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Defense Digest

On the Pulse…Other Notable Achievements

Defense Digest, Vol. 31, No. 3, September 2025

September 1, 2025

THOUGHT LEADERSHIP

Dana Gittleman (Philadelphia, PA), chair of our Real Estate E&O Practice Group, and Jeremy Zacharias (Mount Laurel, NJ) kicked off their Professional Liability Underwriting Society (PLUS) podcast series with “Insurance Agent E&O – Top Ten Tips for Risk Management.” From memorializing communications to protecting attorney-client privilege, Dana and Jeremy share practical strategies to help insurance professionals manage risk more effectively. Tune in! https://lnkd.in/eQGs3u2y

David Shannon (Philadelphia, PA), chair of our Privacy and Data Security Practice Group, and guest Evgueni Erchov from Cypfer, recorded the Professional Liability Underwriting Society (PLUS) podcast “Managing Cybersecurity Threats in 2025.” This is the third season of David’s ongoing podcast with PLUS. The program focused on ransomware, business-email compromise, AI, and the increasing sophistication of cyber-threat actors. Tune in today! https://plusweb.org/podcast/managing-cybersecurity-threats-in-2025-episode-1/. 

 

SPEAKING ENGAGEMENTS

Kimberly Berman (Fort Lauderdale, FL) spoke at the 28th Annual Florida Defense Lawyers Association (FLDA) Liability Claims Conference about “Pleading, Proof, and Preservation of Punitive Damages Claims: Tips for Florida Trial Lawyers and Appellate Attorneys.”

Ryan Burns, Angie Colorado, and A.C. Nash (all in Fort Lauderdale, FL) presented “Relevant Procedural Rule Changes for Risk Managers” at the Tampa Bay RIMS (Risk & Insurance Management Society) educational luncheon. This program provided an insightful overview of the procedural changes in the Florida circuit court system. The discussion shed light on the impact of the Florida tort reform of 2023, aligning the state’s court procedures with those of the Federal court. These changes are set to influence the way lawsuits are handled, introducing strict timelines throughout the process.

Josh J.T. Byrne (Philadelphia, PA) was a panelist at the Philadelphia Bar Associations’ webcast, “Ethics and Legal Malpractice Avoidance.” Josh is Co-Chair of the Bar’s Professional Responsibility and Guidance Committee. Josh also co-presented “Ethics Hotline and Special Ethical Considerations for Prosecutors,” at District Attorney’s Office: August CLE Program hosted by the Philadelphia Bar Association.

James Cole and Alec DelConte (both of Philadelphia, PA) presented “Untying Tangled Titles: How Property Deed Fraud Drives Costs and Indemnity,” at the annual conference of the International Association of Special Investigation Units. 

Christopher Conrad (Harrisburg, PA) and Lee Durivage (Philadelphia, PA) presented “Hot Topics in Employment Law,” for the Pennsylvania Bar Association’s Law Firm Administrators’ Conference of Central Pennsylvania. Their presentation, which was attended by law firm administrators, human resources staff, and managing attorneys, focused on the current employment law issues facing law firms and practical advice for managing risk.

Michael Duffy (King of Prussia, PA) presented as part of the Pennsylvania Bar Institute’s and Pennsylvania Bar Association Workers’ Compensation Law Section’s conference Tough Problems in Workers’ Compensation 2025. Mike was part of a panel that presented “Surveillance and Using Social Media to Win Your Case.” Designed specifically by and for the experienced workers’ compensation practitioner, this presentation highlighted select challenges in workers’ compensation practice and offered techniques for managing them. Developments, practices, strategies, and preferences were discussed to help avoid making mistakes that could negatively affect a client’s claim.

Christina Gonzales (Philadelphia, PA) served as moderator for a panel at the 2025 Defense Research Institute’s Diversity for Success Expo, titled “Building Your Book of Business with Brand YOU! (Pitching Business and Executive Branding).” The discussion explored how developing a personal brand and growing a book of business are essential strategies for standing out—both within your organization and across the legal profession. Panelists shared practical insights on how to balance client development with professional responsibilities, offering guidance on how legal professionals can define their value, build meaningful relationships, and pursue long-term success—whether in a law firm, in-house role, or independent practice.

Gregory Graham (Pittsburgh, PA) presented “AI Litigation: The Current Landscape,” at the Pennsylvania Defense Institute’s annual CLE and Conference. This seminar focused on the current landscape of liability claims stemming from the use of generative and agentic AI. While generative AI is more commonly discussed at this point in time, it is agentic AI—particularly its end-to-end automated goal identification and action initiation—that is going to profoundly impact our clients’ industries.

Sean Greenwalt and Amara Rodriguez (both of Tampa, FL) spoke at the 28th Annual Florida Defense Lawyers (FDLA) Association Liability Claims Conference about effective use of proposals for settlement in Florida’s new legal landscape.

Matthew Keris (Scranton, PA) presented “MPL Crossfire: How to Prepare for AI From a Medico-Legal Perspective,” at the 2024 Medical Professional Liability Association conference. Matt also presented two seminars at the Hospital Insurance Forum 2025 Conference. For the first seminar, Matt co-presented with Jill Huntley Taylor. Their presentation discussed “New Jury Considerations in the Age of Big Law, Verdicts, and Medicine.” One day later, Matt presented “AI in Healthcare: Views from a Clinical and Legal Perspective.” Finally, Matt joined a panel presentation for a webinar put on by the Pennsylvania Coalition for Civil Justice Reform. The program, “Medical Malpractice Pennsylvania Update,” explored a number of emerging issues in medical malpractice, including the continuing surge of Philadelphia cases; dilution of plaintiffs’ burden to prove that an agent causes harm; preservation of issues on appeal and waiver rulings of Superior Court; ethical concerns of double and triple booking; and the rise of punitive damages. 

Paul Krepps (Pittsburgh, PA) spoke at the Pennsylvania Chiefs of Police Association Conference and Training Session on “Litigation After-Action – Lessons from the Perspective of a Defense Lawyer.” 

Missy Minehan (Harrisburg, PA) presented “Mitigating and Responding to a Professional Liability Claim: Documentation, Discovery, and Depositions” during the Skilled Nursing Development Institute’s administrator appreciation event. Missy discussed pre-suit documentation issues, including documentation of arbitration agreements, missing medical records documentation and maintenance of key paper records (e.g. staffing, deployment, statements), and intra-lawsuit discovery and depositions.

Megan Nelson (Orlando, FL) presented “The Latest on Medical AI and Liability Claims,” at the Florida Society for Healthcare Risk Management and Patient Safety’s annual meeting and education conference.

Jeffrey Rapattoni (Mount Laurel, NJ) presented “Ethics and the Investigator,” at the conference of the Illinois Chapter of IASIU (International Association of Special Investigation Units Inc.). Jeff also spoke at the Coalition Against Insurance Fraud’s Mid-Year Meeting, participating in the panel “Insurance Fraud Through a Legal Lens: Insights from the Frontlines.” At the annual conference of the International Association of Special Investigation Units, Jeff made two presentations, “Legal Update: Emerging Legal Issues in Fraud Fighting,” and “Ethics.”

Jack Slimm and Jeremy Zacharias (both of Mount Laurel, NJ) presented at the Camden County Bar Association Annual Civil Practice Update. Jack covered recent case law updates within New Jersey, and Jeremy moderated the panel discussion, which was also presented by the Honorable Steven J. Polansky, as well as several private practitioners. This annual seminar is well attended and has been a staple within the Camden County Bar Association for over two decades.

Jack Slimm was also a featured speaker at the annual New Jersey Institute for Continuing Legal Education seminar “Legal Malpractice Update.” Jack and Appellate Judge, Harry Carroll, presented “Rule 104 Hearings Regarding Experts In Legal Malpractice Actions.”

Jeremy Zacharias also presented at an all-day CLE for the New Jersey State Bar Association on “Solving Problems in Commercial Real Estate Transactions.” Jeremy’s topic included a discussion on ethical considerations in commercial real estate transactions. Jeremy covered topics including pitfalls using artificial intelligence with commercial real estate transactions, as well as the applicability of the Rules of Professional Conduct in representing clients. 

PUBLISHED WORKS

August 18, 2025 – Todd Leon and Alec DelConte (both of Philadelphia, PA) published an article in The Legal Intelligencer’s Insurance Law Supplement. Titled, “Choice of Law in Coverage Disputes: What Happens When the Policy, the Loss and the Parties Span State Lines?,” the article explores how “choice of law” issues arise in litigation, using a Pennsylvania–New Jersey insurance dispute scenario to highlight the significant impact differing state laws can have on insurers and policyholders. Read their article here.

August 1, 2025 – Alana Staniszewski’s (Pittsburgh, PA) article “Pa. Supreme Court Permits Payment of Specific Loss Benefits to a Deceased Injured Workers’ Estate,” was published in The Legal Intelligencer. Read her article here.

July 28, 2025 – PLUS Blog published “Navigating the Doctrine of Reasonable Expectations: A Liability Risk for Insurance Agents,” by Dana Gittleman (Philadelphia, PA). Read her article here.

July 21, 2025 – The Legal Intelligencer published Alesia Sulock and Josh J.T. Byrne’s (both of Philadelphia, PA) article “Socially Responsible Lawyers: Why You Need to Understand Social Media to Competently Represent Your Clients, Part 2.” You can read this article here.

July 11, 2025 – William Murphy (Roseland, NJ) authored the article “Medical Marijuana in New Jersey Workers’ Compensation Law,” appearing in the New Jersey Law Journal’s Cannabis Supplement. The article discusses developments since the 2021 Hager decision (Vincent Hager v. M&K Construction, 246 N.J. 1 (2021), and recent shifts in the legal landscape as state and federal laws have evolved with regard to medical marijuana. You can read the article here. 

June 20, 2025 – Mark Wellman (New York, NY) was published in CLM Construction Claims Magazine – Summer Edition as a co-author of the article “Danger: Construction Site. Avoiding Liability & Workers’ Compensation Exposure in the Construction Industry.” The article explores key strategies for mitigating risk and managing claims in the high-stakes world of construction. You can read this article here.

June 17, 2025 – Jacob Gilboy’s (Harrisburg, PA) article “Employment Discrimination and Retaliation – Best Practices to Avoid Headaches,” was published in PLUS Blog. Employment discrimination and retaliation claims can disrupt even the most well-run organizations. In this article, Jake shares five practical tips for navigating these situations without making them worse! Read it now on the Professional Liability Underwriting Society (PLUS) blog. 

June 10, 2025 – Ryan Friel (Philadelphia, PA) authored the article, “Proposed FINRA Rule 3290—A Regulatory Breakthrough or a Halfhearted Attempt at Real Reform?,” appearing in The Legal Intelligencer. The article questions if the proposed rule is truly a modernization of outdated regulations or merely a cosmetic update that fails to address the core concerns of broker-dealers and their registered representatives. Read here.

May 19, 2025 – Josh J.T. Byrne and Alesia Sulock (both of Philadelphia, PA) authored “The Barrier to Legal Malpractice Cases Arising Out of Class Action Settlements,” published in The Legal Intelligencer. Josh and Alesia explore a recent Delaware Supreme Court decision which examines why it is appropriate to have high barriers to legal malpractice actions after a class action settlement. You can read their article here.

May 2025 – Michele Punturi (Philadelphia, PA) co-authored, with clients, the article “Danger: High Risk Ahead – Managing Workers’ Comp Exposure in Risky Industries,” appearing in CLM Magazine. The article discusses best workers’ compensation claims management practices for high-risk sectors including construction, health care, transportation, and retail and hospitality. You can read the article here. 

 

RECOGNITION

Jason Banonis (King of Prussia, PA) has been elected to the Board of Governors of the Bowie State University Maguire Academy for Risk Management and Insurance. He will also serve on its Education, Curriculum, and Program Committee. The Academy is affiliated with the Saint Joseph’s University Maguire Academy of Insurance & Risk Management, which was created by Saint Joseph’s alumnus James J. Maguire, founder and longtime CEO of the Philadelphia Insurance Company. Its purpose is to promote and support education in insurance, risk management, and actuarial science and offers services to its students, including scholarships, internships and co-op experiences, counseling, and assistance with career placement. Current academy board members include executives from global insurance companies and corporate risk managers.

James Hanratty (Jacksonville, FL) and Alesia Sulock (Philadelphia, PA) have been admitted to membership of the International Association of Defense Counsel. The IADC is an invitation-only, peer-reviewed association that has served a prestigious membership of corporate insurance executives and insurance defense attorneys since 1920. Its members include many of the world’s foremost corporate and insurance lawyers, as well as leading insurance executives.

Ryan Hauck (Pittsburgh, PA) was recently elected by his peers to serve a two-year term as a Council Member on the Allegheny County Bar Association Workers’ Compensation Section Committee. 

Blake Hood (Jacksonville, FL) was recently appointed as co-chair of the Jacksonville Bar Association’s Social Security/Workers’ Compensation Committee. 

Marshall Dennehey has once again been recognized as a leader in client service, earning a spot on BTI Consulting’s Client Service A-Team 2025, which honors law firms delivering the highest levels of service to corporate clients. Based exclusively on feedback from corporate counsel, the firm ranked as a “Stand Out” among all law firms nationwide, affirming our continued strength in building trusted relationships, understanding client goals, and delivering consistent, results-driven service. The BTI Client Service A-Team is the only law firm ranking based solely on direct, unprompted feedback from legal decision-makers at large companies. The 2025 report is based on more than 350 in-depth interviews conducted between May 2024 and February 2025 with general counsel, chief legal officers, and their direct reports. To learn more, visit BTI’s Client Service A-Team, at https://bticonsulting.com/bti-client-service-a-team. 

 

Defense Digest, Vol. 31, No. 3, September 2025, 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. © 2025 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

Casey Alan Coyle Joins Marshall Dennehey's PA Appellate Practice as a Shareholder in Harrisburg and Philadelphia

News

Marshall Dennehey Expands Leading Pennsylvania Appellate Practice With Addition of Shareholder Casey Coyle

Thought Leadership

New Jersey Appellate Division Affirms Exclusion of Legal Malpractice Expert as Impermissible Net Opinion

Jack Slimm and Jeremy Zacharias obtained a favorable decision on behalf of their client in a case centering on the admissibility of expert testimony in legal malpractice actions. In Martin v. Loury, the New Jersey Appellate Division affirmed the exclusion of a plaintiff's legal malpractice expert, holding that the expert's opinions on causation and damages were too speculative to support the malpractice claim. The legal malpractice action arose from an underlying employment dispute involving claims for damages stemming from the breach of an employment agreement. The plaintiff alleged that defense counsel committed malpractice during a second trial by failing to recall the plaintiff as a rebuttal witness after the employer's CEO testified. According to the plaintiff's expert, additional rebuttal testimony would have bolstered the plaintiff's damages claims and led to a more favorable result. Both the trial court and the Appellate Division rejected that theory. The courts found that the expert could not explain how the proposed rebuttal testimony would have altered the outcome of the underlying case or resulted in any additional recoverable damages. Notably, the trial judge in the underlying employment matter had already rejected the CEO's testimony as not credible and had accepted the damages analysis advanced by the plaintiff. The court had also determined that the amount of damages was not genuinely disputed. As a result, the expert's opinion that additional rebuttal testimony would have produced a better outcome was unsupported by the record and based on speculation rather than evidence. The Appellate Division agreed that neither the plaintiff nor the expert could identify any actual damages attributable to the alleged malpractice or demonstrate the required element of proximate causation. The court further upheld the trial court's application of New Jersey's net opinion doctrine, finding that the expert failed to provide the necessary "why and wherefore" supporting his conclusion that the attorney's conduct caused a compensable loss. Because the opinions rested on unquantified possibilities rather than demonstrable facts, they were inadmissible. Key Takeaway for Legal Malpractice Defendants For attorneys and firms defending legal malpractice claims, Martin v. Loury underscores the importance of closely scrutinizing an opponent's expert report on the critical elements of proximate causation and damages. The decision demonstrates that a malpractice claim cannot survive where an expert merely speculates that different litigation tactics might have produced a better result. Instead, the plaintiff must present admissible expert testimony grounded in the record that explains how the alleged attorney error probably changed the outcome of the underlying matter and resulted in measurable damages.

Portrait of Carolyn Schweizer, with text below: Philadelphia Office Managing Attorney

News

Marshall Dennehey Names Carolyn Schweizer New Philadelphia Office Managing Attorney

Marshall Dennehey Announces 2026 Ohio Super Lawyers and Rising Stars

News

Marshall Dennehey Announces 2026 Ohio Super Lawyers and Rising Stars

Thought Leadership

Court Allows Recklessness and Punitive Damages Claims to Proceed After Work‑Zone Crash

In a case where a defendant filed preliminary objections against allegations of recklessness and punitive damages, the Susquehanna County Court of Common Pleas denied these preliminary objections. This case stems from a motor vehicle accident, where the defendants car struck the plaintiffs car after the defendant allegedly fell asleep at the wheel, going at a high rate of speed, through a construction work zone. Defendant first objected to the general allegations throughout the plaintiff’s complaint pertaining to “reckless” conduct contending that there were insufficient factual allegations to support the claim of reckless conduct. Defendant next objected to the plaintiffs claim for punitive damages, as punitive damages may only be assessed against a motorist for falling asleep while driving if there is further evidence to prove driver was aware of their drowsiness and risk of falling asleep. Lastly, defendant objected to plaintiffs complaint, claiming it lacked specificity. The court here found that the plaintiff had included in the complaint specific allegations related to the defendant’s alleged recklessness, including allegations regarding speeding in a work zone, almost striking the flagger, falling asleep at the wheel, and striking the plaintiffs vehicle which was stopped. Additionally, the court noted that falling asleep does not come without warning. The court found that these allegations were sufficient to support an allegation of recklessness at the pleadings stage.

Result

Summary Judgment Secured, Preserving $750,000 in Coverage for Insured in Major Trucking Liability Dispute

Ray Freudiger and Michael A. Roberts (both of Cincinnati) successfully obtained summary judgment on behalf of their client in a coverage dispute arising from a May 19, 2022, motor vehicle accident. A permissive driver operated a box truck for an interstate trucking company and caused severe injuries to two tort victims. Prior to the accident, the insured had procured a commercial auto policy for the trucking company with stated limits of $1,000,000. Following the accident, the insurer initiated a declaratory judgment action asserting that only reduced bodily injury limits of $25,000/$50,000 applied and later counterclaimed, alleging it would not have insured the driver had he been properly submitted for approval under the policy. After extensive discovery, briefing, and oral argument, the court rejected the insurer’s attempt to shift responsibility for the $750,000 in coverage it was legally required to provide for permissive drivers under Ohio law, granting summary judgment in favor of the insured and preserving $750,000 in liability exposure.

empty courtroom photo

Result

Summary Judgment Secured for Life Insurance Agent

blue facade of a hospital sign against blue sky

Result

Defense Verdict in Complex Medical Malpractice Trial

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

Supreme Court of Pennsylvania Holds That Public Policy Does Not Prevent Insurance Coverage for Sex Trafficking Claims

On July 21, 2026, the Supreme Court of Pennsylvania issued an opinion emphasizing the limited circumstances in which courts may invoke public policy to bar insurance coverage, holding in Samsung Fire & Marine Insurance Co., Ltd. (U.S. Branch) v. RI Settlement Trust that Pennsylvania public policy does not preclude coverage for claims alleging that insureds enabled or profited from human sex trafficking. The decision rejects a line of federal district court decisions predicting otherwise and reinforces that Pennsylvania courts will invoke the public policy doctrine only in the clearest of circumstances. RI Settlement is particularly significant because it arose on certified questions from the United States Court of Appeals for the Third Circuit, giving the Supreme Court the opportunity to resolve an issue on which federal courts had predicted Pennsylvania law differently. RI Settlement arose out of four separate civil complaints in which the underlying plaintiffs alleged that, as minors, they were the victims of human sex trafficking at various hotels in Philadelphia. The plaintiffs claimed that the hotel owners were negligent in failing to stop the sex trafficking from happening at their hotels. After the filing of the lawsuits, the hotel owners sought coverage under their Commercial General Liability policies. The insurers initially defended the hotels under Reservation of Rights letters, though the carriers later filed Declaratory Judgment actions seeking declarations that they did not owe a duty to defend or indemnify. In short, the insurers argued in the alternative that they did not owe any obligation to provide coverage based upon Pennsylvania public policy (because the claims violated the Human Trafficking Law – 18 Pa.C.S. § 3011) and the terms and conditions of the policy. On motions for judgment on the pleadings, the District Court found for the insurers on the basis of public policy: There is no duty to defend or indemnify against actions arising out of an insured's criminal conduct related to the sex trafficking of minors. The Court appreciates that it may make public policy the basis of a judicial decision only in “the clearest of cases.” See Minnesota Fire & Cas. Co. v. Greenfield, 589 A.2d 854, 868 (Pa. 2004) (quoting Hall v. Amica Mut. Ins. Co., 648 A.2d 755, 760 (Pa. 1994)). Yet, the Court strains to imagine a clearer case than the one presented here in which the facts alleged indicate that Policyholders engaged in criminal conduct in violation of Pennsylvania's Human Trafficking Law. The hotel owners appealed the matter to the Third Circuit, which petitioned the Supreme Court of Pennsylvania to grant review of two certified questions of law: (1) whether Pennsylvania law had an “overriding public policy” against sex trafficking, such that an insurer’s duty to defend and/or indemnify is abrogated when an insured is alleged to have enabled or profited from such trafficking; and (2) if yes, is that duty abrogated whenever the insured’s alleged conduct would constitute a violation of the Pennsylvania Human Trafficking statute. Importantly, the certified questions did not ask the Supreme Court to determine whether the policies afforded coverage under their terms. Rather, the court was asked only whether Pennsylvania public policy independently barred coverage. As a result, the court assumed for purposes of answering the certified questions that the insurers otherwise owed a duty to defend and addressed only the public policy issue, leaving all policy-based coverage defenses for further proceedings. Because the court concluded that the answer to the first certified question was “no”, it did not reach the second issue. In reaching its determination that Pennsylvania public policy does not prohibit insurance coverage for sex trafficking claims, the court limited the impact of its decision in Minnesota Fire & Cas. Co. v. Greenfield, 855 A. 2d 854, 855 (Pa. 2004), which the RI Settlement opinion emphasized as having been an “Opinion Announcing Judgment of the Court” – or a plurality opinion. In Greenfield, the insured homeowner was sued by the estate of his houseguest who overdosed from heroin that he sold to her. The matter wound its way to the Supreme Court, which determined that the insurer did not owe a duty to defend or indemnify based upon Pennsylvania public policy, which criminalized the sale and use of heroin as a Schedule I narcotic. In RI Settlement, the court “decline[d] the invitation” to extend the rationale of the three-justice plurality in Greenfield beyond cases involving Schedule I controlled substances. In so holding, the justices in RI Settlement refused to “divine an overriding public policy pronouncement by the General Assembly by virtue of its enactment of the Human Trafficking Law.” The opinion further states that it is not “within the purview of this Court to rank the magnitude of the public policy underlying the various crimes defined in the Crimes Code. It is sufficient for the work of the courts to know that the General Assembly has identified conduct it deems harmful and dangerous to the maintenance of an orderly society and criminalized it.” While the court declined to declare that Pennsylvania public policy prohibits coverage for sex trafficking claims, the opinion in RI Settlement expressly states that insurers are free to include appropriate exclusionary language for such causes of actions in their policies if they desire to do so. It will certainly be interesting to see whether the insurance industry accepts the court’s invitation, or perhaps whether the Pennsylvania legislature steps in to clarify that sex trafficking claims are indeed of the type or magnitude that they should not be covered by insurance. In any event, we will, of course, continue to monitor this and other insurance coverage issues that arise before courts in Pennsylvania, New Jersey and throughout our firm’s geographic footprint and around the country.