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KEITH E. JOHNSON and
HOLLY M. JOHNSON, his wife,
Plaintiffs
V.
CCI; ENGINEERED PRODUCTS,
INC. and ROTONDO
WEIRICH, INC.,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
CIVIL ACTION -- LAW
NO. 99-7382
ORDER
AND NOW, this day of , 200_, upon consideration of
Defendant CCI's Motion for Summary Judgment, and the briefs of the parties thereon, it is
herebv ORDERED and DECREED that said Motion is GRANTED, and Plaintiffs' claims
against CCI are hereby DISMISSED, with prejudice.
BY THE COURT:
J.
Distribution List:
Keith E. and Holly Johnson
7298 Ulmerton Road
Apartment 108
Largo, FL 33771-4827
Corey J. Adamson, Esquire
Thomas, Thomas and Hafer, LLP
305 N. Front St. POB 999
Harrisburg, PA 17108
10
Hugh P. O'Neill, III, Esquire
Attorney I.D. No. 69986
Corey J. Adamson, Esquire
Attorney I.D. No. 204508
THOMAS, THOMAS & HAFER, LLP
305 North Front Street
Post Office Box 999
Harrisburg, Pennsylvania 17108
(717) 237-7100
E-Mail: honeill@tthlaw.com
cadamson@tthlaw.com
Attorneys for Defendant:
CCI
KEITH E. JOHNSON and
HOLLY M. JOHNSON, his wife,
Plaintiffs
V.
CCI; ENGINEERED PRODUCTS,
INC. and ROTONDO
WEIRICH, INC.,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION --LAW
NO. 99-7382
DEFENDANT CCI' S MOTION FOR SUMMARY JUDGMENT
AND NOW, Defendant CCI ("CCI") by its attorneys, Thomas, Thomas & Hafer, LLP,
files this Motion for Summary Judgment, and avers as follows:
1. Plaintiffs, Keith E. Johnson and Holly M. Johnson ("Plaintiffs") commenced the
within action by filing a Praecipe for Writ of Summons against Defendants on or about
December 8, 1999.
2. Plaintiffs filed their Complaint on January 24, 2000, alleging negligence on the
part of Defendants, including Defendant, CCI.
3. This case arises out of a slip and fall accident which occurred on December 9,
1997, at the Houtzdale Prison construction project.
4. Plaintiffs' Complaint alleges that Plaintiff, Keith E. Johnson, was injured while
working on the Houtzdale Prison job site for Glenco Construction Services', when he slipped on
a piece of plastic that was covered by snow, twisting his knee and causing him to fall and break
his ankle. Complaint ¶¶6-7; 13.
CCI WAS PLAINTIFF KEITH E. JOHNSON'S STATUTORY EMPLOYER AT THE
TIME OF THE ACCIDENT AND IS IMMUNE FROM SUIT
5. Plaintiffs aver that Plaintiff Keith E. Johnson was an employee of Glenco
Construction Services at the time of the accident. Complaint ¶6.
6. Plaintiffs allege, and CCI admits, that CCI was a general contractor on the
Houtzdale Prison project. Complaint ¶8; CCI's Answer with New Matter ¶8.
7. Plaintiffs further allege that CCI "through its agents, servants, workers or
employees" was responsible for the placement of the plastic on which Plaintiff Keith E. Johnson
allegedly slipped. Complaint ¶19-17.
8. At the time of the accident, CCI was the general contractor for the construction of
a prison, the Houtzdale Prison project.
9. At the time of the accident, Defendants Engineered Products, Inc. and Rotondo
Weirich, Inc., were subcontractors on the Houtzdale Prison project.
10. At the time of the accident, CCI had subcontracted with Engineered Products for
the steel erection.
11. At the time of the accident, CCI had subcontracted with Rotondo for the pre-cast
concrete cells which formed the structure of the building.
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12. At the time of the accident, Engineered Products and Rotondo had subcontracted
work to Glenco, including erection of steel beams and crane work..
13. The pleadings in this matter are closed, and discovery has been completed.
SUMMARY JUDGMENT STANDARD
14. A proper grant of summary judgment depends upon an evidentiary record that
either (1) shows that the material facts are undisputed, or (2) contains insufficient evidence and
facts to make out a prima facie cause of action or defense, and therefore, there is no issue to be
submitted to a jury. Pa.R.C.P. 1035.2; McCarthy v. Dan Lepore & Sons, Inc., 724 A.2d 938, 940
(Pa. Super. 1998).
15. When a motion for summary judgment is based upon insufficient evidence of
facts, the adverse party must come forward with evidence essential to preserve their cause of
action. Id.
16. If a nonmoving party fails to come forward with sufficient evidence to establish
or contest a material issue to the case, the moving party is entitled to judgment as a matter of
law. Id.
17. The nonmoving party must adduce sufficient evidence on the issues essential to
its case and on which it bears the burden of proof such that a jury could return a verdict favorable
to the nonmoving party. Id.
18. In other words, once a motion for summary judgment is made and properly
supported, the nonmoving party may not simply rest upon the mere allegations in her pleadings.
Samarin v. GAF, 571 A.2d 398, 402 (Pa. Super. 1989).
' Glenco Construction Services was formerly an Additional Defendant in this matter, and was dismissed from this
matter via stipulation of the parties filed May 21, 2001.
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19. The purpose of Rule 1035(d) "is to assure the motion for summary judgment may
pierce the pleading and to require opposing party to disclose the facts of his defense." Id. (citing
Rowland v. Kravco Inc., 513 A.2d 1029, 1034 (Pa. Super. 1986)).
20. Thus, once the motion for summary judgment has been properly supported, the
burden is upon the nonmovant to disclose evidence that is the basis for his or her argument
resisting summary judgment. Samarin, supra, at 402.
21. Importantly, bold unsupported assertions of conclusory accusations cannot
generate issues of material fact. McCain v. Penn Bank, 549 A.2d 1311, 1313-14 (Pa. Super.
1988).
PLAINTIFF KEITH JOHNSON'S CLAIMS AGAINST DEFENDANT CCI ARE
PRECLUDED BY THE STATUTORY EMPLOYER DOCTRINE
22. The owner of the Houtzdale Prison is the Department of General Services, Bureau
of Construction, of the Commonwealth of Pennsylvania.
23. Via stipulation of the parties, filed on June 28, 2000, COI's Answer with New
Matter was amended to include under the heading "Additional New Matter to Plaintiff' a
paragraph numbered "42," reading "Plaintiffs' claims may be barred or limited by workers'
compensation immunity."
24. CCI now files this Motion for Summary Judgment, avering that under the facts
and circumstances of this case, CCI was Plaintiff Keith E. Johnson's statutory employer at the
time of his alleged fall, and as a consequence, is immune from suit pursuant to Section 203 of the
Workers' Compensation Act, 77 P.S. 52.
25. The issue of whether an employer is a "statutory employer" for purposes of the
Workers' Compensation Act is properly the subject of a motion for summary judgment, as
"whether the facts as they are determined to exist constitute an employment relationship is
strictly a question of law." Wilkinson v. K-Mart, 603 A.2d 659, 660-61 (Pa. Commw. 1992).
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26. A statutory employer is not a contractual or common law employer, but instead is
an employer pursuant to the Workers' Compensation Act. O'Donnell v. R.M. Shoemaker & Co.,
816 A.2d 1159, 1162 (Pa. Super. 2003).
27. As the Pennsylvania Superior Court explained:
Although not apparent from its express terms, the language from
Section [52] [of the Workers' Compensation Act] stating that the
statutory employer shall be liable to such laborer or assistant in the
same manner and to the same extent as to his own employee
confers upon the statutory employer immunity from the suit. By
placing the statutory employer in the same position as the
contractual or common-law employer of the injured worker,
Section 52 entitles the statutory employer to the same immunity
from suit that would be enjoyed by the contractual or common-law
employer.
Id. at 1162-63.
28. Importantly, Courts have found that an entity can be considered a statutory
employer despite language in a contract stating that the employee is an independent contractor
since "courts will not be controlled by the nomenclature the parties apply to their relationship."
Kenney v. Jeanes Hosp , 769 A.2d 492, 496 (Pa. Super. 2001) (noting that the mere labeling of
someone as an independent contractor in an agreement does not determine his legal status, and
that instead, the court must make an independent evaluation of the terms of the contract and all
of the surrounding circumstances).
29. Our appellate courts have long utilized the "McDonald test" for determining
whether a general contractor is a statutory employer, consisting of five elements: (1) an employer
who is under contract with an owner or one in the position of an owner; (2) premises occupied by
or under the control of such employer; (3) a subcontract made by such employer; (4) part of the
employer's regular business entrusted to such subcontractor; and (5) an employee of such
subcontractor. Kelly v. Thackray Crane Rental, -Inc., 874 A.2d 649, 655 (Pa. Super. 2005), citing
McDonald v. Levinson Steel Co., 153 A. 424, 426 (Pa. 1930).
30. An employer will satisfy the control element of the test if either he occupies the
premises or if he is in control of the premises. Douahert 7 v Conduit & Foundation Corte , 674
A.2d 262, 266 (Pa. Super. 1996).
31. At the time of the incident, as CCI was the general contractor for the Houtzdale
prison project and working under contract with the owner, Commonwealth of Pennsylvania, it
was occupying the work premises and was in control of the same.
32. The work that Plaintiffs contractual employer, Glenco, was performing work on
the Houtzdale prison project was part of CCI's regular business, which had been subcontracted
to Engineered Products and Rotondo, who in turned subcontracted it to Glenco.
33. Therefore, based on the facts and circumstances of this case, CCI was Plaintiff
Keith E. Johnson's statutory employer at the time of the incident and is, as a consequence,
immune from suit pursuant to Section 203 of the Workers' Compensation Act, 77 P.S. §52.
LOSS OF CONSORTIUM IS A DERIVATIVE CLAIM AND WHERE THE
UNDERLYING CLAIM IS DISMISSED, THE LOSS OF CONSORTIUM CLAIM MUST
ALSO BE DISMISSED
34. Any action for loss of consortium is derivative, depending for its viability upon
the substantive merit of the injured party's claims. See Boa is v. McCord, 511 A.2d 204
(1986).
35. Because Plaintiff Holly Johnson's loss of consortium claims is dependent upon
the merits of her husband's (Plaintiff Keith Johnson) personal injury claim, and because her
husband's personal injury claim must be dismissed, Plaintiff Holly Johnson's loss of consortium
claim must also be dismissed.
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WHEREFORE, Defendant CCI respectfully requests Your Honorable Court grant its
Motion for Summary Judgment, and dismiss Plaintiffs' claims against it, with prejudice.
Respectfully submitted,
"Thomas, Thomas & Hafer, LLP
by
Date: /a-q-el
qIP9h P• squire
I. o. 6
Core . Adamson, Esquire
1. o.204508
5 N. Front Street
POB 999
Harrisburg, PA 17108-0999
7
CERTIFICATE OF SERVICE
AND NOW, this -?- day of , 2007, I, Corey J. Adamson, Esquire,
for the firm of THOMAS, THOMAS & HAFER, LLP, attorneys for Defendant CCI, hereby
certify that I have this day served the within Motion for Summary Judgment by depositing a
copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania,
addressed to:
Keith E. and Holly M. Johnson (via Certified Mail)
7298 Ulmerton Road
Apartment 108
Largo, FL 33771-4827
•.7
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