HomeMy WebLinkAbout94-5098 CivilGERALD W. HOGAN and : IN THE COURT OF COMMON PLEAS OF
CHARLENE HOGAN, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs :
:
v. : CIVIL ACTION - LAW
:
WATKINS MOTOR LINES, :
INC., JACK JORDAN and
KENNETH ALLEN ROW, :
Defendants : 94-5098 CIVIL TERMS
IN RE: DEFENDANTS' MOTION FOR JUDGMENT N.O.V.
BEFORE HOFFER, P.J.
ORDER OF COURT
AND NOW, January 16, 1998, pursuant to the opinion filed this date, and
after careful consideration of the parties' briefs, Defendants' Motion for Judgment
N.O.V. is denied.
By the Court,
Delano M. Lantz, Esquire
McNees, Wallace & Nurick
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108-1166
For the Plaintiffs
Thomas J. Williams, Esquire
Martson, Deardorff, Williams & Otto
10 East High Street
Carlisle, PA 17013
For the Defendants
GERALD W. HOGAN and : IN THE COURT OF COMMON PLEAS OF
CHARLENE HOGAN, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
:
v. : CIVIL ACTION - LAW
:
WATKINS MOTOR LINES, :
INC., JACK JORDAN and :
KENNETH ALLEN ROW, :
Defendants : 94-5098 CIVIL TERMS
IN RE: DEFENDANTS' MOTION FOR JUDGMENT N.O.V.
BEFORE HOFFER, P.J.
OPINION
HOFFER, P.J.:
This case involves Defendants' Motion for Judgment N.O.V. The facts are
as follows: Plaintiffs and Defendants were involved in an automobile accident in
Cumberland County on May 2, 1994. Defendants admitted liability and a jury trial
was held to determine the extent of Defendants' liability. The jury returned a
verdict in favor of the Plaintiffs for $280,000. From this amount, $35,000 was
awarded to the Plaintiffs for past medical expenses.
Defendants have filed a Motion for Judgment N.O.V. claiming that Plaintiffs
are precluded from past medical expenses by Pennsylvania's Motor Vehicle
Responsibility Law, 75 Pa. C.S.A. Section 1722. However, Plaintiff argues that
this section does not apply to him because Hogan was not a Pennsylvania
resident, his car was not registered in Pennsylvania, and Hogan was not eligible
94-5098 CIVIL TERM
to receive benefits under Pennsylvania law. We now deny Defendants' motion.
DISCUSSION
There are several relevant sections under the Pennsylvania Motor Vehicle
Code which apply to this case. 75 Pa. C.S.A. Section 1722 states:
In any action for damages against a tortfeasor...a person
who is eligible to receive benefits under the coverages
set forth in this subchapter, or workers' compensation, or
any program, group contract or other arrangement for
payment of benefits as defined in section 1719 shall be
precluded from recovering the amount of benefits paid or
payable under this subchapter, or workers' compensation,
or any program, group contract or other arrangement for
payment of benefits as defined in section 1719.
75 Pa. C.S.A. Section 1722 (1996). Benefits set forth in this subchapter are found
in Section 1711: "An insurer issuing or delivering liability insurance policies
covering any motor vehicle of this type required to be registered under this
title...registered and operated in this Commonwealth, shall include coverage
providing a medical benefit in the amount of $5000." 75 Pa. C.S.A. Section 1711
(1996).
Plaintiff is a resident of Texas. Texas law is in direct conflict with
Pennsylvania law because Texas provides medical benefits of $2500 for personal
injury protection coverage on a first-party basis without regard to fault. The insurer
paying such benefits has no right of subrogation. Beyond this provision there are
no other limitations under Texas law with regard to the recovery of medical
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benefits. Tex. Ins. Code Ann. Section 5.06-3. Based upon the above statutes and
the following case law, the Court finds that Pennsylvania law does not apply to this
case.
The Pennsylvania Superior Court has found that the benefits in Section 1711
apply only to those cars registered and operated in Pennsylvania. Pugh v. Govt.
Employees Ins. Co., 552 A.2d 708 (1989). In Pugh, the plaintiff was involved in
an automobile accident in Pennsylvania; however, he was a resident of Maryland
and his motor vehicle was registered in Maryland. At the time of the accident,
Maryland law required minimum benefit coverage of $2500 for medical bills while
Section 1711 required minimum medical coverage of $10,000. Plaintiff claimed
that because the accident took place in Pennsylvania, the Pennsylvania Motor
Vehicle Financial Responsibility Law applied and he should receive $10,000.
Pugh, 552 ^.2d 708-09. The Superior Court said that Section 1711 has 'two
requirements for determining an insured's entitlement to recover first party benefits:
(1) the insured vehicle must be a vehicle of the type required to be registered and
(2) the insured vehicle must actually be registered in the Commonwealth." Pugh,
552 A.2d 709-10. See also Boone v. Stonewall Ins. Co., 382 Pa. Super. 104, 554
A.2d 968 (1989).
In the case at bar, Pennsylvania law is not applicable. None of the vehicles
involved in the accident were registered in Pennsylvania, therefore Section 1711
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does not apply. Section 1722 applies only to those people able to receive benefits
under Section 1711. Because Plaintiff does not fall under this category, Texas law
applies and Plaintiff may collect damages attributable to past medical expenses,
less the $2500 Hogan already received.