 1980. In Strother, the Court upheld an award of benefits to a cashier who was assaulted and robbed by individuals who followed her home from work under the mistaken belief that she was carrying restaurant cash deposits. In Bouayad, the 1st DCA concluded that the claimant's injuries were not compensable because they did not arise out of his employment. The Florida Supreme Court disagreed, holding that the 1st DCA applied too narrow an interpretation of the "arising out of employment" requirement. In doing so, the Court reaffirmed a broader and more traditional view of occupational causation than that recently adopted by the 1st DCA. The claimant in Bouayad was the general manager of a car rental business operating from a hotel near an airport. Around midnight, while walking along a covered outdoor walkway from the hotel's atrium, where the rental kiosk was located, to an office near the pool, he was shot multiple times by an unidentified assailant. As part of his regular duties, the claimant carried rental agreements and cash receipts from the kiosk to the office at the end of each shift. After the shooting, the claimant managed to return to the hotel atrium, where he stated that he believed "Robert" had shot him, referring to an individual who had threatened the claimant's son the previous day. The assailant, however, was never identified. Consequently, the Supreme Court analyzed the case as involving an unknown third party while the claimant was acting within the course and scope of his employment. The central issue therefore was whether the injury "arose out of" the claimant’s employment. At the final hearing, the claimant presented evidence regarding the risks and hazards associated with his employment, including the nature of his duties, his late-night work schedule, and the location of the business in a high-turnover hotel near a major airport. His expert opined that these factors exposed him to an increased risk of becoming the victim of a crime while at work. In contrast, the employer/carrier's expert characterized the shooting as a targeted attack rather than a robbery and asserted that the risk of violent crime was actually higher near the claimant's residence than at the hotel. Based on that analysis, the expert concluded that the claimant was not exposed to an increased workplace risk. The 1st DCA focused narrowly on the specific activity the claimant was performing at the moment of injury. According to the court, the claimant's “work performed” at the time of the shooting was simply "walking" between two employer-operated locations, and that act of walking did not itself cause the injury. The Florida Supreme Court found this analysis far too myopic and inconsistent with decades of workers' compensation precedent. Reaffirming longstanding principles of workplace causation, the Court explained that the proper inquiry is not whether the precise physical task being performed at the moment of injury directly caused the harm. Rather, the relevant question is whether the employment, viewed as a whole, exposed the worker to risks and hazards that contributed to the injury. The decision is significant because it reinforces a broader conception of work-relatedness in the “arising out of” compensability analysis. Instead of limiting the causation analysis to the employee's discrete physical activity at the time of injury, courts must consider the totality of the employment circumstances, including the employee's duties, work environment, hours, and occupational risks. Under that framework, an injury may arise out of employment when the employment places the employee in a position of increased hazard, even if the specific task being performed at the moment of injury is not itself the direct cause of the harm.

Thought Leadership

Appellate Division Affirmed Trial Judge’s Orders Granting Summary Judgement for Defendants on COVID-19 Case

In Dunne v. Advanced Subacute Rehab Servs. at Sewell, LLC, et al., the plaintiffs appealed from two Law Division orders. By way of background, Louis Doto, Sr. (Doto) worked for BP & SC Services, Inc. (BP). BP leased Doto to Advanced Subacute Rehabilitation Center at Sewell, LLC (Advanced Subacute) and it had control of his work, paid wages, and had the power to hire or fire him. A BP employee was assigned to the facility to train and supervise him and BP was responsible for securing workers’ compensation coverage. Doto worked as an aide in the laundry department. Linen from COVID-19 residents were delivered in clearly marked bags and he had no direct contact with residents. A co-worker, Sheila Smith, was also an aide and she never contracted COVID-19 at the facility. Advanced Subacute did not require Doto to wear an N-95 mask, but instead a surgical mask, though N-95 masks were available to all employees. He was also required to attend period mandatory meetings with other high-risk employees, the last of which he attended was in November 2020. All employees were required to test for COVID-19 and there were no reported cases from June to October 2020. On December 23, 2020, Doto tested positive for COVID-19 and passed away on January 18, 2021. The last member of housekeeping that Doto may have encountered tested positive 22 days earlier. After his death, OSHA found two “serious” violations concerning the N-95 masks worn by housekeepers. In response, Advanced Subacute fit tested all non-clinical staff. Doto’s estate filed a workers’ compensation claim and named both BP and Advanced Subacute as his employer. The estate received an award. In July 2022, the plaintiffs filed a complaint in the Law Division, alleging wrongful death and survivor causes of action. In October 2024, the defendants moved for summary judgment, arguing: 1) immunity pursuant to the Emergency Health Powers Act: 2) the exclusive remedy provision of the Workers’ Compensation Act; 3) Doto’s inability to establish infection at the facility; 4) net expert opinions by the plaintiffs’ expert; and 5) inadmissibility of the OSHA report. The plaintiffs opposed and filed a cross-motion for summary judgment, arguing: 1) no immunity as Advanced Subacute engaged in gross negligent or willful misconduct; 2) no preclusion by the Workers’ Compensation Act as Doto was not Advanced Subacute’s employee; and 3) no net expert opinions. In February 2025, the judge issued a written decision granting the defendants’ motion. Specifically, he found Advanced Subacute’s COVID-19 immunity precluded the plaintiffs’ claim as no reasonable jury could find any gross negligence or utter disregard for Doto’s safety. He also addressed the other defenses for completeness. The plaintiffs moved for reconsideration and the judge issued another written decision denying the plaintiffs’ motion in April 2025. The plaintiffs then appealed both decision. The Appellate Division affirmed the orders for reasons stated by the judge in his written decisions. The Appellate Division only added: 1) Advanced Subacute acted consistently with the legislative grant of immunity; 2) there was no doubt Doto was an employee of both BP and Advanced Subacute and the latter may have inadvertently failed to follow some precautions; and 3) confirmed the plaintiffs’ experts did not identify a basis for their opinions. Ultimately, the Appellate Division found no reason to disturb the judge’s well-reasoned decisions and affirmed the judge’s orders.

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Commonwealth Court Deemed Worker an Employee Despite Independent Contractor Agreement; Insurer Estopped from Denying Coverage

In this case, the claimant filed a Claim Petition for injuries sustained on October 28, 2019, naming J&S as his Employer, and alleging that the injuries occurred when he fell from a ladder while installing a satellite dish for Dish Network. Dish Network contracted with J&S to install satellite dishes. Subsequently J&S filed a Petition to Join Brickstreet Insurance Company and the claimant filed a Claim Petition against the Uninsured Employer Guaranty Fund. The Fund then joined Dish Network as another employer.  Before the Workers’ Compensation Judge (WCJ), the claimant testified that he was hired in 2015 by J&S and at the time signed an Independent Contractor Agreement (IC Agreement). J&S defended the case on the basis that the claimant was not an employee, but was an independent contractor, even after the IC Agreement expired. Additional evidence showed that, at the time of the October 28, 2019, work injury, J&S’ workers’ compensation insurance with Brickstreet had lapsed, even though a Brickstreet agent had been working to renew J&S’ policy and had a Certificate for coverage from September 25, 2019 to September 25, 2020 issued, with Dish Network listed as the Certificate Holder. A renewal policy was not in effect at the time the Certificate was issued and the agent learned on October 25, 2019 that Brickstreet was not going to renew their policy with J&S, due to an unpaid premium.    Ultimately, the WCJ found that the claimant was an employee of J&S at the time of the work injury and that J&S did not have a workers’ compensation policy in place at the time, due to their failure to pay the renewal premium to Brickstreet. The WCJ also found Dish Network was a Statutory Employer under Section 302(a) of the Act. The Claim Petition and the Guaranty Fund Claim Petition were both granted, as was the Guaranty Fund’s Petition to Join Dish Network. The WCJ also denied J&S’ Petition to Join Brickstreet, finding that neither J&S or Dish Network showed that Brickstreet was estopped from denying coverage. J&S and Dish Network appealed to the Workers’ Compensation Appeal Board (Board) and the Board affirmed. J&S and Dish Network appealed to the Commonwealth Court. The Commonwealth Court rejected J&S' argument that the claimant was an independent contractor. In doing so, the court noted that the claimant credibly testified that he worked for J&S full time, could not work for another company, and that J&S, scheduled his jobs, tracked him, and scheduled additional installations, if he finished early. Additionally, the court noted the claimant lacked discretion in the manner he performed his job, because all questions had to be referred to J&S.  As for Dish Network’s appeal, the court held that the WCJ erred in holding that Brickstreet was not estopped from denying coverage as to Dish Network. According to the court, the insurance agent was an authorized representative of Brickstreet and, at the direction of J&S, issued the Certificate of Insurance that he knew was not accurate at the time, and was aware would be presented as proof of coverage for J&S. Dish Network relied upon that information and continued to use J&S, ultimately leading to Dish Network being named as the Statutory Employer liable for payment of benefits because of J&S’ uninsured status. The court held that the Board erred in affirming the WCJ ’s conclusion that Dish Network did not establish that Brickstreet was equitably estopped from denying coverage, reversed the decision below, and remanded the case to the WCJ.