Wolfe v. Stroudsburg Area School Distrist

31 Pa. D. & C.4th 357, 1996 Pa. Dist. & Cnty. Dec. LEXIS 279
CourtPennsylvania Court of Common Pleas, Monroe County
DecidedMay 15, 1996
Docketno. 309 Civil 1995
StatusPublished

This text of 31 Pa. D. & C.4th 357 (Wolfe v. Stroudsburg Area School Distrist) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Monroe County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wolfe v. Stroudsburg Area School Distrist, 31 Pa. D. & C.4th 357, 1996 Pa. Dist. & Cnty. Dec. LEXIS 279 (Pa. Super. Ct. 1996).

Opinion

CHESLOCK, J.,

This action commenced with the filing by plaintiffs of a complaint on February 2,1995. In their complaint, plaintiffs allege that on November 15,1993, Douglas Wolfe was a sixth-grade student at the Stroudsburg Middle School. While in his health class, Douglas was told by his teacher to kneel on the floor. When Douglas stood up some minutes later, he found an “Exacto” knife protruding from his left knee. Douglas had to be taken to the hospital to have the knife removed.

In their complaint, plaintiffs aver, among other things, that:

“The injuries and damages sustained by Douglas H. Wolfe were the sole, direct, legal, and proximate result of the negligence of defendant Stroudsburg Area School [359]*359District through its agents, servants, and employees, acting within the scope of their employment, generally, and in the following particulars:

“(f) in failing to properly design and construct the school building in that:

“(1) it designed and constructed a classroom with carpeted floors which provided a hiding place for sharp objects such as the Exacto knife blade by which Douglas H. Wolfe was injured;

“(2) in [sic] failed to design and construct a classroom with floor material which would permit dangerous objects to be found and retrieved prior to causing injury to students and staff.”

On March 27, 1995, defendant filed an answer and new matter to plaintiffs’ complaint. In its new matter, defendant averred that it was immune from liability for plaintiff’s injury by virtue of the Pennsylvania Political Subdivision Tort Claims Act, 42 Pa.C.S. §8541 et seq. Consequently, on April 3, 1996, defendant filed a motion for summary judgment. Argument was heard on this motion on May 6, 1996 and briefs have been received from both parties. We are now ready to address defendant’s motion.

In support of its motion, defendant argues that it is immune from liability because it has sovereign immunity by virtue of the Tort Claims Act. Defendant further asserts that none of the exceptions to immunity apply to the instant situation. In response, plaintiffs argue that defendant does not have immunity because this situation falls within the real property exception to sovereign immunity found at 42 Pa.C.S. §8542(b)(3). Specifically, plaintiffs allege that Douglas’ injury was the result of the design and construction of the carpeting in the classroom in which Douglas was injured.

We begin our analysis with the applicable standard of review for a motion for summary judgment:

[360]*360“The judgment sought [summary judgment] shall be rendered if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to judgment as a matter of law.” Pa.R.C.P. § 1035(b).

Furthermore, “[SJummary judgment should be granted only where the right is clear and free of doubt.” Hopewell Estates Inc. v. Kent, 435 Pa. Super. 471, 475, 646 A.2d 1192, 1194 (1994).

In support of its motion for summary judgment, defendant relies upon 42 Pa.C.S. §8541, which provides that:

“[N]o local agency shall be liable for any damages on account of any injury to a person or property caused by any act of the local agency or an employee thereof or any other person.”

Conversely, plaintiffs argue that their cause of action falls within one of the exceptions to sovereign immunity and, therefore, their claim survives. Plaintiffs specifically rely upon 42 Pa.C.S. §8542(b)(3), which provides that local agencies will not be immune from suits arising out of the care, custody or control of real property in the possession of the agency. Plaintiffs assert that Douglas’ injury was a result of the design or construction of the carpeting installed in the classroom in which the injury occurred.

We first recognize that, “Exceptions to the rule of immunity must be narrowly interpreted given the express legislative intent to insulate political subdivisions from tort liability.” Farber v. Pennsbury School District, 131 Pa. Commw. 642, 646, 571 A.2d 546, 548 (1990). The Commonwealth Court has also stated that, under the real property exception to sovereign immunity, liability depends, first, on a legal determination that an injury was caused by a condition of government realty [361]*361itself, deriving, originating from, or having the realty as its source. Bullard v. Lehigh-Northampton Airport Authority, 668 A.2d 223, 226 (Pa. Commw. 1995).

The standard to use to determine whether or not the real property exception to immunity applies to a given situation has been stated a number of times by the Commonwealth Court:

“Immunity will be denied a local agency such as a school district only when there is negligence which makes government-owned property unsafe for the activities for which it is regularly used, for which it is intended to be used, or for which it may be reasonably foreseen to be used. . . . Further, immunity will lie when injury occurs due to the faulty supervision and inadequate instruction.” Gore v. Bethlehem Area School District, 113 Pa. Commw. 394, 396-97, 537 A.2d 913, 914 (1988), alloc. denied, 519 Pa. 656, 546 A.2d 60 (1988).

The real property exception to sovereign immunity, although it sounds straightforward, can be a complicated concept to apply. As such, it is often difficult to determine whether the realty itself caused an injury or whether the realty merely facilitated an injury. The Commonwealth Court noted that, “The Pennsylvania Supreme Court has specifically held that the real property exception to governmental immunity applies only to cases where the artificial condition or defect is ‘of’ the land itself, as opposed to a condition or defect which merely facilitates injury to the plaintiff.” Shedrick v. William Penn School District, 654 A.2d 163, 164 (Pa. Commw. 1995), alloc. denied, 542 Pa. 682, 668 A.2d 1142 (1995).

Upon review of the facts of this case, it is obvious that the Exacto knife which caused Douglas’ injury was not always present on the carpeting. Someone either dropped the knife there or left it there after using it. [362]*362Plaintiffs argue that, had there not been carpeting on the floor in that room, Douglas’ injury would not have occurred. Under plaintiffs’ theory, it was the carpeting itself which caused Douglas’ injury in that the carpeting provided a hiding place for the Exacto knife.

We do not read plaintiffs’ claim to state that it is per se negligent for a school district to install carpeting in one of its buildings. Rather, we read plaintiffs’ claim to state that this particular carpeting was harmful in that it provided a hiding place for sharp objects like this Exacto knife.

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Related

Farber v. Pennsbury School District
571 A.2d 546 (Commonwealth Court of Pennsylvania, 1990)
Gore v. Bethlehem Area School District
537 A.2d 913 (Commonwealth Court of Pennsylvania, 1988)
Hopewell Estates, Inc. v. Kent
646 A.2d 1192 (Superior Court of Pennsylvania, 1994)
Shedrick v. William Penn School District
654 A.2d 163 (Commonwealth Court of Pennsylvania, 1995)
Bullard v. Lehigh-Northampton Airport Authority
668 A.2d 223 (Commonwealth Court of Pennsylvania, 1995)

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Bluebook (online)
31 Pa. D. & C.4th 357, 1996 Pa. Dist. & Cnty. Dec. LEXIS 279, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wolfe-v-stroudsburg-area-school-distrist-pactcomplmonroe-1996.