S. Brewington v. City of Philadelphia and Walter G. Smith Elementary School -- Appeal of: S. Brewington and J. Brewington

149 A.3d 901, 2016 Pa. Commw. LEXIS 478, 2016 WL 6677925
CourtCommonwealth Court of Pennsylvania
DecidedNovember 14, 2016
Docket886 C.D. 2015
StatusPublished
Cited by13 cases

This text of 149 A.3d 901 (S. Brewington v. City of Philadelphia and Walter G. Smith Elementary School -- Appeal of: S. Brewington and J. Brewington) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
S. Brewington v. City of Philadelphia and Walter G. Smith Elementary School -- Appeal of: S. Brewington and J. Brewington, 149 A.3d 901, 2016 Pa. Commw. LEXIS 478, 2016 WL 6677925 (Pa. Ct. App. 2016).

Opinion

OPINION BY

JUDGE WOJCIK

Syeta Brewington, as parent and natural guardian for Jarrett Brewington, a minor, and Syeta Brewington in her own right (Plaintiff) appeals from the April 27, 2015 order of the Court of Common Pleas of Philadelphia County (trial court) granting summary judgment to Walter G. Smith Elementary School and the School District of Philadelphia (collectively, Defendants).

The-• relevant. facts follow. On May 9, 2012, nine-year-old Jarrett Brewington (Student) was injured during gym class at the Walter G. Smith Elementary School (School). At the time Student was injured, he and other children were engaged in a relay race whose boundaries were concrete walls at either end of the school’s gym. 1 (Reproduced Record (R.R.) at 86a.) Student testified: “I was running too fast and I couldn’t stop and I tripped and fell. ,.. And hit my head on the wall. .., I fell to the ground and blacked out ... blood ran all the way down my face.” (R.R. at 79a-80a; 86a-87a.)

Student suffered a concussion that caused him to miss classes for the final weeks of the spring 2012 semester. His symptoms initially required him to severely curtail his activities, including watching television and even talking, for about three months. Student returned to school in the fall, but his memory problems persisted and his grades dropped. During his February 17, 2015 deposition, Student stated that he still experienced occasional headaches and intermittent memory problems.

On November 19, 2013, Plaintiff filed a Complaint against the School, the School District of Philadelphia, and the City of Philadelphia, 2 alleging in part as follows:

10. [Student] was engaged in gym activities when he was caused to sustain injuries as a result of a defective and dangerous condition of the premises caused directly by the actions/inactions of defendants (i.e. gym without safety mats).
11. Defendants were negligent in maintaining the property that was within their care, custody and control[.]
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*904 23. [Defendants’] negligence and carelessness consisted of the following:
(a) defendants caused or permitted dangerous conditions to exist;
(b) defendants failed to make a reasonable'inspection of the premises, which would have revealed the dangerous condition created by the defendants;
(c) defendants failed to give warning of the dangerous condition and failed to erect barricades or to take any other precautions to prevent injury to [Student];
(d) defendants failed to remove the dangerous condition;
(e) defendants failed to exercise reasonable prudence and due care to keep the gym in a safe condition for the minor plaintiff;
(f) defendants violated the ordinance of Philadelphia County pertaining to maintenance of the premises; and
(g) defendants failed to conform to their own specifications and standards as to design and maintenance of the school gymnasium.
(h) defendants’ negligence was a direct cause of injury to [Student];
(i) defendants were negligent in the care, custody and control of the premises.
(j) defendants were negligent in failing to maintain the property in a safe condition;

(Complaint, ¶¶ 10-11, 23, R.R. at 21a-22a, 24a-25a.)

Defendants filed an Answer and New Matter denying the relevant allegations in the complaint and asserting, among other things, the defense of governmental immunity. Sections 8541-8542 of the Judicial Code, 42 Pa.C.S. §§ 8541-8542, commonly known as the Political Subdivision Tort Claims Act, (Tort Claims Act). On March 2,2015, Defendants filed a motion for summary judgment alleging that they were immune from liability for Student’s injuries because the real property exception to governmental immunity at 42 Pa.C.S. § 8542(b)(3) does not apply.

The trial court granted Defendants’ motion for summary judgment by order dated April 25, 2015. The trial court first focused on the allegation in Paragraph 10 of Plaintiffs Complaint, alleging that Student’s injuries resulted from a “defective and dangerous condition of the premises caused directly by the actions/inactions of defendants (i.e. gym without safety mats).” Relying on Rieger v. Altoona Area School District, 768 A.2d 912 (Pa. Cmwlth. 2001), the trial court held that a claim that Defendants were negligent in failing to protect the walls with safety mats does not fall within the real property exception because safety mats are personalty, not realty. The trial court next determined that, although Plaintiff adequately pleaded a claim of negligent design or construction, that claim was “comingled” with Plaintiffs claim of negligent care, custody and control of real property and accordingly, the holding in Rieger was dispositive.

On appeal to this Court, Plaintiff argues that the trial court erred in granting summary judgment to Defendants because Plaintiffs claim falls within the real property exception to governmental immunity. 3

*905 Local government agencies are generally immune from tort liability. 42 Pa.C.S. § 8541. However, Section 8542 of the Tort Claims Act waives immunity for specific categories of tort claims. It states:

(a) Liability imposed.—A local agency shall be liable for damages on accóünt of an injury to a person or property within the limits set forth in this subchapter if both of the following conditions are satisfied and the injury occurs as a result of one of the acts set forth in subsection
(b):
(1) The damages would be recoverable under common law or a statute creating a cause of action if the injury were caused by a person not having available a defense under section 8541 (relating to governmental immunity generally) or section 8546 (relating to defense of official immunity); and
(2) the injury was caused by the negligent acts of the local agency or an employee thereof acting within the scope of his office or. duties with respect to one of the. categories listed in subsection (b). As used in this paragraph, “negligent acts” shall not include acts , or conduct which constitutes a crime, actual' fraud, actual malice or willful-misconduct.
(b). Acts which may impose liability.— The following acts by a local agency, or any of its employees may result in the imposition of liability on a local agency:
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Cite This Page — Counsel Stack

Bluebook (online)
149 A.3d 901, 2016 Pa. Commw. LEXIS 478, 2016 WL 6677925, Counsel Stack Legal Research, https://law.counselstack.com/opinion/s-brewington-v-city-of-philadelphia-and-walter-g-smith-elementary-school-pacommwct-2016.