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10.
Plaintiff considered passing the GMc truck along the berm, but the benn was too narrow,
and an overpass lay ahead,
I!.
Plaintiff, initially traveling at approximately 64 miles per hour in a maximum speed limit
zone of 65 miles per hour, then immediately applied the brakes and skidded approximately 180
feet.
12,
Despite the reasonableness of Plaintiffs actions, including his attempts to prevent
accident, Plaintiffs tractor-trailer struck the GMC truck from the rear.
13,
Following the collision, Plaintiff was able to exit Defendant's tractor-trailer without
assistance, and the driver and passenger of the GMC truck, not visibly injured, were able to exit
their truck without assistance.
14,
A few minutes after the collision, a state police trooper from the Bowmansville State'
Police barracks, Trooper Robert Willianls, arrived at the scene and asked both the driver and
passenger of the GMC truck if they were injured, and both responded that they were fine.
15.
After investigating the accident, Trooper Robert Williams deemed the accident "non-
reportable" and decided that the incident did not the warrant the issuance of citations. A copy of
4
Dcparuncnt DISTRIBlJrlON CENTER
Pagc J. of 1
POLICY NO,
TITLE
101
Lurnper Policy &. Practiccs
102
Distribution Ccntcr Security
Driver/Operator Incident Policy
104
Vendor Purchase of Unusablc Pallets
105
Uniform Program (Distribution Center)
106
Dairy Receiving Proccdure
*107
Trailer Seal Procedure
*108
Drug Testing
109
Safety Shoe Program
*110
Store Rcturn Control Sheet
III
Pre-Employment Drug Testing
10:
* = Policies that must be filcd in store manuals,
HRICP.IOO
Giant Food Storcs. Inc,
Corporatc Poliey and Proccdurc Manual
Table of Contcnts
Date Aoril I. 1997
EFFECTIVE
DATE
12/01/88
10/01/81
04/01/97
12/15/88
06/01/91
04/03/89
12/01/88
09/01/92
02/05/92
04/1 0/92
05/08/94
\
ille
Original Effective Dale
Policy No.
Driver/Operator
Incident Policy
01/03/83
Revision Effective Date
04/01/97
103
Page 2 of 4
POLICY/METHODOLOGY: (cont'd)
Note: Since there may be incidents that arc non-preventable, but do not fall under tlle non-prevencable
definition, Distribution Center management will make the decision as to whethcr an aceidcnt was noo-
prevcntablc.
\_/ g.
Prcventable accidcnt - one in which the drivcr/opcrator failed to do evcrything reasonable to prevcnt an
accident, bascd on adhering to applicablc laws and defensive driving tcchniques. This also includes
performing proper pre-trip inspections to detect equipment degradation that if detected could have prevented
an accident.
J2.
Non-chargeable and non-oreventable accidents, Associates involved in non-chargeable and non-prcventable accidents
are not subject to disciplinary action, Howcver, all accidcnts must bc discussed and documented with the appropriatc
supervisor and Dircctor of Distribution. Accident reports and reports of occupational injury will be fillcd out when
circumstanccs warrant.
v3.
Chargeable and orevcntablc accidents. Disciplinary action up to and including termination will be a consideration
for all chargeable accidents. Each accidcnt must be handled on a casc-bv-case basis, \\ith the seriousncss and
circumstan~cs of the accident being the major consideration, Separation' will bc considcred for seriOus preventablc, ,
accidents resulting in bodily injury, death, major propcrty damage, or negligcnce, which includes violation of compllJ.,'
policies. Steps for corrcctive action arc as follows (documentation for each occurrcncc will remain on filc
pennanently):
va
Minor accidents: A minor accident is any accident resulting in minor damage to vehicles, company
property and/or cquipment,
\,...,/~ First accident - a counscling discussion and a Constructive Advice Report filed in the associate's
pcrsonnel file, Ncwly hircd associatcs under probation may be tcnninated if circumstances so
warrant.
. Second accident (,,;thin a 24 month period of last accident) - counseling discussion with a
Constructivc Advice Rcport filed, and threc day suspension from work without pay,
. Third accident (\\ithin a 24 month pcriod oflast accident) - samc as second accident, cxccpt 5 days
suspension from work without pay.
. Fourth accident ("ithin a 24 month period of last accidcnt) - termination of employment.
Vb,
Serious accidents: Giant management ,,;11 detennine whethcr an accident is to be deemed as minor or
serious on a case-bv-casc basis.'" Howcvcr, an accidcnt "ill be considcrcd serious if it rcsults in serious bodily
injury, dcath, majo; property damagc or negligence, which includcs violation of company policies.
Tcrmination \\ill be the major consideration for all serious accidents.
PLII03
i
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'itle
Ori~inal Effective Dale
Policy No.
Driver/Operator
Incident Policy
01/03/83
Revision Effective Date
04/01/9i
103
I'anc 3 of 4
POLlCY/METHODOLOGY: (cont'd)
. First serious accident - Newly hircd associates undcr the probational)' period \\ill be tenninated.
Nonnally:my associate involved in a serious accident \\ill be terminated. However, Gi:mt
m:magement \\ill determine if mitigating circumstances warrant that :m associate \\ill continue
employment with Gi:mt. If it is deemed an associate can continue tenure with Gi:mt :md there is a
position available for which the associate is qualified, the associate may apply for the open position,
Giant m:magement will determine what driving privileges, if any, will be allowed,
. Secund serious accident - Mandatory tennination.
4. Traffic citations, Any traffic citation given to an associate while operating a company vehicle \\ill be handled at
management's discretion using the follO\ving as a guideline, All citations must be viewed \vith concern, but the
circumstances surrounding the issuing of a citation may be classified as minor or serious and to what degree the driver
had control over the incident. For example, if a driver is cited for driving overweight or if the registration has expired,
this citation may not be counted against the associate's record. Management will make a detennination on whether a
dri\'er should be held responsible for a citation as defined under this policy, General guidelines to distinguish between
a minor :md serious offense are as follows:
a, Some examples of minor citations: Not having your license with you while driving, and failure to
nOli!}' state of address change,
b, Some examples of serious citations (which are generally moving violations, but not limited only to moving
violations): failure to obey traffic device, driving through red signal, exceeding the posted speed limit. unsafe
lane changing, reckJessdriving, follO\ving vehicle too closely.
c. Minor citations \vill be handled on a case-by-case basis, but the minimum action taken for minor citations
\\ill be the submission of a Constructive Advice Report,
d. Serious citations \\ill be handled as follows:
. First offense (within 12 months): Constructive Advice and 3 day suspension,
. Second offense (within 12 months of previous citation): Constructive advice and a 5 day suspension.
. Third offense (\\ithin 12 months of previous citation): Te~tion at management's discretion.
5, Unsafe drivinl!!irresponsible driving. Ifa report is received by management from a credible source regarding a
driver operating a company vehicle in an unsafe or irresponsible manner, management will conduct an investigation to
determine what action should be taken, Ifit is believed the report has merit, the Director of Distribution will decide 01:
the appropriate response; at a minimum., a Constructive Advice Report \\ill be submitted. However, if deemed serious
credible reports can be handled in the same manner as citations in paragraph 4 (above),
PLII03
J.E TERRY ASSOCIATES, INC.
Pennsylvania
Independent Multi-Line Adjusters
1'.0, Box 219
333 E. Luneaster Ave.
Suite 202
\Vynnewood.PA 19096
New Jersey
!-Iome Offiee
March 13, 1998
(610) 649,5134
Delaware
1.800.243.7238
Fax: (6tO) 649.5664
,Reference:
D/L:
Our file:
Ernest Morris vs,
Giant Foods
1-15-98
98-1-246-83
Dear Mr, McKnight:
ASSIGNMENT:
This report serves to acknowledge our receipt of this
assignment to investigate the accident of 1-15-98 on the
Pennsylvania Turnpike involving Giant Foods' driver, Ernest
Morris.
ACCIDENT FACTS:
On the date of Thursday, 1-15-98 at approximately 7:30 A.M"
Mr, Ernest Morris was traveling alone and driving a Giant
Foods tractor-trailer westbound on the Pennsylvania Turnpike
near milemarker 288.1. The truck was carrying only wooden
pallets and bales of cardboard, no groceries, The weather was
clear, with no precipitation evident, Mr, Morris was
traveling in the right of the two lanes of travel. In this
area there are concrete barriers separating the eastbound from
the westbound lanes, and a shoulder on the right side--wide
enough for a parked vehicle. There are no exit ramps nor
pull-off parking areas in the vicinity where this accident
occurred, According to theon-board computer on Mr. Morris's
truck, he was traveling no more than 64 miles per hour prior
to this accident,
The accident occurred just past the Bowmansville State Police
barracks, The milemarker 288.1 is located about 50 feet west
of the Panorama Road bridge overpass to the Turnpike,
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A 1990 GMC truck with a hydraulic lift in the back was also in
the right lane ahead of Mr. Morris. This truck had one driver
and one passenger and had no hazard lights nor brake lights on
prior to this accident, Upon spotting this vehicle ahead of
him, Mr, Morris applied his brakes and skidded approximately
-2-
180 feet, striking
milemarker 288,1
overpass,
the GMC truck in the rear approximately at
just west of the Panorama Road bridge
Mr, Morris was able to exit his truck on his own. The driver
and passenger were not visibly injured and were able to exit
their vehicle on their own, A state police trooper from the
Bownamsville State Police barracks arrived at the scene within
a few minutes and spoke with all individuals involved. The
officer who responded to the scene was Trooper Robert
Williams, Badge #6222, Trooper Williams did not write up any
citations for any of those involved. He also deemed the
accident as non-reportable in that no ambulance was required
and no towing was required directly from the scene.
Both vehicles were driven further down the turnpike and
stopped at a resting area, where information was exchanged,
The trooper asked the other driver and passenger if they were
O.K, Both responded that they were fine, An EMT responded to
the scene soon after and also asked Mr, Morris and the other
two individuals if they were O.K. Both the driver and the
passenger of the other vehicle refused to sign a paper stating
that they refused treatment. Therefore, an ambulance was
called and both were taken to the closest hospital. In the
meantime, Mr, Morris awaited a tow truck to transport his
damaged truck, (The truck's radiator was damaged in that it
was punctured by the hydraulic lift located on the back of the
claimant vehicle.) while Mr. Morris was waiting, the other
driver and passenger came back to their car and drove away
without any assistance, A tow truck arrived soon afterwards
and towed Mr, Morris's truck from the scene,
SCENE INVESTIGATION:
Enclosed please find several scene photographs of the accident
area at Milemarker 288,1 on the Pennsylvania Turnpike near the
Bowmansville State Police barracks. As a vehicle travels west
on the Turnpike, there is a slight curve after the Panoram~
Bridge Road overpass, Prior to and after the bridge, the road
is basically straight and level. There is a concrete barrier
separating the west from the east bound lanes of traffic on
the Turnpike, On the right there is a shoulder area with
enough room for a vehicle to be parked, and it is possible
that a vehicle could have pulled from this area prior to a
truck approaching the bridge area,
The maximum speed limit on the Turnpike in this area is 65
miles per hour, The minimum speed limit in this area is 40
miles per hour.
-3-
CLAIMANT INFORMATION:
The driver of the claimant
J. Nankn of the Bronx, New
had one identified male
accident,
vehicle was identified as Bhoowan
York, date of birth 11-20-63, He
passenger at the time of this
The vehicle Mr. Nankn was driving was a 1990 GMC 4000 truck
with a hydraulic lift, The truck is used to haul chickens and
had empty crates on board at the time, New York license plate
7S732AJ. Mr, Nankn's insurance was identified as All City
Insurance, with policy #2120155030. There was approximately
$5,000 to $6,000 worth of damage caused to the claimant's
truck.
Both claimants were taken to Hershey Medical Center, reporting
minor injuries, Initially they told both Mr. Morris and the
police officer that they were O,K. After an EMT responded to
the scene, they said they would need to be taken to a
hospital.
NON-PREVENTABLE DETERMINATION:
Mr, Morris has claimed that he made every effort to prevent
this accident from occurring, He was traveling at a safe
speed of 64 miles per hour, in the right hand lane, under
normal weather conditions, He has been an experienced truck
driver for the past fifteen years, driving an lS-wheeler for
the past 12 years, During that time he has found to be at
fault for no accidents and has received no traffic violations
while driving a truck, He has driven for Giant Foods for the
past two years and has a clean driving record, Furthermore,
Mr. Morris has nothing to gain by getting into this accident
and only everything to lose.
It was viewed at the accident scene immediately following the
accident that there were skidmarks of approximately lS0 feet
leading to the impact area, Many of these skidmarks were
found to be located near or O~ the center lines of the
roadway, suggesting that Mr, Morris made an attempt to move to
his left but another vehicle was already in the process of
passing him,
It was also determined earlier that roughly 51,4 feet of
skidmarks could be made per second at Mr, Morris's speed of 64
miles per hour, However, if the brakes were applied causing
ISO feet of skidmarks, Mr, Morris's speed would have dropped,
Because the speed would have dropped, the amount of time
before impact would have been considerably longer than the 1
to 2 seconds he was said to have only taken avoidance action
before impact.
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99-471 CIVIL
456 Pa. 171, 175,319 A.2d 174, 176 (1974). See also Brozovich v. Dugo, 651
A.2d 641, 643 (Pa. Cmwlth. 1994). The presumption of at-will employment may
be rebutted if ''the employee provided additional consideration apart from the
detriments commensurate with those incurred by all manner of salaried
professionals." Brozovich at 643. "The employer's privilege to dismiss an
employee with or without cause is not absolute, however, and may be qualified by
the dictates of public policy." Shick v. Shirey. 552 Pa. 590, 595, 716 A.2d 1231,
1233 (1998).
Public policy is set by a virtual unanimity of opinion in the community and
establishes a policy for what is just and right related to public health, safety,
morals, and welfare, Shick at 600, 716 A.2d at 1235-36 (citations omitted).
Pennsylvania courts have recognized the following examples of public policy
trumping the presumption of at-will employment: (1) a cause of action in wrongful
discharge existed because public policy was violated where employee terminated
for filing for unemployment compensation, a statutory right'; (2) a violation of public
policy occurred where employment was conditioned upon taking a polygraph test
even though Pennsylvania law expressly prohibits such a condition on
1 Hiahhouse v. Averv Transport, 443 Pa, Super. 120,660 A,2d 1374 (1995).
4
99-471 CIVIL
employment2; (3) public policy was violated where employee denied employment
based upon a conviction that had been pardoned despite the fact that such action
was impermissible under the Pennsylvania Constitution3; and (4) employee had a
cause of action for wrongful discharge because employment terminated for serving
jury duty, a violation of public policy because of the existence of the statutory
requirement to serve jury duty4.
In the case at bar, plaintiff is not able to overcome the presumption that his
employment with defendant was at-will. Nothing has been pled claiming that
plaintiff provided any additional consideration to defendant beyond that which
ordinary employees provide. Therefore, defendant's privilege to terminate plaintiff
for any or no reason remained intact.
Plaintiff does not claim that his firing was in violation of public policy.
Plaintiff's complaint alleges that he was wrongfully discharged because defendant
incorrectly characterized the January 15, 1998 accident and, therefore, failed to
follow the provisions set out in Policy 103, Although Policy 103 clearly states that
employees are not subject to discipline for non-chargeable and non-preventable
2 Kroen v. Bedwav Sec. Aoenev, Ine" 430 Pa. Super, 83, 633 A.2d 628 (1993).
3 Hunter v, Port Authoritv. 277 Pa. Super. 4, 419 A,2d 631 (1980).
4 Reuther v. Fowler & Williams, Ine" 235 Pa. Super. 28, 386 A.2d 119 (1978).
5
99-471 CIVIL
accidents, the discretion to determine whether an accident is non-chargeable is left
solely in the hands of defendant's Distribution Center management. Under Policy
103, characterizing an accident as chargeable or not is a decision left to the police
or the Distribution Center management.
Plaintiff claims that defendant's investigation of the accident was not
thorough enough, in light of the trooper's characterization of the accident as non-
reportable, to allow defendant to terminate plaintiff's employment. As discussed
above, plaintiff's employment with defendant was at-will and the provisions of
Policy 103 did not alter the fact that defendant maintained the right to terminate
plaintiff, its at-will employee, for any or no reason. Plaintiff cannot overcome the
presumption of at-will employment. No violation of public policy occurred when
plaintiff was terminated from his job. Accordingly, plaintiff has failed to state a
cause of action for wrongful discharge upon which relief can be granted.
Therefore, defendant's Preliminary Objection, in the form of a demurrer to count
one of plaintiff's complaint, is granted.
Breach of Contract
Plaintiff further alleges that the termination of his employment was carried
out by defendant in breach of an employment contract between the parties that
was created by Policy 103. Plaintiff argues that Policy 103 transformed his
6
99-471 CIVIL
employment from at-will into a contractual relationship, to be terminated only upon
violations of defendant's stated employment policies.
As stated above, employment in Pennsylvania is presumed to be at-will,
absent a statutory or contractual provision to the contrary. Gearv v. U.S. Steel,
456 Pa. 171,319 A.2d 174 (1974).
In order to rebut the presumption of at-will employment,
a party must establish one of the following: (1) an
agreement for a definite duration; (2) an agreement
specifying that the employee will be discharged for just
cause only; (3) sufficient additional consideration; or (4)
an applicable recognized public policy exception.
Luteran v. Loral Fairchild Coro., 455 Pa. Super. 364, 370, 688 A.2d 211, 214
(1997).
Plaintiff, in the case at bar, has not pointed to an agreement for a definite
duration, additional consideration, or a violation of public policy as evidence to
rebut the presumption of at-will employment. Plaintiff relies solely on Policy 103
to claim that defendant could not terminate his employment absent just cause, as
defined in Policy 103. Plaintiff claims that the handbook, in which Policy 103 is
found, created a binding contract between the parties, even though it was issued
unilaterally by defendant. The policy also allowed defendant to unilaterally change
any or all provisions of the policy. Furthermore, the policy does not include an
express provision stating that employees may only be terminated for just cause.
7
99-471 CIVIL
A handbook is enforceable against an employer if a
reasonable person in the employee's position would
interpret its provisions as evidencing the emploYElr's
intent to supplant the at-will rule and be bound legally by
its representations in the handbook. The handbook must
contain a clear indication that the employer intended to
overcome the at-will presumption. We have held that it
is for the court to interpret the handbook to discern
whether it contains evidence of the employer's intention
to be bound legally.
Luteran at 371,688 A.2d at 214-15 (citations omitted).
Plaintiff cannot overcome the presumption of at-will employment. Policy 103
includes no clear indication of defendant's intent to create a contractual relationShip
with plaintiff and supplant the at-will rule. Policy 103 merely reflects defendant's
company policy of promoting the reporting of accidents and presents proposed
methods for dealing with accidents and subsequent discipline.5 Defendant issued
the policy and maintained the right to unilaterally change its provisions. Nothing
has been pled and no evidence can be pointed to that supports plaintiff's allegation
that he can be terminated only for just cause. Plaintiff has failed to state a cause
of action for breach of contract. Therefore, defendant's demurrer to count two of
5 Even if a binding contract was formed, defendant followed the provisions of
Policy 103 when it conducted an investigation and used its permissible discretion to
determine that plaintiff's employment was to be terminated.
8