Pennsylvania Court Holds Maryland Has Significant Interest in Litigating Personal Injury Lawsuit Involving Maryland Business
The Pennsylvania Superior Court recently determined a case involving a choice of law between Pennsylvania and Maryland in a personal injury lawsuit. Significantly, in this case, the issue of which state law applied significantly affected the outcome of the case. While the accident at issue took place in Maryland, the injured victim was a resident of Pennsylvania. Maryland has a contributory negligence statute, while Pennsylvania has a comparative negligence statute. Since the plaintiff in this case was deemed partially responsible for his injuries, he would be barred from recovering compensation under Maryland law.
Darrell Marks worked as a deliveryman for King’s Quality Foods, delivering items to grocery stores, including Redner’s Warehouse Market in Elkton, Maryland. Mr. Marks was a resident of Pennsylvania. On August 20, 2012, while pulling a hand truck containing products into the store, he tripped on the forks of a pallet jack inside the door threshold and fell, injuring his knee.
Mr. Marks and his wife filed a complaint in Lackawanna County, Pennsylvania, asserting negligence and loss of consortium claims. Redner’s moved for summary judgment on the basis that the trial court must apply Maryland law. Under Maryland law, the Markses were barred from recovery because Mr. Marks was contributorily negligent in bringing about his injury. The trial court granted Redner’s motion for summary judgment, and the Markses appealed.
The appellate court stated that when determining which substantive law applies, the conflict-of-law principles set forth in the Pennsylvania Supreme Court case of Griffith v. United Air Lines, Inc. apply. The methodology combines the government interest analysis with the significant relationship approach of sections of the Restatement of Conflicts. The court is to apply an analysis of the policies and interests underlying the issue. Factors to be considered include where the injury occurred, the residence and place of business of the parties, and the place of relationship between the parties.
In personal injury cases, there is a presumption that favors the application of the law of the state where the injury occurred, unless another state has a more significant relationship to the occurrence and the parties. The court stated that here, the choice of law may determine the outcome of the case. Pennsylvania has a comparative negligence statute that allows plaintiffs the right to partial recovery when they are 50% or less negligent. Maryland uses contributory negligence, protecting defendants from tort claims if the plaintiff is found negligent at all. This is a true conflict between the laws of Maryland and Pennsylvania.
Turning to which state has a priority of interest in the application of their rule of law, the court stated all parties have close ties to Pennsylvania. Mr. and Mrs. Marks are Pennsylvania residents, and Kin’s Quality Goods as well as Redner’s are Pennsylvania corporations. The accident took place in Maryland, at one of four stores that Redner’s operates in that state. Maryland has a connection with the place of the injury and the occurrence itself. Additionally, Maryland has an interest in regulating the conduct of businesses operating inside its borders.
The court stated that Redner’s decision to conduct business in Maryland may be influenced by the state’s contributory negligence defense. The state has an interest in limiting Redner’s liability, since it wants to protect the state’s business climate. The allegations of wrongdoing here implicated Redner’s employees, at a facility located in Maryland and operated under Maryland law. The appellate court found the trial court appropriately found Maryland law applied in this case.
The Markses also alleged that the trial court erred when it granted summary judgment based on the conclusion that a jury could not find Redner’s 100% responsible for Mr. Marks’ injuries. The Markses contended that Maryland case law requires a jury to determine whether Mr. Marks was contributorily negligent.
Under Maryland law, if a plaintiff is found negligent, they are barred from recovery against a negligent defendant. In this case, the trial court concluded Mr. Marks was responsible for contributory negligence. The appellate court examined the facts presented before the trial court and found that the trial court erred and abused its discretion by granting the motion for summary judgment. The appellate court stated the trial court failed to view the facts in the light most favorable to Mr. Marks. He followed protocols and had not seen the forks of the pallet jack before tripping. The appellate court stated Mr. Marks was not contributorily negligent as a matter of law when he tripped and fell.
The court affirmed in part and reversed in part, remanding the case to the lower court.
At Needle Law, P.C., our personal injury attorneys can help you or your loved ones secure compensation following a collision or other accident. For a free, confidential consultation, contact our office at (570) 344-1266.