HomeMy WebLinkAbout2006-5370 Civil
JAMES D. HEGARTY and
JEAN MARIE HEGARTY,
Individually, and as parents
and natural guardians of
Brendan Hegarty, a minor,
Hugh Hegarty, a minor, and
John Hegarty, a minor,
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
CUMBERLAND V ALLEY
SCHOOL DISTRICT,
H.E. ROHRER, INC.,
CHAD T. KOVACH,
Defendants
NO. 06-5370 CIVIL TERM
IN RE: DEFENDANT CUMBERLAND VALLEY SCHOOL
DISTRICT'S PRELIMINARY OBJECTIONS TO PLAINTIFFS'
FIRST AMENDED COMPLAINT and PLAINTIFFS' PRELIMINARY
OBJECTION TO DEFENDANT'S PRELIMINARY OBJECTIONS
BEFORE OLER and GUIDO, JJ.
OPINION and ORDER OF COURT
OLER, 1., March 23,2007,
In this negligence action, Plaintiffs James D. Hegarty and Jean Marie
Hegarty, individually, and as the parents of three minor children, Brendan
Hegarty, Hugh Hegarty, and John Hegarty, have sued Defendant Cumberland
Valley School District (hereinafter Defendant or the school district) et al.
Plaintiffs' suit arises from an alleged school bus accident on April 25, 2006.1
The school district has filed preliminary objections in the nature of a
demurrer to Plaintiffs' amended complaint, contending that (1) the school district
is immune from suit based on 42 Pa. C.S. 98541 et seq., which provides immunity
from liability for torts to certain governmental entities and (2) the Plaintiffs
1 Plaintiffs' First Amended Complaint, para. 17, filed November 7,2006 (hereinafter Plaintiffs'
amended complaint).
misapply the vehicle liability exception found at 42 Pa. C.S. 98542(b )(1)?
Plaintiffs III response have filed a preliminary objection to Defendant's
preliminary objections, contending that under Pennsylvania Rule of Civil
Procedure 1030(a) the issue of governmental immunity is to be raised as an
affirmative defense in new matter. 3
These issues were argued on January 24, 2007. For the reasons stated in
this opinion, Defendant's preliminary objections will be denied, Plaintiffs'
preliminary objection will be granted, and Defendant will be afforded 20 days
within which to file a responsive pleading to Plaintiffs' first amended complaint.
STATEMENT OF FACTS
The facts alleged in Plaintiffs' first amended complaint may be summarized
as follows:
Plaintiffs are James D. Hegarty and Jean Marie Hegarty, individually and
as the parents of three minor children, Brendan Hegarty, Hugh Hegarty, and John
Hegarty. 4 One of the Defendants is the Cumberland Valley School District, a
Pennsylvania school district located in Cumberland County. 5
Defendant school district regulated the discipline of students while on
school buses.6 However, it ignored complaints from parents about unruly
behavior of students on a certain school bus, the operation of which subsequently
became a subject of the present case?
2 Defendant's Preliminary Objections against the Plaintiffs' First Amended Complaint, paras. 15,
20, filed November 22,2006 (hereinafter Defendant's preliminary objections).
3 Plaintiffs' Preliminary Objection to Cumberland Valley School District's Preliminary
Objections to First Amended Complaint, filed December 4,2006 (hereinafter Plaintiffs'
preliminary objection).
4 Plaintiffs' First Amended Complaint, para. 1.
5 Plaintiffs' First Amended Complaint, para. 5.
6 Plaintiffs' First Amended Complaint, paras. 6-11.
7 Plaintiffs' First Amended Complaint, para. 25.
2
On April 25, 2006, at approximately 4: 15 p.m., the aforesaid minors were
being transported on this bus from Green Ridge Elementary School to their home.8
The bus was being driven by Chad T. Kovach, an employee of H.E. Rohrer, Inc.,
both named defendants. 9 At this time, the bus was involved in an accident on
Deer Lane in Middlesex Township, Cumberland County,lO when it struck a tree
after a disruptive student had placed his hands over the driver's eyes. 11
As a result of the accident, Plaintiffs' son Brendan suffered a broken
collarbone and lacerations to his head and skull and was evacuated to a hospital by
helicopter. 12 Plaintiffs' sons Hugh and John suffered physical pain and emotional
trauma as a result of witnessing their brother's injuries. 13
DISCUSSION
Pennsylvania Rule of Civil Procedure 1030(a) states:
[A]ll affirmative defenses including but not limited to the defenses of
accord and satisfaction, arbitration and award, consent, discharge in
bankruptcy, duress, estoppel, failure of consideration, fair comment,
fraud, illegality, immunity from suit, impossibility of performance,
justification, laches, license, payment, privilege, release, res judicata,
statute of frauds, statute of limitations, truth and waiver shall be pleaded
in a responsive pleading under the heading "New Matter". A party may
set forth as new matter any other material facts which are not merely
denials of the averments of the preceding pleading. 14
One exception to this rule is that "the affirmative defense of governmental
immunity may be raised by preliminary objections in the nature of a demurrer
where that defense is apparent on the face of the pleading; that is, that a cause of
8 Plaintiffs' First Amended Complaint, paras. 16-17.
9 Plaintiffs' First Amended Complaint, para. 17.
10 Plaintiffs' First Amended Complaint, para. 20.
11 Plaintiffs' First Amended Complaint, paras. 20, 26.
12 Plaintiffs' First Amended Complaint, para. 35.
13 Plaintiffs' First Amended Complaint, para. 36.
14 Pa. RC.P. 1030(a) (emphasis added).
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action is made against a governmental body and it is apparent on the face of the
pleading that the cause of action does not fall within any of the exceptions to
governmental immunity." Wurth v. City of Philadelphia, 136 Pa. Commw. 629,
638, 584 A.2d 403, 407 (1990). Since it is not disputed that the Defendant is a
"governmental body,,,15 it must be determined in the context of the Defendant's
preliminary objections and Plaintiffs' preliminary objection to Defendant's
preliminary objections if it is "apparent" that the Plaintiffs' cause of action does
not fall within any of the exceptions to governmental immunity.
Rule 1028 of the Pennsylvania Rules of Civil Procedure allows for preliminary
objections based on legal insufficiency of a pleading (demurrer). 16 When ruling
on a demurrer to a complaint, the court must determine "whether, on the facts
averred, the law says with certainty that no recovery is possible." Santiago v.
Penna. Nat'l Mutual Casualty Ins. Co., 418 Pa. Super. 178, 184,613 A.2d 1235,
1238 (1992). "Where any doubt exists as to whether a demurrer should be
sustained, it should be resolved in favor of overruling the demurrer." Id
The Political Subdivision Tort Claims Act found at 42 Pa. C.S. 9 8541 et
seq. provides, inter alia, as follows:
Except as otherwise provided in this subchapter, no 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.
An exception to immunity is found at 42 Pa. C.S. 98542(B)(1):
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:
(1) Vehicle liability. -- The operation of any motor vehicle
in the possession or control of the local agency, provided
that the local agency shall not be liable to any plaintiff that
15 Plaintiffs' First Amended Complaint, para. 5.
16 See Pa. RC.P. 1028(a)(4).
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claims liability under this subsection if the plaintiff was,
during the course of the alleged negligence, in flight or
fleeing apprehension or resisting arrest by a police officer or
knowingly aided a group, one or more of whose members
were in flight or fleeing apprehension or resisting arrest by
a police officer. As used in this paragraph, "motor vehicle"
means any vehicle which is self-propelled and any
attachment thereto, including vehicles operated by rail,
through water or in the air.
Exceptions to immunity under the Political Subdivision Tort Claims Act are
to be narrowly construed. 17
Plaintiffs allege that, because Defendant was in "operational control" of the
bus while it transported students, the vehicle liability exception to immunity
applies. 18 Defendant argues that, because its policies did not directly affect the
operation of the vehicle, the exception is not applicable. 19
As a general rule, of course, an agency is not operating a vehicle for
purposes of the exception to immunity when the vehicle is being driven by an
independent contractor. 20 On the other hand, it has been held by the Pennsylvania
Supreme Court that operation of a vehicle for this purpose encompasses
maintenance of the vehicle?1 Depending upon the degree of control maintained
by Defendant over the discipline of students while on school buses, and the unique
circumstances underlying the present alleged failure of operational control of the
bus on which the minor plaintiffs were riding, it is not impossible that the factual
record can be developed to support an argument that the alleged tort in the present
case was encompassed by the vehicle exception to immunity contained in the
17 Mickle v. City of Philadelphia, 550 Pa. 539, 707 A.2d 1124 (1998).
18 See generally, Plaintiffs' First Amended Complaint.
19 See Defendant's preliminary objections, para. 38.
20 O'Brien v. Bennote, 18 Pa. D. & C.4th 523 (Luzeme Co. Ct. of Common Pleas, 1993).
21 Mickle v. City of Philadelphia" 550 Pa. 539, 707 A.2d 1124 (1998).
5
statute. Accordingly, it appears appropriate to defer the immunity issue raised by
Defendant to a later stage of the proceedings.
F or this reason, the following order will be entered:
ORDER OF COURT
AND NOW, this 23rd day of March, 2007, upon consideration of the
Preliminary Objections against the Plaintiffs' First Amended Complaint filed by
Defendant Cumberland Valley School District, and of Plaintiffs' Preliminary
Objection to Cumberland Valley School District's Preliminary Objections to First
Amended Complaint, and for the reasons stated in the accompanying opinion, it is
ordered and directed as follows:
1. The Preliminary Objections against the Plaintiffs' First
Amended Complaint filed by Defendant Cumberland Valley
School District are denied;
2. Plaintiffs' Preliminary Objection to Cumberland
Valley School District's Preliminary Objections to First
Amended Complaint is granted; and
3. Defendant Cumberland Valley School District is
afforded a period of twenty days from the date of this order
within which to file a responsive pleading to Plaintiffs' first
amended complaint.
BY THE COURT,
s/ 1. Wesley Oler, Jr.
1. Wesley Oler, Jr., 1.
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C. Grainger Bowman, Esquire
KIRKPATRICK & LOCKHART
NICHOLSON GRAHAM LLP
17 North Second Street, 18th Floor
Harrisburg, P A 17101
Counsel for Plaintiffs
Charles E. Haddick, Jr., Esquire
Grant W. Schonour, Esquire
DICKIE, McCAMEY & CHILCOTE, P.C.
Suite 205
1200 Camp Hill Bypass
Camp Hill, PA 17011
Counsel for Defendant
Cumberland Valley School District
Stephen E. Geduldig, Esquire
THOMAS, THOMAS, & HAFER, LLP
305 North Front Street
Post Office Box 999
Harrisburg, P A 17108
Counsel for Defendants H.E. Rohrer, Inc.,
and Chad T. Kovach
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8
JAMES D. HEGARTY and
JEAN MARIE HEGARTY,
Individually, and as parents
and natural guardians of
Brendan Hegarty, a minor,
Hugh Hegarty, a minor, and
John Hegarty, a minor,
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
CUMBERLAND V ALLEY
SCHOOL DISTRICT,
H.E. ROHRER, INC.,
CHAD T. KOVACH,
Defendants
NO. 06-5370 CIVIL TERM
IN RE: DEFENDANT CUMBERLAND VALLEY SCHOOL
DISTRICT'S PRELIMINARY OBJECTIONS TO PLAINTIFFS'
FIRST AMENDED COMPLAINT and PLAINTIFFS' PRELIMINARY
OBJECTION TO DEFENDANT'S PRELIMINARY OBJECTIONS
BEFORE OLER and GUIDO, JJ.
ORDER OF COURT
AND NOW, this 23rd day of March, 2007, upon consideration of the
Preliminary Objections against the Plaintiffs' First Amended Complaint filed by
Defendant Cumberland Valley School District, and of Plaintiffs' Preliminary
Objection to Cumberland Valley School District's Preliminary Objections to First
Amended Complaint, and for the reasons stated in the accompanying opinion, it is
ordered and directed as follows:
1. The Preliminary Objections against the Plaintiffs' First
Amended Complaint filed by Defendant Cumberland Valley
School District are denied;
2. Plaintiffs' Preliminary Objection to Cumberland
Valley School District's Preliminary Objections to First
Amended Complaint is granted; and
3. Defendant Cumberland Valley School District is
afforded a period of twenty days from the date of this order
within which to file a responsive pleading to Plaintiffs' first
amended complaint.
BY THE COURT,
1. Wesley Oler, Jr., 1.
C. Grainger Bowman, Esquire
KIRKPATRICK & LOCKHART
NICHOLSON GRAHAM LLP
17 North Second Street, 18th Floor
Harrisburg, P A 17101
Counsel for Plaintiffs
Charles E. Haddick, Jr., Esquire
Grant W. Schonour, Esquire
DICKIE, McCAMEY & CHILCOTE, P.C.
Suite 205
1200 Camp Hill Bypass
Camp Hill, PA 17011
Counsel for Defendant
Cumberland Valley School District
Stephen E. Geduldig, Esquire
THOMAS, THOMAS, & HAFER, LLP
305 North Front Street
Post Office Box 999
Harrisburg, P A 17108
Counsel for Defendants H.E. Rohrer, Inc.,
and Chad T. Kovach