French v. Fedorchak

37 Pa. D. & C.5th 140
CourtPennsylvania Court of Common Pleas, Lawrence County
DecidedMarch 17, 2014
DocketNo. 10617 of 2006, C.A.
StatusPublished

This text of 37 Pa. D. & C.5th 140 (French v. Fedorchak) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Lawrence County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
French v. Fedorchak, 37 Pa. D. & C.5th 140 (Pa. Super. Ct. 2014).

Opinion

MOTTO, P.J.,

Before the court for disposition are the defendants’ preliminary objections to plaintiffs’ complaint. The preliminary objections contend that any reference in the complaint to allegations of “recklessness,” “careless disregard,” “reckless indifference,” “conscious indifference,” “outrageous, wanton and grossly negligent conduct,” “unreasonable risk” and “grossly negligent” be stricken from plaintiffs’ complaint because plaintiffs have not alleged any specific facts which would demonstrate that defendants possessed a state of mind or engaged in acts which would elevate their conduct to that of alleged willful, wanton or reckless conduct. Despite the manner in which the defendants in their preliminary objection have framed the issue, the court finds that the dispositive issue in this case is whether the plaintiffs have alleged sufficient facts to support a claim for punitive damages.

According to the complaint, this lawsuit arises out of a vehicular accident that occurred on August 6, 2011, when the plaintiff husband was operating his vehicle in a northerly direction on State Route 62 in French Creek Township, Venango county, Pennsylvania, with [142]*142the plaintiff wife as a passenger. Defendant Fedorchak, while an employee of defendant McClymonds acting in the course of his employment, was operating a tractor trailer loaded with tons of crushed vehicles in a southerly direction approaching plaintiffs’ vehicle on State Route 62. The complaint alleges that Fedorchak drove his tractor trailer at such a speed and in such a reckless manner that the vehicle crossed the center line of State Route 62 into the northbound lane, then attempted to steer back into the southbound lane, causing the load of crushed vehicles to shift and the tractor trailer to leave its axles and roll over, thereby throwing the crushed vehicles from the trailer onto the plaintiffs’ vehicle.

The allegations that plaintiffs rely upon to support a claim for punitive damages include allegations that defendant Fedorchak operated the vehicle at a “high, dangerous and reckless speed under the circumstances,” “driving too fast for conditions,” “failing to make certain that the cargo of crushed vehicles was properly distributed and secured,” “operating the trailer without extreme caution and at an unsafe speed,” “operating the tractor trailer without undertaking a proper pre-trip inspection,” “operating in violation of the Federal Hours of Service Rules,” “operating when defendant knew or should have known he was physically incapable of doing so safely,” and “operating a tractor trailer that was in such condition as likely to cause an accident or breakdown.” Complaint paragraphs 11(a), (h), (m), (o), (p), (q), (r), (u).

Relative to defendant McClymonds supply, defendant Fedorchak’s employer, the complaint alleges outrageous conduct in “failing to properly and adequately investigate defendant’s experience, record and fitness for [143]*143employment,” “failing to generate and/or enforce proper rules, policies and procedures regarding the safe operation of its vehicles,” “allowing defendant operator to drive a tractor trailer when owner knew or should have known that the tractor trailer was improperly maintained and therefore unsafe to drive,” “allowing defendant operator to drive an overloaded tractor trailer which defendants knew or should have known can compromise a tractor trailer’s stability and the driver’s ability to operate,” “allowing defendant operator to haul a load that was improperly distributed and/or not adequately secured,” “failing to establish and enforce safe driving practices and procedures,” “failing to keep the tractor trailer systematically inspected,” and “permitting defendant operator to drive its tractor trailer when he was unable to do so properly, safely, and lawfully and he exhibited a pattern and course of conduct of exceeding posted speed limits, violating state traffic laws and violating federal motor carrier safety regulations hours of service limitations.” Complaint Paragraphs 12(b) through (g), (i), (j).

It is well settled that in considering preliminary objections, the court must accept all material facts set forth in the complaint, as well as all inferences reasonably deducible therefrom as admitted and true, and decide whether, based upon the facts averred, recovery is impossible as a matter of law. See Wiernik v. PHH U.S. Mortg. Corp., 736 A.2d 616 (Pa. Super. 1999). Preliminary objections should be sustained only in cases that are clear and free from doubt. See Pennsylvania AFL-CIO, ex.rel. George v. Commonwealth, 563 Pa. 108, 757 A.2d 917 (2000); Butler v. Illes, 747 A.2d 943 (Pa. Super. 2000). It should be clear from all of the well pleaded facts that the pleader will unable to prove facts sufficient to legally [144]*144establish a right to relief. Id. Any doubt should be resolved by refusing to sustain the objections. See Ellenbogen v. PNC Bank, N.A., 731 A.2d 175 (Pa. Super. 1999).

A leading case in Pennsylvania on the issue of punitive damages is Focht v. Rabada, 217 Pa. Super. 35, 268 A.2d 157 (1970). InFocht, the defendant driver, while proceeding at an excessive speed down a crowded thoroughfare, struck an automobile, which, in turn, struck the plaintiff pedestrian causing personal injuries to the plaintiff. The trial court had ruled that evidence of defendant’s intoxication was inadmissible because it could not support an award of punitive damages. On appeal, the Superior Court vacated the lower court’s ruling and concluded that under the appropriate circumstances, evidence of driving while under the influence of intoxicating liquors may constitute a sufficient ground for allowing punitive damages pursuant to §908 of the restatement of torts. Id. at p. 42. The court went on to say that “driving while under the influence of intoxicating liquor, with its very great potential for harm and serious injury, may under certain circumstances be deemed ‘outrageous conduct’ and ‘a reckless indifference to the interest of others’ sufficient to allow the imposition of punitive damages.” Id. at 40. The Superior Court thus remanded the case to the trial court to determine whether the office of proof were sufficient.1

As noted in Focht, Pennsylvania has adopted the law of punitive damages as set forth in §908 of the restatement of torts and the comments thereunder. Chambers v. Montgomery, 411 Pa. 339, 192 A.2d 355 (1963). §908(1) of the restatement provides that “punitive damages are [145]*145damages, other than compensatory or nominal damages, awarded against a person to punish him for his outrageous conduct, comment (b) of the above section states that ‘outrageous conduct’ consists of acts done with a bad motive or with a reckless indifference to the interests of others.” Punitive damages are thus recoverable when the act is done with reckless indifference as well as with bad motive or intent. Focht, Supra at p. 38.

The Focht

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Related

Chambers v. Montgomery
192 A.2d 355 (Supreme Court of Pennsylvania, 1963)
Butler v. Illes
747 A.2d 943 (Superior Court of Pennsylvania, 2000)
Focht v. Rabada
268 A.2d 157 (Superior Court of Pennsylvania, 1970)
Smith v. Brown
423 A.2d 743 (Superior Court of Pennsylvania, 1980)
Ellenbogen v. PNC Bank, N.A.
731 A.2d 175 (Superior Court of Pennsylvania, 1999)
Wiernik v. PHH U.S. Mortgage Corp.
736 A.2d 616 (Superior Court of Pennsylvania, 1999)
Pennsylvania ex rel. George v. Commonwealth
757 A.2d 917 (Supreme Court of Pennsylvania, 2000)
Joseph v. Naylor
101 A. 846 (Supreme Court of Pennsylvania, 1917)

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Bluebook (online)
37 Pa. D. & C.5th 140, Counsel Stack Legal Research, https://law.counselstack.com/opinion/french-v-fedorchak-pactcompllawren-2014.