intentional tort exception (Pennsylvania) · Go Syfert
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intentional tort exception in Pennsylvania

18 Pennsylvania opinions name it 6 courts 1982–2023 4 in the last five years

The cases below were cited by Pennsylvania courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (9)

CaseFollowedCited
La Frankie v. Miklichgreen
pacommwct · 1992 · cited in 4 Pennsylvania opinions naming this issue, 2017–2022
2 sentences

2022See Williams v. Stickman, 917 A.2d 915, 917 (Pa. Cmwlth. 2007) (affirming the trial court’s dismissal of an inmate’s intentional tort claim against prison employees, reasoning that where “an employee of a Commonwealth agency [is] acting within the scope of his or her duties, the Commonwealth employee is protected by sovereign immunity from the imposition of liability for intentional tort claims”); La Frankie v. Miklich, . . . 618 A.2d 1145, 1149 ([Pa. Cmwlth.] 1992) (same).

2021See Williams v. Stickman, 917 A.2d 915, 917 (Pa. Cmwlth. 2007) (affirming the trial court’s dismissal of an inmate’s intentional tort claim against prison employees, reasoning that where “an employee of a Commonwealth agency [is] acting within the scope of his or her duties, the Commonwealth employee is protected by sovereign immunity from the imposition of liability for intentional tort claims”); La Frankie v. Miklich, 618 A.2d 1145, 1149 (Pa. Cmwlth.1992) (same).

34
Williams v. Stickmangreen
pacommwct · 2007 · cited in 2 Pennsylvania opinions naming this issue, 2021–2022
2 sentences

2022See Williams v. Stickman, 917 A.2d 915, 917 (Pa. Cmwlth. 2007) (affirming the trial court’s dismissal of an inmate’s intentional tort claim against prison employees, reasoning that where “an employee of a Commonwealth agency [is] acting within the scope of his or her duties, the Commonwealth employee is protected by sovereign immunity from the imposition of liability for intentional tort claims”); La Frankie v. Miklich, . . . 618 A.2d 1145, 1149 ([Pa. Cmwlth.] 1992) (same).

2021See Williams v. Stickman, 917 A.2d 915, 917 (Pa. Cmwlth. 2007) (affirming the trial court’s dismissal of an inmate’s intentional tort claim against prison employees, reasoning that where “an employee of a Commonwealth agency [is] acting within the scope of his or her duties, the Commonwealth employee is protected by sovereign immunity from the imposition of liability for intentional tort claims”); La Frankie v. Miklich, 618 A.2d 1145, 1149 (Pa. Cmwlth.1992) (same).

22
Evans v. Allentown Portland Cement Co.green
pa · 1969 · cited in 2 Pennsylvania opinions naming this issue, 1987–1989
2 sentences

1989See e.g., Evans v. Allentown Portland Cement Co., 433 Pa. 595 , 252 A.2d 646 (1969), (a decedent who was killed as a result of his employer’s alleged willful and unlawful conduct was bound to the provisions of the WCA and was precluded from bringing an action at common law).

1989See e.g., Evans v. Allentown Portland Cement Co., 433 Pa. 595 , 252 A.2d 646 (1969), (a decedent who was killed as a result of his employer’s alleged willful and unlawful conduct was bound to the provisions of the WCA and was precluded from bringing an action at common law).

12
Higgins v. Clearing MacHine Corp.green
pa · 1985 · cited in 2 Pennsylvania opinions naming this issue, 1987–1989
2 sentences

1989Higgins v. Clearing Machine Corporation, 344 Pa. Super. 325, 330 , 496 A.2d 818, 821 (1985).

1989Higgins v. Clearing Machine Corporation, 344 Pa. Super. 325, 330 , 496 A.2d 818, 821 (1985).

12
American & Foreign Insurance v. Jerry's Sport Center, Inc.green
pa · 2010 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023However, if any one claim in the complaint is potentially covered by the policy, the insurer is obligated to provide a defense to the insured in the action, as “it is the potential, rather than the certainty, of a claim falling within the insurance policy that triggers the insurer’s duty to defend.” See id. at 541 (holding that an insurer is obligated to defend its insured if the factual allegations of the complaint on its face encompass an injury that is actually or potentially within the scope of the policy).

11
Barber v. Pittsburgh Corning Corp.green
pa · 1989 · cited in 1 Pennsylvania opinions naming this issue, 1995–1995
2 sentences

1995Id. 521 Pa. 36 , 555 A.2d at 770 (citations omitted).

1995Id. 521 Pa. 36 , 555 A.2d at 770 (citations omitted).

11
Millison v. E.I. Du Pont De Nemours & Co.green
nj · 1985 · cited in 1 Pennsylvania opinions naming this issue, 1987–1987
2 sentences

1987See Millison v. E.I. duPont de Nemours & Co., 101 N.J. 161 , 501 A.2d 505 (1985).

1987See Millison v. E.I. duPont de Nemours & Co., 101 N.J. 161 , 501 A.2d 505 (1985).

11
Koslop v. Cabot Corp.green
pamd · 1985 · cited in 1 Pennsylvania opinions naming this issue, 1987–1987
2 sentences

1987See also Koslop v. Cabot Corp., 622 F.Supp. 222, 224 (M.D.Pa.1985) (“the weight of authority supports the continued recognition of the intentional tort exception [to the “exclusivity” provision of the Act].”).

1987See also Koslop v. Cabot Corp., 622 F.Supp. 222, 224 (M.D.Pa.1985) ("the weight of authority supports the continued recognition of the intentional tort exception [to the "exclusivity" provision of the Act].").

11
Boris v. Liberty Mutual Insurancegreen
pa · 1986 · cited in 1 Pennsylvania opinions naming this issue, 1987–1987
2 sentences

1987Even more recently, this court explicitly stated: "[A]n action can lie against the employer itself if it harmed its employee through an intentional wrongful act.” Boris v. Liberty Mutual Insurance Company, 356 Pa.Super. 532, 539 , 515 A.2d 21, 24-25 (1985).

1987Even more recently, this court explicitly stated: "[A]n action can lie against the employer itself if it harmed its employee through an intentional wrongful act.” Boris v. Liberty Mutual Insurance Company, 356 Pa.Super. 532, 539 , 515 A.2d 21, 24-25 (1985).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway.

Also cited on this issue (13)

CaseCitedYears
Readinger v. Gottschall green
pasuperct · 1963
2 sentences

1989Readinger v. Gottschall, 201 Pa.Super. 134 , 191 A.2d 694 (1963).

1989Readinger v. Gottschall, 201 Pa.Super. 134 , 191 A.2d 694 (1963).

31982–1989
Brooks v. Marriott Corp. green
pa · 1987
2 sentences

1991The Defendants also argue, in support of their preliminary objections, that Brown might have attacked a different person, regardless of who it was, in Sabot’s position, and therefore the attack falls outside the intentional tort exception to the Workmen’s Compensation Act. 77 P.S. § 411(1); Dolan v. Linton’s Lunch, 397 Pa. 114 , 152 A.2d 887 (1959); Workmen’s Compensation Appeal Board v. Plum, 20 Pa.Commonwealth Ct. 35, 340 A.2d 637 (1975); Brooks v. Marriott Corporation, 361 Pa. Superior Ct. 350 , 522 A.2d 618 (1987); Mike v. Borough of Aliquippa.

1991The Defendants also argue, in support of their preliminary objections, that Brown might have attacked a different person, regardless of who it was, in Sabot’s position, and therefore the attack falls outside the intentional tort exception to the Workmen’s Compensation Act. 77 P.S. § 411(1); Dolan v. Linton’s Lunch, 397 Pa. 114 , 152 A.2d 887 (1959); Workmen’s Compensation Appeal Board v. Plum, 20 Pa.Commonwealth Ct. 35, 340 A.2d 637 (1975); Brooks v. Marriott Corporation, 361 Pa. Superior Ct. 350 , 522 A.2d 618 (1987); Mike v. Borough of Aliquippa.

21988–1991
Jones v. P.M.A. Insurance green
pa · 1985
2 sentences

1987Union Carbide in its answer to automation’s motion for judgment on the pleadings cites Jones v. PMA Insurance Company, 343 Pa. Super. 411 , 495 A.2d 203 (1985), as standing for an acknowledgment by the Superior Court of the continued validity of the holding in Readinger, supra. However, in a subsequent opinion, Higgins v. Cleaning Machine Corporation, 344 Pa. Super. 325 , 331 n.5, 496 A.2d 818 , 821 n.5 (1985), the court held that the issue was still unsettled.

1987Union Carbide in its answer to automation’s motion for judgment on the pleadings cites Jones v. PMA Insurance Company, 343 Pa. Super. 411 , 495 A.2d 203 (1985), as standing for an acknowledgment by the Superior Court of the continued validity of the holding in Readinger, supra. However, in a subsequent opinion, Higgins v. Cleaning Machine Corporation, 344 Pa. Super. 325 , 331 n.5, 496 A.2d 818 , 821 n.5 (1985), the court held that the issue was still unsettled.

21987–1987
Neitzke v. Williams red
scotus · 1989
1 sentence

2021(Id.) Thus, the trial court found that White’s Complaint “‘lacks an arguable basis either in law or in fact’ and is therefore [] frivolous.” (Id. (quoting Neitzke v. Williams, 490 U.S. 319 (1989)).) On August 19, 2019, White appealed the July 2019 Order to this Court.1 1 “Our scope of review is limited to determining whether constitutional rights have been violated, whether the trial court abused its discretion, or whether the trial court committed an error of law.” Lichtman v. Glazer, 111 A.3d 1225 , 1227 n.4 (Pa. Cmwlth. 2015). 3 By order dated September 4, 2019 (September 2019 Order), the t

12021–2021
Lichtman v. Glazer green
pacommwct · 2015
1 sentence

2021(Id.) Thus, the trial court found that White’s Complaint “‘lacks an arguable basis either in law or in fact’ and is therefore [] frivolous.” (Id. (quoting Neitzke v. Williams, 490 U.S. 319 (1989)).) On August 19, 2019, White appealed the July 2019 Order to this Court.1 1 “Our scope of review is limited to determining whether constitutional rights have been violated, whether the trial court abused its discretion, or whether the trial court committed an error of law.” Lichtman v. Glazer, 111 A.3d 1225 , 1227 n.4 (Pa. Cmwlth. 2015). 3 By order dated September 4, 2019 (September 2019 Order), the t

12021–2021
Flowers v. Philadelphia Parking Authority green
pa · 2012
1 sentence

2017We held that “when an employee of a Commonwealth agency was acting within the scope of his or her duties, the Commonwealth employee is protected by sovereign immunity from the imposition of liability for intentional tort claims.” Id. at 917 (quoting La Frankie, 618 A.2d at 1149 ).

12017–2017
Kuney v. PMA Insurance green
pa · 1990
2 sentences

1992As our supreme court has recently held, “When the allegations of a claim have as their ultimate basis an injury compensable *637 under the Workman’s Compensation Act, the claim must be considered within the framework of the statute.” Kuney, supra 525 Pa. at 176 , 578 A.2d at 1287 .

1992As our supreme court has recently held, “When the allegations of a claim have as their ultimate basis an injury compensable *637 under the Workman’s Compensation Act, the claim must be considered within the framework of the statute.” Kuney, supra 525 Pa. at 176 , 578 A.2d at 1287 .

11992–1992
Vosburg v. Connolly green
pasuperct · 1991
1 sentence

1992However, as the court in Vosburg, supra, aptly points out, a blanket statement denying the existence of an intentional tort exception the Act is not finally dispositive, since in claims such as appellant’s the pertinent inquiry is whether the assault or attack which is the intentional injury arose out of “personal or business related animosity.” Id. 405 Pa.Super. at 127 n. 3, 591 A.2d at 1131 n. 3.

11992–1992
Workmen's Compensation Appeal Board v. Borough of Plum & Bituminous Casualty Corp. green
pacommwct · 1975
2 sentences

1991The Defendants also argue, in support of their preliminary objections, that Brown might have attacked a different person, regardless of who it was, in Sabot’s position, and therefore the attack falls outside the intentional tort exception to the Workmen’s Compensation Act. 77 P.S. § 411(1); Dolan v. Linton’s Lunch, 397 Pa. 114 , 152 A.2d 887 (1959); Workmen’s Compensation Appeal Board v. Plum, 20 Pa.Commonwealth Ct. 35, 340 A.2d 637 (1975); Brooks v. Marriott Corporation, 361 Pa. Superior Ct. 350 , 522 A.2d 618 (1987); Mike v. Borough of Aliquippa.

1991The Defendants also argue, in support of their preliminary objections, that Brown might have attacked a different person, regardless of who it was, in Sabot's position, and therefore the attack falls outside the intentional tort exception to the Workmen's Compensation Act. 77 P.S. § 411(1); Dolan v. Linton's Lunch, 397 Pa. 114 , 152 A.2d 887 (1959); Workmen's Compensation Appeal Board v. Plum, 20 Pa. Commonwealth Ct. 35 , 340 A.2d 637 (1975); Brooks v. Marriott Corporation, 361 Pa. Superior Ct. 350 , 522 A.2d 618 (1987); Mike v. Borough of Aliquippa . *507 In Holland , we followed the Superior

11991–1991
Dolan v. Linton's Lunch green
pa · 1959
2 sentences

1991The Defendants also argue, in support of their preliminary objections, that Brown might have attacked a different person, regardless of who it was, in Sabot’s position, and therefore the attack falls outside the intentional tort exception to the Workmen’s Compensation Act. 77 P.S. § 411(1); Dolan v. Linton’s Lunch, 397 Pa. 114 , 152 A.2d 887 (1959); Workmen’s Compensation Appeal Board v. Plum, 20 Pa.Commonwealth Ct. 35, 340 A.2d 637 (1975); Brooks v. Marriott Corporation, 361 Pa. Superior Ct. 350 , 522 A.2d 618 (1987); Mike v. Borough of Aliquippa.

1991The Defendants also argue, in support of their preliminary objections, that Brown might have attacked a different person, regardless of who it was, in Sabot’s position, and therefore the attack falls outside the intentional tort exception to the Workmen’s Compensation Act. 77 P.S. § 411(1); Dolan v. Linton’s Lunch, 397 Pa. 114 , 152 A.2d 887 (1959); Workmen’s Compensation Appeal Board v. Plum, 20 Pa.Commonwealth Ct. 35, 340 A.2d 637 (1975); Brooks v. Marriott Corporation, 361 Pa. Superior Ct. 350 , 522 A.2d 618 (1987); Mike v. Borough of Aliquippa.

11991–1991
Callender v. Goodyear Tire & Rubber Co. green
pa · 1989
2 sentences

1990Defendant Pfister cites Callender, Administratix of the Estate of Gary Callender v. Goodyear Tire and Rubber Company, 387 Pa. Super. 283 , 564 A.2d 180 (1989), rearg’t denied September 25, 1989.

1990Defendant Pfister cites Callender, Administratix of the Estate of Gary Callender v. Goodyear Tire and Rubber Company, 387 Pa. Super. 283 , 564 A.2d 180 (1989), rearg’t denied September 25, 1989.

11990–1990
Poyser v. Newman & Co., Inc. green
pa · 1987
2 sentences

1988The Pennsylvania Supreme Court in Poyser v. Newman, 514 Pa. 32 , 522 A. 2d 548 (1987) refused to allow the intentional tort exception to section 481(a) when an employer allegedly disregarded governmental safety regulations and forbade workers using a machine safety device.

1988The Pennsylvania Supreme Court in Poyser v. Newman, 514 Pa. 32 , 522 A. 2d 548 (1987) refused to allow the intentional tort exception to section 481(a) when an employer allegedly disregarded governmental safety regulations and forbade workers using a machine safety device.

11988–1988
McGinn v. Valloti green
pa · 1987
2 sentences

1988Readinger v. Gottshall, 201 Pa. Super. 134 , 191 A.2d 694 (1963); McGinn v. Valloti, 363 Pa. Super. 88 , 525 A.2d 732 (1987); Jones v. PMA Ins.

1988Readinger v. Gottshall, 201 Pa. Super. 134 , 191 A.2d 694 (1963); McGinn v. Valloti, 363 Pa. Super. 88 , 525 A.2d 732 (1987); Jones v. PMA Ins.

11988–1988

Statutes the citing opinions construe

PA § 42 Pa. Cons. Stat. § 8522 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

OH 137 (1986–2025) TX 79 (1984–2025) MI 65 (1984–2026) FL 53 (1967–2024) LA 31 (1986–2026) CT 20 (1994–2026) PA 18 (1982–2023) CA 14 (1983–2021) MS 14 (1994–2026) NY 13 (1983–2024) NE 13 (1989–2024) NC 11 (1990–2024) TN 10 (1996–2020) SD 9 (1991–2022) IA 8 (2011–2025) IL 7 (1984–2022) MA 7 (1987–2025) MN 7 (1984–2019) NJ 7 (1988–2026) IN 7 (1992–2004) WA 6 (1998–2018) AZ 5 (1994–2024) OK 4 (2005–2023) AR 4 (1998–2025) DC 4 (1988–2007) CO 4 (1985–2003) AL 4 (2001–2026) GA 3 (1998–2008) HI 3 (2002–2014) MT 2 (1997–2017) DE 2 (2019–2023) NV 2 (2014–2014) UT 2 (2015–2024) KY 2 (2026–2026) VA 2 (1989–1990) OR 2 (1994–2016) ID 2 (1986–1997) ND 2 (1997–1997) RI 2 (1989–1997) MO 2 (1994–2009) NM 2 (2010–2017) VT 2 (2004–2018) WY 2 (2010–2022) WI 2 (1997–2024) KS 2 (2012–2022)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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