Pawlowski v. Conrail Inc.

42 Pa. D. & C.4th 517, 1999 Pa. Dist. & Cnty. Dec. LEXIS 165
CourtPennsylvania Court of Common Pleas, Alleghany County
DecidedFebruary 25, 1999
Docketno. GD96-1087
StatusPublished

This text of 42 Pa. D. & C.4th 517 (Pawlowski v. Conrail Inc.) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Alleghany County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pawlowski v. Conrail Inc., 42 Pa. D. & C.4th 517, 1999 Pa. Dist. & Cnty. Dec. LEXIS 165 (Pa. Super. Ct. 1999).

Opinion

WETTICK, J.,

Conrail Inc.’s motion for summary judgment is the subject of this opinion and order of court. The issue raised through this motion is whether plaintiff may raise claims against Conrail based on the negligence of a general contractor whom Conrail hired to perform work on Conrail’s property.

This is a wrongful death and survival action arising out of the death of Gerald F. Lynch. Mr. Lynch died as the result of the collapse of a portion of a roof in a railroad tunnel (Allegheny Tunnel). Conrail owns the tunnel. Conrail had contracted with Shannon & Wilson Inc. to perform construction management services and with Monterey Construction to enlarge this tunnel. Mr. Lynch was a Monterey employee.

It is Conrail’s contention that the evidence establishes that it was the contractor’s responsibility to take precautions to avoid this type of rock fall and it was the contractor’s negligence which caused the rock fall. Reply brief in support of motion for summary judgment at 10. Conrail relies on the general rule that an employer of an independent contractor is not liable for the physical harm caused to another by an act or omission of that independent contractor or its servants. See Motter v. Meadows Limited Partnership, 451 Pa. Super. 520, 680 A.2d 887 (1996), and cases cited therein. See section 409 of the Restatement (Second) of Torts which provides that except as stated in sections 410-429, the employer of an independent contractor is not liable for physical harm caused to another by an act or omission of the con[519]*519tractor or his servants. Comment (b) to section 409 states that the explanation commonly given for this rule is that since the employer has no power of control over the manner in which the work is to be done by the contractor, it is to be regarded as the contractor’s own enterprise. Thus, the contractor rather than the employer is the proper party to be charged with the responsibility of preventing the risk and bearing and distributing it.

I.

It is plaintiff’s position that even assuming that Mon-terey was an independent contractor with full control over the manner in which the work was to be done, Conrail is liable for Monterey’s negligence because the work that Monterey was performing was exceptionally dangerous. This case, according to plaintiff, is not governed by the general rule that an owner is not responsible for the negligence of its contractor but rather by exceptions to this general rule that hold the owner responsible for the activities of its contractor. These exceptions upon which plaintiff relies are set forth in section 416 and section 427 of the Restatement (Second) of Torts.

Section 416 of the Restatement (Second) of Torts reads as follows:

“One who employs an independent contractor to do work which the employer should recognize as likely to create during its progress a peculiar risk of physical harm to others unless special precautions are taken, is subject to liability for physical harm caused to them by the failure of the contractor to exercise reasonable care to take such precautions, even though the employer has provided for such precautions in the contract or otherwise.”

[520]*520Section 427 of the Restatement (Second) of Torts reads as follows:

“One who employs an independent contractor to do work involving a special danger to others which the employer knows or has reason to know to be inherent in or normal to the work, or which he contemplates or has reason to contemplate when making the contract, is subject to liability for physical harm caused to such others by the contractor’s failure to take reasonable precautions against such danger.”

In Philadelphia Electric Company v. Julian, 425 Pa. 217, 228 A.2d 669 (1967), the Supreme Court adopted sections 416 and 427 as the law of this Commonwealth. It described the impact of these exceptions as follows:

“Sections 416 and 427 recognize that there exists a vicarious liability on the part of an employer of an independent contractor, which imposes upon the former responsibility in damages for the negligence of the latter, regardless of the fault of the former.” Id. at 220, 228 A.2d at 671.

Also see Heath v. Huth Engineers Inc., 279 Pa. Super. 90, 93, 420 A.2d 758, 760 (1980) (employee of independent contractor was killed when a trench collapsed; court held that the owner was liable under section 416 because this section “imposes liability upon an employer regardless of control, the theory being that an employer hiring an independent contractor to do particularly dangerous work ought not to be allowed to insulate himself from liability”).

In Colloi v. Philadelphia Electric Company, 332 Pa. Super. 284, 481 A.2d 616 (1984), the plaintiff — an employee of independent contractor’s subcontractor — was injured when breaking through concrete with a jackham[521]*521mer and striking an electric conduit. The plaintiff raised claims against the owner (Philadelphia Electric) based on the negligence of the independent contractor and its subcontractor. The trial court directed a verdict in favor of the owner; the Superior Court reversed. It ruled that the plaintiff’s evidence was sufficient to make out a prima facie case against the owner under section 416 and section 427 of the Restatement. In its opinion, the court ruled that employees of an independent contractor are among the third parties to whom the duties specified in section 416 and section 427 apply. The court described the duties which the owner owes under section 416 and section 427 as follows:

“The duties defined in these sections are said to be ‘non-delegable’; they impose vicarious liability for the negligence of an independent contractor upon one who employs the contractor to do work involving heightened risks of physical harm to third parties.” Id. at 296, 481 A.2d at 622. (citations omitted)

The remaining issue in part I is whether the evidence, as construed most favorably to plaintiff, makes out the elements of a case under section 416 and section 427. The Pennsylvania courts use the analysis developed in Ortiz v. Ra-El Development Corp., 365 Pa. Super. 48, 528 A.2d 1355 (1987), in deciding whether the section 416-section 427 exception applies.

In that case, an employee was injured when a 14-foot high scaffold collapsed. The employee, relying on section 416 and section 427, sued the owner based on allegations that its contractor failed to assemble the scaffolding in accordance with OSH A standards. The trial court granted the owner’s motion for summary judgment; it ruled that the special risk exception to the general rule [522]*522of nonliability of an employer of an independent contractor was not applicable. The Superior Court affirmed.

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42 Pa. D. & C.4th 517, 1999 Pa. Dist. & Cnty. Dec. LEXIS 165, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pawlowski-v-conrail-inc-pactcomplallegh-1999.