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Defense Digest

Pennsylvania Supreme Court Adopts a “Strict Liability” Standard for UTPCPL “Catch-All” Claims

Defense Digest, Vol. 27, No. 3, June 2021

June 1, 2021

by Dana A. Gittleman and Todd J. Leon

Key Points:

  • Pennsylvania adopts “strict liability standard” applicable to claims brought under “catch-all” provision of UTPCPL, rejecting state-of-mind determination.
  • Going forward, the focus of  claims under the “catch-all” provision will be on words and actions that have the tendency or capacity to deceive, as opposed to intent to deceive.

On February 17, 2021, a 4-3 majority of the Supreme Court of Pennsylvania handed down its decision in Gregg v. Ameriprise Financial, Inc., et al., 245 A.3d 637 (Pa. 2021), holding that a strict liability standard would be applied to claims brought under the “catch-all” provision of the Unfair Trade Practices Consumer Protection Law (UTPCPL). The decision likely has far-reaching consequences for insurers, insurance brokers, financial advisors and real estate brokers, any of whom may now find themselves exposed to liability for conduct that has the potential to deceive, without a showing of state of mind or intent to deceive.

Gregg arose from purported misrepresentations by a broker/financial advisor for Ameriprise to his clients, the Greggs, regarding the purchase of life insurance policies. More specifically, the alleged misrepresentations concerned the manner in which monies the Greggs contributed would be used to fund their account. By way of oversimplification, instead of doing what he told the Greggs he would do in conjunction with funding the policies and the Greggs’ accounts, the broker performed different transactions, which increased the commissions he was paid.

After learning that Ameriprise was the subject of a class action claim involving some of its other clients, the Greggs sued their insurance broker/financial advisor and Ameriprise for negligent misrepresentation, fraudulent misrepresentation, violation of the catch-all provision of UTPCPL, breach of fiduciary duty and negligent supervision. Subsequent to the dismissal of some of the claims, the jury found in favor of Ameriprise on the fraudulent and negligent misrepresentation counts. However, the Greggs prevailed on the UTPCPL claim.

Ameriprise appealed to the Pennsylvania Superior Court and ultimately to the Pennsylvania Supreme Court. It contended that it could not be found to have violated the UTPCPL because the jury had entered a verdict in its favor on the fraud and misrepresentation claims.

The trial court had disagreed with Ameriprise’s contention. It noted that, while claims of fraud and negligent misrepresentation require findings of a defendant’s state of mind (intent to deceive) or negligence, respectively, claims under the UTPCPL “catch-all” provision require no such state-of-mind determination. The Superior Court agreed.

In its recent opinion, the Supreme Court affirmed the rulings below and found that an actor’s state of mind is immaterial under the plain statutory language of the “catch-all” provision of the UTPCPL, which was amended in 1996 to include liability for both “fraudulent or deceptive conduct which creates a likelihood of confusion or misunderstanding.” The key issue for the Supreme Court was the Legislature’s addition of the word “deceptive” in the “catch-all” clause, so that liability was no longer moored to a requirement that fraud needed to be shown in order to trigger liability under the statute.

In examining what the word “deceptive” means, the Supreme Court held that the statute imposes “liability upon commercial vendors who engage in conduct that has the potential to deceive and which creates a likelihood of confusion or misunderstanding.” Simply put, the focus moving forward on claims under the “catch-all” provision will be on words and actions that have the tendency or capacity to deceive, as opposed to whether the actor has the intent to deceive.

In disagreeing with the majority’s construction of the statute, the three-justice dissent focused upon the absence of any language indicating a legislative intent to impose strict liability under the “catch-all” provision of the UTPCPL. Additionally, the dissenters noted that reading the “fraudulent” prong of the “catch-all” clause to require a showing of intent, while reading the “deceptive” prong to be a strict liability provision requiring no state of mind in order to impose liability, was nonsensical. Instead, the minority suggested that the Legislature’s addition of the word “deceptive” into the “catch-all” provision was intended to create a negligence standard that would be applicable in the situation where a “vendor is aware, or should be aware, that his statements are capable of being interpreted in a misleading way by a consumer, regardless of the vendor’s belief regarding the truth or falsity of the statements.”

Gregg, thus, holds that, moving forward, a claim for “deceptive conduct during a consumer transaction that creates a likelihood of confusion or misunderstanding … upon which the consumer relies to his or her financial detriment does not depend upon the actor’s state of mind.” How courts will apply this new standard, particularly in the context of the historical divide between claims for “misfeasance” (an improper performance of a contractual obligation), which are actionable under the UTPCPL, and “nonfeasance” (the failure to perform a contractual duty), which are not actionable, will be just one of many fertile areas of litigation.

With all of the above in mind, it is critical that, at minimum, businesses adopt clear, comprehensive, and accurate disclosures capable of consumer comprehension and understanding in order to combat against the anticipated widening of liability under the court’s adoption of a “strict liability” standard for UTPCPL “catch-all” claims.

*Dana, an associate, and Todd, special counsel, work in our Philadelphia, Pennsylvania office. Dana can be reached at 267.519.6597 or dagittleman@mdwcg.com. Todd can be reached at 215.575.2605 or tjleon@mdwcg.com.

Defense Digest, Vol. 27, No. 3, June 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

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

The Enforceability of Online Arbitration Agreements Remains Unresolved in Pennsylvania, But the Pennsylvania Superior Court has Provided Substantive Guidance on the Issue

Key Points: The Pennsylvania Supreme Court confirms that an order compelling arbitration is not immediately appealable as collateral orders. The outcome of Chilutti II has generally left the substantive enforceability issues with browsewrap agreements unresolved in Pennsylvania. Until this issue is resolved by the Pennsylvania courts, companies operating in the Commonwealth should strive to ensure that their registration websites and/or application screens conspicuously present arbitration agreements in manners which ensure their users and consumers assent to the terms of the agreements by following the standards set forth in Chilutti I. Browsewrap agreements have been defined as agreements “‘in which a website offers terms that are disclosed only through a hyperlink and the user supposedly manifests assent to those terms simply by continuing to use the website,’ and typically do not require an electronic signature.” See, Cobb v. Tesla, Inc., 2026 WL 458470, at *1 n. 2 (Pa. Super. Feb. 18, 2026) (citation omitted). They are largely regarded as the “if you keep using this, you agree to everything buried in this link” terms embedded into almost every online agreement consumers and users sign before proceeding with purchases of goods and/or services. While consumers are generally aware of them, many almost never click on the link, nor read them in their entirety. This leaves many consumers and users ignorant of the terms and impact of such agreements. However, one’s ignorance of the otherwise neatly-tucked-away terms rarely renders them unenforceable. The issue of the enforceability of browsewrap agreements has been up for debate for some time in many jurisdictions, including Pennsylvania. Indeed, Pennsylvania had a brief grip on this issue for a period in time. Specifically, in 2023, an en banc Superior Court set forth heightened standards for companies to meet in order to secure assent and enforce browsewrap arbitration agreements. See Chilutti v. Uber Techs., Inc., 300 A.3d 430 (Pa.Super. 2023) (en banc) (“Chilutti I”) Chilutti I involved a husband and wife who sued Uber and its subsidiaries after the wife, a wheelchair bound passenger using Uber’s rideshare service, fell, struck her head, and lost consciousness due to her uber driver failing to provide a seatbelt and making an aggressive turn during the trip. The Chilutti’s filed a negligence lawsuit against Uber and its subsidiaries. In response, the defendants moved to compel arbitration, arguing that “the couple’s conduct on the company’s website and application — when they registered for the ridesharing service — signified that they agreed to be bound by the mandatory arbitration provision found in the hyperlinked terms and conditions.” The trial court granted the defendants’ petition and stayed the proceedings pending the results of arbitration, and the Chilutti’s appealed. On appeal, the Superior Court addressed two issues. First, it addressed the issue of whether it had jurisdiction to hear the appeal. A divided Superior Court determined that it did, with its basis for the holding being that the order from which the Chilutti’s appealed was a collateral order. Next, the Superior Court set out to address the merits of the Chilutti’s substantive claim. The Superior Court concluded that the parties lacked a valid agreement to arbitrate. Its rationale was that Uber’s website and application did not provide reasonably conspicuous notice of the terms to the Chiluttis. In reaching this decision, the en banc Superior Court held that browsewrap arbitration agreements are enforceable in Pennsylvania only if the registration website and application screens explicitly inform consumers that they are waiving the right to a jury trial, the registration process cannot be completed until the consumer is fully informed of this waiver, and, when the agreement is available via hyperlink, the waiver appears at the top of the first page of the terms in bold, capitalized text. Since the ruling, Pennsylvania courts have applied Chilutti I to determine if browsewrap agreements are enforceable.  For instance, the Allegheny County Court of Common Pleas invoked Chilutti I to reject an agreement that lacked an express jury-trial waiver on the assent screen.  See Miller v. Festival Fun Parks, LLC, 92 WDA 2025 (C.P. Alleg. Cnty. Mar. 24, 2025). Similarly, the Superior Court has held that notice which failed to explicitly state the consumer was waiving a jury-trial right did not “me[e]t the strict burden set forth by our en banc Court in Chilutti I.” Pierce v. FloatMe Corp., 348 A.3d 1077, 1088 (Pa. Super. 2025). While the issue of enforceability of browsewrap agreements appeared to have been resolved by Chilutti I, Pennsylvania courts’ grip on this issue has been slackened by the Pennsylvania Supreme Court’s January 21, 2026, opinion in Chilutti II. See Chilutti v. Uber Techs., Inc., 349 A.3d 826 (Pa. 2026) (“Chilutti II”). Therein, the Supreme Court did not address the merits of the Chiluttis’ substantive claim, but rather the issue of whether the Superior Court had appellate jurisdiction to immediately review the orders staying litigation pending arbitration. The Court ultimately vacated the en banc opinion on jurisdictional grounds, holding that the Superior Court did not have appellate jurisdiction because the trial court’s order from which the Chiluttis appealed did not qualify as a collateral order and, thus, the Superior Court erred in holding to the contrary and lacked jurisdiction to entertain the merits” of the Chiluttis’ substantive claim. As such, Chilutti II has rendered Chilutti I nonbinding, and the issue of enforceability of online arbitration agreements remains unresolved. However, in light of the fact the Supreme Court did not address or comment on the merits of the Chiluttis’ appeal, Chilutti I is still meaningful. Specifically, it provides guidance as to the standards a company should strive to meet to ensure they have obtained users’ assent so that they are able to enforce online arbitration agreements. Additionally, it may serve as persuasive authority in judges’ evaluations of petitions and/or motions to compel browsewrap arbitration agreements until this particular issue is properly put before our appellate courts. Keanna works in our Pittsburgh, PA office. She can be reached at (412) 803-1174 or KASeabrooks@MDWCG.com.

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.