- Superior Court Upholds Summary Judgment for U-Haul in Negligence Action Where U-Haul Was Plaintiff’s Statutory Employer and Where Plaintiff Contractually Waived His Claims Against U-Haul.
- August 7, 2018 | Author: Brook T. Dirlam
- Law Firm: Thomas, Thomas & Hafer LLP - Pittsburgh Office
Plaintiff Matranga, was employed by staffing agency, McGrath Technical Staffing. U-Haul, a client of McGrath, entered into a contract with McGrath that included a waiver, wherein employees would waive their right to pursue claims against U-Haul for workplace injuries. The contract also provided that all workers assigned to U-Haul are employees of McGrath and that such workers are not employees of U-Haul. Matranga suffered a serious injury as a result of a forklift accident while at the U-Haul facility and subsequently brought a negligence action against U-Haul.
U-Haul filed a motion for summary judgment claiming that it was not liable for Matranga’s injuries based on the defenses of, among other things, statutory employer and contractual waiver/release. The Trial Court granted said motion and dismissed Matranga’s complaint, with prejudice.
HoldingThe Superior Court upheld the entry of summary judgment. The Court noted that despite the language of the contract indicating that Matranga was not a employee of U-Haul, the evidence clearly showed he was a statutory employee of U-Haul. Accordingly, Matranga’s exclusive remedy was to seek recovery under the Pennsylvania Workers’ Compensation Act. Further, the Court found that Matranga had contractually waived his claims against U-Haul and that he presented no evidence to nullify his written waiver.