DeJoia v. City of Meadville

3 Pa. D. & C.4th 444, 1989 Pa. Dist. & Cnty. Dec. LEXIS 206
CourtPennsylvania Court of Common Pleas, Crawford County
DecidedSeptember 21, 1989
Docketno. 1987-92
StatusPublished
Cited by1 cases

This text of 3 Pa. D. & C.4th 444 (DeJoia v. City of Meadville) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Crawford County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
DeJoia v. City of Meadville, 3 Pa. D. & C.4th 444, 1989 Pa. Dist. & Cnty. Dec. LEXIS 206 (Pa. Super. Ct. 1989).

Opinion

WALKER, J.,

— This declaratory-judgment action raises a novel issue of law on essentially undisupted facts.

On February 29, 1984, Ruth Ann Dejoia, wife plaintiff, fell at a parking lot in the City of Meadville, operated by the Parking Authority of the City of Meadville (hereinafter collectively referred to as the municipal defendants). At the time of the fall, wife plaintiff was an employee of Crawford County, which carried workers’ compensation insurance through defendant, Fireman’s Fund Insurance Companies. Apparently it was determined that plaintiffs injuries occurred during the course of her employment, and Fireman’s Fund as the workers’ compensation carrier has paid out substantial funds as workers’ compensation and for medical expenses. Plaintiffs have filed suit against the municipal defendants to recover damages arising out of the incident alleging tortious conduct on the part of the municipal defendants.

Fireman’s Fund notified plaintiffs of its intention to subrogate against any recovery made by plaintiffs for the workers’ compensation benefits paid to wife plaintiff either past or future. Plaintiffs then filed this declaratory-judgment action to determine the right of Fireman’s Fund to subrogation against any recovery in the tort action alleging, and we believe rightly so, that a ruling on the issue would facilitate ultimate settlement of the underlying tort case.

Although plaintiffs commenced this declaratory-judgment proceeding with a view toward facilitating settlement, other than that possibility, plaintiffs have no substantial interest in the outcome. This is essentially a dispute between two insurance carriers as to who will bear the burden of the injuries. The municipal defendants have moved for summary judgment to resolve the issue since there are no [446]*446disputed facts, and the legal issue revolves around the interpretation of section 319 of the Pennsylvania Workmen’s Compensation.Act, 77 P.S. §671, which grants to an employer a subrogation claim to the rights of an employee against third persons, and its interface with the Political Subdivision Tort Claims Act, 42 Pa.C.S. §8541 et seq., and particularly, the section, relating to limitations on damages, 42 Pa.C.S. §8553.

It can thus be seen that the real issue joined is between two insurance carriers as to who will bear the brunt of the expense if plaintiffs are successful in their tort action. If there is a right of subrogation and the plaintiffs ultimately succeed in the tort action, then the entire burden is shifted to the liability insurance carrier for the municipal defendants. If threre is no right of subrogation and plaintiffs ultimately succeed in Winning a verdict in the tort action excluding -damages duplicating the amounts paid under the Workmen’s Compensation Act, the two insurance carriers will to some degree jointly bear the financial burden, albeit not necessarily equally since that will depend upon the size of the tort verdict.

42 Pa.C.S. §8553(d) provides as follows:

“If a claimant receives or is entitled to receive benefits under a policy of insurance other than a life insurance policy a.s a result of losses for which damages are recoverable under subsection (c) the amount of such benefits shall be deducted from the amount of damages which would otherwise be recoverable by such claimant.”

A brief review of the history of governmental immunity sometimes intertwined with sovereign immunity in the decisions of our appellate courts may be helpful in our analysis of the Political Subdivision Tort Claims Act. The genesis of the [447]*447doctrine of governmental immunity has generally been traced to the English case of Russell v. Men of Devon, 100 Eng. Rep. 359 (K.B. 1788). Gradually, Russell became engrafted in the common law of the several states of the United States. In Pennsylvania the doctrine had a somewhat uneven growth. Eventually, however, two tests emerged from the Pennsylvania case law, first an examination of whether the duty of the municipality was mandatory or discretionary, and second, whether that duty was a governmental or a proprietary function.

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Bluebook (online)
3 Pa. D. & C.4th 444, 1989 Pa. Dist. & Cnty. Dec. LEXIS 206, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dejoia-v-city-of-meadville-pactcomplcrawfo-1989.