Court Confirms that Wrongful Death Claims are Derivative to Underlying Liability Claims

 In the case of Byers v. Finishing Systems, Inc., No. 1:20-CV-02110 (M.D. Pa. March 31, 2025 Wilson, J.), the court granted summary judgment in a wrongful death case arising out of a products liability claim.

According to this Opinion, the Court had previously granted summary judgment to the Defendants on certain claims but did not grant summary judgment on the Plaintiff's Wrongful Death claims because the Defendant had not ask for it in the motion.

In this decision, the Court treated the more recent filings presented by the defense as adding a request for summary judgment on the Plaintiff's Wrongful Death claims.

The court noted that, where all substantive negligence claims had been dismissed in a given matter, the Plaintiff’s wrongful death claim also necessarily failed as matter of law.  The court affirmed that wrongful death claims are derivative of other substantive causes of action.  

Anyone wishing to review a copy of this decision may click this LINK.

I send thanks to Attorney James M. Beck of the Philadelphia office of the Reed Smith law firm for bringing this case to my attention.