Emerick, C. v. Erie Insurance Exchange

CourtSuperior Court of Pennsylvania
DecidedFebruary 27, 2026
Docket88 WDA 2025
StatusUnpublished
AuthorOlson

This text of Emerick, C. v. Erie Insurance Exchange (Emerick, C. v. Erie Insurance Exchange) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Emerick, C. v. Erie Insurance Exchange, (Pa. Ct. App. 2026).

Opinion

J-A26017-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

CHRISTOPHER EMERICK ON BEHALF : IN THE SUPERIOR COURT OF OF HIMSELF AND AS EXECUTOR OF : PENNSYLVANIA THE ESTATE OF JANET EMERICK : : Appellant : : : v. : : No. 88 WDA 2025 : ERIE INSURANCE EXCHANGE :

Appeal from the Judgment Entered December 17, 2024 In the Court of Common Pleas of Allegheny County Civil Division at No(s): GD-19-15291

BEFORE: OLSON, J., STABILE, J., and KING, J.

MEMORANDUM BY OLSON, J.: FILED: February 27, 2026

Appellant, Christopher Emerick on behalf of himself and as executor of

the Estate of Janet Emerick, appeals from the December 17, 2024 judgment

entered in the Court of Common Pleas of Allegheny County upon a jury verdict

in favor of Appellant and against Erie Insurance Exchange (“Erie Insurance”).

Upon review, we affirm.

The trial court summarized the factual and procedural history as follows:

Janet Emerick was the owner and resident of a home located [] in Economy Borough, Beaver County, [Pennsylvania,] when the home and a separate storage structure nearby were struck by a windstorm during the night of November 17, 2018. The home was constructed in the year 1849 and[, at the time of the windstorm,] had its original, decorative slate roof. The morning after the windstorm, Linda Emerick (Janet Emerick’s daughter-in-law) noticed that numerous tree branches had apparently been blown down. One branch penetrated the roof of the separate storage structure, which was referred to as the “spring house.” Another J-A26017-25

large branch was hanging from the roof of the home where Linda Emerick resided with Janet Emerick. [Appellant] (Janet Emerick’s grandson and Linda Emerick’s nephew) had been responsible for maintaining the property, and Janet [Emerick] telephoned him and asked for help removing the tree limb from the roof of her home. [Appellant] was in Michigan on a work assignment when Janet [Emerick] spoke to him over the telephone about the tree limb on the roof. On November 19, 2018[,] Linda [Emerick] found there was water leaking into the home from the ceiling of its third floor/attic[. ]Janet [Emerick] telephoned her homeowners insurance company, Erie Insurance[,] and notified it that her home had been damaged by the November 17, 2018 windstorm.

Two or three days after his grandmother telephoned him asking for assistance, [Appellant] went to her home. He observed a tree branch hanging off the roof that was 16 to 18 inches in diameter at its base and 25 to 30 feet long. He placed a ladder near the tree branch and was able to get it to drop from the roof to the ground without injuring himself. [Appellant] believes the tree branch weighed at least 150 pounds. Janet [Emerick made] [Appellant] a joint owner of the property [in] 2019.

Erie Insurance [] adjuster Jason Watkins [(“Mr. Watkins”)] went to the Economy Borough property on November 25, 2018. He viewed and photographed the damage to the home and the spring house, using a drone to photograph the home’s roof from above. Mr. Watkins issued an estimate of $5,020.50 in damages[,] and [based upon the estimate, Erie Insurance sent] a $4,520.50 check [made payable] to Janet [Emerick], reduced by the insurance policy’s $500[.00] deductible. Mr. Watkins’ estimate allocated $1,726.56 towards the repair of the damage to the home’s decorative slate roof. Believing repair of the damage to her home would cost more than $5,020.50, Janet [Emerick] hired public adjuster Brian Pfister [(“Mr. Pfister”)] to represent her for a fee of 20 percent of any additional payments made by [Erie Insurance]. See 63 P.S. [§]§ 1601-1607 and Pennsylvania’s Insurance Department regulation at 31 PA. CODE § 115.2 that allows public adjuster compensation to be “expressed as a percentage of any payments to be received on the negotiated claim."

On January 11, 2019[,] Mr. Pfister [sent Erie Insurance] an estimate[, via electronic mail, that] he prepared in the total amount of $121,598.77 to repair the home and the spring house. On January 24, 2019[,] Mr. Pfister, Erie [Insurance] adjuster Michele Buck [(“Ms. Buck”)] and Joshua Hunt [(“Mr. Hunt”)], a

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professional, structural engineer hired by Erie [Insurance], met at [the] property. They inspected the interior of the home and the interior and exterior of the spring house, but the inspection of the roof [on] the home by Mr. Hunt was postponed due to an accumulation of snow on [the roof. Eighteen] days later[,] Erie [Insurance] sent Janet [Emerick], care of Mr. Pfister, a revised estimate [along] with a check for an additional [payment of] $7,751.75. With the $4,520.50 check sent in November [] 2018, this brought the total amount Erie [Insurance] paid on the claim to $12,272.25. On April 2, 2019[,] Mr. Hunt returned to [the] property to inspect the roof. Thereafter, Mr. Pfister, on behalf of Janet [Emerick], and Erie [Insurance] were unable to reach an agreement on the amount of the damages to the home and the spring house. There were two primary areas of disagreement. First, Erie [Insurance] believed the slate roof of the home could be repaired by replacing [four] missing pieces of slate, while Mr. Pfister and Janet [Emerick] believed Erie [Insurance] was obligated to pay the replacement cost for the home’s entire slate roof. Second, Erie [Insurance] believed the only repair required for the spring house was replacement of the non[-]slate roof, while Mr. Pfister and Janet [Emerick] believed Erie [Insurance] was obligated to pay for demolition of the entire spring house together with construction of its replacement.

[Appellant commenced an action against Erie Insurance by filing a praecipe for writ of summons on October 31, 2019. Ultimately, Appellant filed an amended complaint, on April 30, 2020, raising claims for breach of contract and bad faith, pursuant to 42 Pa.C.S.A. § 8371.] In January [2020,] Janet Emerick and [Appellant] had the entire slate roof of the home replaced by asphalt shingles for the price of $19,380[.00]. A suggestion of the death of Janet Emerick was filed in November [] 2021. Before the trial [on] the breach of contract claim began, [Appellant] argued a motion in limine to preclude [Erie Insurance] from presenting evidence of [the insurance policy’s] functional replacement cost loss settlement endorsement. [Appellant] believed [Erie Insurance] could not assert a provision in its homeowners insurance policy relative to the slate roof of the home that allowed [Erie Insurance] to limit payment to “the amount which it would cost to repair or replace the damaged building with less costly common construction materials and methods which are functionally equal to obsolete, antique or custom construction materials and methods used in the original construction of the

-3- J-A26017-25

building.” [The trial court] denied [the] motion [on January 25, 2024].

[A trial on Appellant’s breach of contract claim commenced on January 17, 2024.] The jury had a difficult time reaching a verdict. The jury submitted approximately [twelve] written questions to [the trial court] while deliberating for approximately [nine] hours over the course of [two] days. [The trial court] then submitted to the jury, without objection from counsel, the written question of whether the jurors believed they were hopelessly deadlocked. After receiving a response that [ten] jurors were willing to keep talking but several said they will not change their minds, [the trial] charged the jury on the consequences of them being hopelessly deadlocked. Shortly afterward the jury rendered a verdict[, on January 24, 2024, in favor of [Appellant and awarded damages] in the amount of $19,380[.00].

[Appellant] promptly filed a motion for post-trial relief [that sought] a new trial as to damages only[. The trial court] denied [the motion on May 20, 2024.]

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Cite This Page — Counsel Stack

Bluebook (online)
Emerick, C. v. Erie Insurance Exchange, Counsel Stack Legal Research, https://law.counselstack.com/opinion/emerick-c-v-erie-insurance-exchange-pasuperct-2026.