The Honorable Thomas I. Vanaskie is set to be sworn in as a United States Third Circuit Court of Appeals Judge on Monday, May 10, 2010 at 12:30 p.m. in Courtroom No. 4 of the William J. Nealon Federal Building & U.S. Courthouse in Scranton, Pennsylvania.
There will be Reception to follow in Second Floor Atrium sponsored by the Lackawanna Bar Association. This event is free and open to the members of the Lackawanna Bar Association.
However, registration is required to attend. Please RSVP to Diane McClosky at 207-5606 by Thursday, May 6, 2010. Lackawanna Bar Association members who plan to attend are cautioned to arrive by 12:00 p.m. to clear security.
Tuesday, May 4, 2010
Lackawanna County Bar Association To Host Third Annual Interfaith Prayer Service
The Lackawanna Bar Association will be hosting the Third Annual Interfaith Prayer Service set to take place on Friday, May 14, 2010 at noon in Shopland Hall in the Scranton Cultural Center.
There will be a keynote address by Judge John E. Jones III of the U.S. District Court of the Middle District of Pennsylvania. In addition, there will be prayers and readings presented by members of the Lackawanna Bar Association along with participation by leaders of various faiths.
The event will be followed by a light lunch. Note also that Lackawanna Bar Association members who attend the event will be entitled to one (1) free ethics hour CLE credit.
RSVP to Karlina at the Bar Association at (570) 969-9161 or kzikor@the-lba.com by Tuesday, May 11, 2010.
There will be a keynote address by Judge John E. Jones III of the U.S. District Court of the Middle District of Pennsylvania. In addition, there will be prayers and readings presented by members of the Lackawanna Bar Association along with participation by leaders of various faiths.
The event will be followed by a light lunch. Note also that Lackawanna Bar Association members who attend the event will be entitled to one (1) free ethics hour CLE credit.
RSVP to Karlina at the Bar Association at (570) 969-9161 or kzikor@the-lba.com by Tuesday, May 11, 2010.
ONE YEAR ANNIVERSARY OF THE START OF TORT TALK
Tort Talk is a year old today!! It was a year ago today that I sat down to write the first post to this blog. The number of email subscribers to the blog started out as a handful and now stands at close to 300 subscribers, a number which does not include those who have marked down the blog as one of their "favorites."
In that first post, I noted that the "purpose" of Tort Talk would be to highlight trends and note important decisions in Pennsylvania civil litigation law. I also noted an intention to periodically attempt to offer practice tips. Last but not least, through this blog I hoped to "also be able to bring to the attention of others little heard developments or verdicts occurring in the courts in the counties that make up Northeastern Pennsylvania" or elsewhere in Pennsylvania.
My hope was, and continues to be, that you will find this blog not only informative but entertaining at times and worthy of returning to on occasion for civil litigation updates.
I send my great thanks to all who have enjoyed Tort Talk and who have spread the word on the blog. As an expression of my gratitude, I hope to continue to bring you civil litigation updates in a clean, tight, and, at times, a hopefully entertaining manner.
In that first post, I noted that the "purpose" of Tort Talk would be to highlight trends and note important decisions in Pennsylvania civil litigation law. I also noted an intention to periodically attempt to offer practice tips. Last but not least, through this blog I hoped to "also be able to bring to the attention of others little heard developments or verdicts occurring in the courts in the counties that make up Northeastern Pennsylvania" or elsewhere in Pennsylvania.
My hope was, and continues to be, that you will find this blog not only informative but entertaining at times and worthy of returning to on occasion for civil litigation updates.
I send my great thanks to all who have enjoyed Tort Talk and who have spread the word on the blog. As an expression of my gratitude, I hope to continue to bring you civil litigation updates in a clean, tight, and, at times, a hopefully entertaining manner.
Monday, May 3, 2010
Pennsylvania Superior Court Holds That Excess/Umbrella Policies Are To Be Included in Calculating Credit Due In UIM Cases
In a monumental Opinion handed down on April 30, 2010, the Pennsylvania Superior Court ruled in D'Adamo v. Erie Insurance Exchange, 2010 PA.Super. 77 (Pa.Super. 2010 Gantman, J.), that both a tortfeasor's automobile insurance liability coverage as well as his separate personal umbrella policy should be considered in determining the credit due to an underinsured motorist benefits (UIM) carrier in a UIM claim.
In D'Adamo, a consolidated case involving two injured husband and wife couples who were in the same vehicle at the time of the accident, the UIM Arbitration panel determined that each of the couples was entitled to a gross award of $850,000.00 per couple.
At issue before the court was the denial by Judge Robert A. Mazzoni of the Lackawanna County Court of Common Pleas of the injured parties' motion to vacate/modify the arbitration award to disallow the credit in the amount of the umbrella policy limits. The injured parties attempted to argue that the offset or credit due to the UIM carrier should not include the tortfeasor's coverage from non-automobile insurance policies such as the umbrella policy owned by the tortfeasor.
According to the Opinion, the applicable Erie policy had an exhaustion clause that provided, in pertinent part: as follows:
"When the accident involves underinsured motor vehicles, we will not pay until all other forms of insurance under all bodily injury liability bonds and insurance policies and self-insurance plans applicable at the time of the accident have been exhausted by payment of their limits or have been resolved by settlement or by final resolution of the court."
The Pennsylvania Superior Court rejected the arguments by the injured parties that (1) the Erie insurance exhaustion clause was ambiguous when compared to the mandates of Pennsylvania's Motor Vehicle Financial Responsibility Law, and (2) the argument that including umbrella policies as part of the exhaustion clause would violate the public policy of Pennsylvania in this context.
In D'Adamo, each couple had already received the $250,000.00 limits under the tortfeasor's automobile policy and $500,000.00 in limits from the tortfeasor's personal umbrella policy, i.e. a total of $750,000.00 in available limits for the tortfeasor.
The Superior Court therefore ruled that, pursuant to the exhaustion clause, the arbitration panel was correct in applying a $750,000.00 credit to the $850,000.00 gross award. As such, the trial court's denial of the motion to vacate/modify the arbitration award was affirmed.
Anyone desiring a copy of the decision may contact me at dancummins@comcast.net. Thanks to Attorney Tom McDonnell of the Pittsburgh law firm of Summers, McDonnell, Hudock, Guthrie & Skeel, P.C. for bringing this case to my attention.
In D'Adamo, a consolidated case involving two injured husband and wife couples who were in the same vehicle at the time of the accident, the UIM Arbitration panel determined that each of the couples was entitled to a gross award of $850,000.00 per couple.
At issue before the court was the denial by Judge Robert A. Mazzoni of the Lackawanna County Court of Common Pleas of the injured parties' motion to vacate/modify the arbitration award to disallow the credit in the amount of the umbrella policy limits. The injured parties attempted to argue that the offset or credit due to the UIM carrier should not include the tortfeasor's coverage from non-automobile insurance policies such as the umbrella policy owned by the tortfeasor.
According to the Opinion, the applicable Erie policy had an exhaustion clause that provided, in pertinent part: as follows:
"When the accident involves underinsured motor vehicles, we will not pay until all other forms of insurance under all bodily injury liability bonds and insurance policies and self-insurance plans applicable at the time of the accident have been exhausted by payment of their limits or have been resolved by settlement or by final resolution of the court."
The Pennsylvania Superior Court rejected the arguments by the injured parties that (1) the Erie insurance exhaustion clause was ambiguous when compared to the mandates of Pennsylvania's Motor Vehicle Financial Responsibility Law, and (2) the argument that including umbrella policies as part of the exhaustion clause would violate the public policy of Pennsylvania in this context.
In D'Adamo, each couple had already received the $250,000.00 limits under the tortfeasor's automobile policy and $500,000.00 in limits from the tortfeasor's personal umbrella policy, i.e. a total of $750,000.00 in available limits for the tortfeasor.
The Superior Court therefore ruled that, pursuant to the exhaustion clause, the arbitration panel was correct in applying a $750,000.00 credit to the $850,000.00 gross award. As such, the trial court's denial of the motion to vacate/modify the arbitration award was affirmed.
Anyone desiring a copy of the decision may contact me at dancummins@comcast.net. Thanks to Attorney Tom McDonnell of the Pittsburgh law firm of Summers, McDonnell, Hudock, Guthrie & Skeel, P.C. for bringing this case to my attention.
Continuing Decline in Medical Malpractice Suits In Pennsylvania
According to an April 27, 2010 article in the Pennsylvania Law Weekly, medical malpractice case filings and verdicts in 2009 revealed a drop in the number of suits filed against health care providers in Pennsylvania. The numbers, secured from the Pennsylvania Supreme Court, dropped for the fifth straight year.
More specifically, the article noted that there were 1,533 such filings in 2009, which was a 43.9 percent decline from the base years used of 2002-2003.
Some have attributed the decline in the number of cases to the rule requiring plaintiff's to produce a certificate of merit regarding the case before being allowed to pursue the case. Another factor cited was the efforts by the courts to prevent forum shopping by plaintiffs.
More specifically, the article noted that there were 1,533 such filings in 2009, which was a 43.9 percent decline from the base years used of 2002-2003.
Some have attributed the decline in the number of cases to the rule requiring plaintiff's to produce a certificate of merit regarding the case before being allowed to pursue the case. Another factor cited was the efforts by the courts to prevent forum shopping by plaintiffs.
Federal Middle District Court Judge Caputo Reviews Value of Emotional Distress Claims
In the recent case of Dee v. Borough of Dunmore, Slip Copy, 2010 WL 1626908 (M.D.Pa. April 21, 2010 Caputo, J.), U.S. Federal District Court Judge A. Richard Caputo of the Middle District of Pennsylvania granted a defendant's motion to reduce a plaintiff's emotional damages award and found that the plaintiff, who had no "long-lasting effects" from a brief period of emotional trauma is not entitled to anything more than $50,000 in compensation for that injury.
The case stemmed from a suit by a plaintiff who alleged that he was improperly suspended without any hearing from his post as an assistant fire chief when borough officials allegedly incorrectly concluded that the plaintiff lacked the necessary qualifications for the position.
Judge Caputo noted that the evidence showed that the plaintiff suffered emotional distress and an elevated blood pressure "for at least a few days" following the suspension.
The judge reviewed other similar emotional distress cases and noted that, where there is some emotional distress without lasting effects established in the case, the average award allowed by the courts was approximately in the range of $50,000.
Turning back to the facts of the Dee case, Judge Caputo found that the jury's award of $150,000 was "shocking to the judicial conscience," particularly where there was no evidence that the plaintiff changed in any lasting way, where it was confirmed that the plaintiff's blood pressure returned to a normal range within a few days, and where the plaintiff was allowed to continue with his employment with the fire department after only nine (9) days on suspension.
In addition to the Westlaw citation above, a copy of this case can be secured, for a small fee, by contacting the Pennsylvania Law Weekly's Instant Case Service at 1-800-276-7427 and giving them the PICS Case No. 10-1762.
The case stemmed from a suit by a plaintiff who alleged that he was improperly suspended without any hearing from his post as an assistant fire chief when borough officials allegedly incorrectly concluded that the plaintiff lacked the necessary qualifications for the position.
Judge Caputo noted that the evidence showed that the plaintiff suffered emotional distress and an elevated blood pressure "for at least a few days" following the suspension.
The judge reviewed other similar emotional distress cases and noted that, where there is some emotional distress without lasting effects established in the case, the average award allowed by the courts was approximately in the range of $50,000.
Turning back to the facts of the Dee case, Judge Caputo found that the jury's award of $150,000 was "shocking to the judicial conscience," particularly where there was no evidence that the plaintiff changed in any lasting way, where it was confirmed that the plaintiff's blood pressure returned to a normal range within a few days, and where the plaintiff was allowed to continue with his employment with the fire department after only nine (9) days on suspension.
In addition to the Westlaw citation above, a copy of this case can be secured, for a small fee, by contacting the Pennsylvania Law Weekly's Instant Case Service at 1-800-276-7427 and giving them the PICS Case No. 10-1762.
Sunday, May 2, 2010
A Clarifying Opinion Out of Venango County on Inter-Policy Stacking in UIM Cases
Judge Robert L. Boyer of the Venango County Court of Common Pleas recently issued an April 24, 2010 Opinion and Order in the case of Heller v. State Farm, No. 408-2008 (Venango Co. 2010 Boyer, J.) that serves to clarify certain issues involving inter-policy stacking in UIM cases. The decision also provides an excellent explanation the interplay of the Pennsylvania Supreme Court's decisions on the issue in the Craley and Generette decisions, a topic that still hurts when I try to wrap my head around it.
As explained by Judge Boyer, intra-policy stacking involves one automobile insurance policy that covers multiple vehicles. An insured can pay a higher premium to purchase the stacking option, which enables the insured to increase the amount of coverage that he or she can receive in the event of an accident by totaling the UIM coverage for each vehicle on the policy.
For example, in the Heller case, the injured party had a stacked policy with Erie on three vehicles. The policy provided for $15,000 in UIM coverage. Since there were three vehicles under this one policy and since stacking was purchased, the injured party had $45,000 in UIM benefits potentially recoverable in the event of an accident.
The Heller court noted that, in Craley v. State Farm, 895 A.2d 530 (Pa. 2006), the Pennsylvania Supreme Court recognized another form of stacking which came to be known as inter-policy stacking. Inter-policy stacking occurs when a single insurance company has issued multiple policies covering separate vehicles in a household.
To illustrate, Craley involved a claimant who was killed in an auto accident. The Claimant's husband attempted to recover both under a State Farm policy that had been issued to the deceased claimant on one vehicle in the household as well as under a separate policy that had been issued by State Farm to the husband on his separate vehicle.
The decision in Craley had to do with the fact that both of the State Farm policies included a waiver of the stacking option executed by the insureds. In addition to recognizing the concept of inter-policy stacking, the Craley court also held that the waiver of stacking was valid in both intra-policy and inter-policy situations. It was therefore determined in Craley that, since stacked coverage was waived, a UIM recovery was only available under the decedent's insurance policy and not the husband's separate policy with the same carrier.
In the Heller case before Judge Boyer, the injured party had a State Farm policy that provided for non-stacked UIM coverage of $100,000. The Plaintiff also had a separate policy with Erie Insurance covering three vehicles with stacking UIM coverage of $15,000, i.e. a total of $45,000 in benefits available.
Erie tendered its $45,000 in UIM benefits to the injured party. State Farm then attempted to limit its exposure pursuant to its "Other Insurance" clause, which provided that, where the injured party had UIM coverage available from more than one policy, regardless of whether the other policies were provided by State Farm or another carrier, the injured party would be limited to the amount of the highest UIM policy limit among all of the available insurance policies.
Since the highest UIM policy limit at issue in Heller was the $100,000 limits in the State Farm policy, State Farm believed that, pursuant to its "Other Insurance" clause, it was correct in only having to pay another $55,000 above the $45,000 paid by Erie (i.e. $45K + $55K = the $100K highest policy limit).
Judge Boyer agreed with State Farm in Heller and, in doing so distinguished the plaintiff's strong reliance upon the case of Generette v. Donegal, 957 A.2d 1180 (Pa. 2008).
In Generette, the claimant was injured while riding as a guest passenger in a vehicle. The injured party recovered under the liability policy that covered the tortfeasor's policy and also obtained a tendering of the Nationwide $50,000 UIM policy limits covering the vehicle in which she was located at the time of the accident.
The injured party in Generette then turned to Donegal Insurance to recover the additionally available $35,000 in UIM limits she had purchased for herself on her own separate personal vehicle. The facts of that case confirmed that the injured party had waived the stacking option under her own policy.
Like the State Farm policy in Heller, the Donegal Insurance Company policy in Generette contained an "Other Insurance" clause, which implemented the waiver of stacked UIM benefits. In Generette, Donegal Insurance refused to pay any benefits under this clause, which like the clause in the State Farm policy in Craley, provided that the UIM carrier's maximum exposure across multiple, applicable insurance policies was the highest policy limit stated in any of the policies.
Since the Nationwide Insurance policy had the highest available limits of $50,000 and since those limits were already paid by Nationwide, Donegal refused to pay any of its lesser amount of $35,000 in available UIM benefits under an application of the "Other Insurance" clause.
In Generette, the Pennsylvania Supreme Court rejected Donegal Insurance's position as being in violation with the public policy of Pennsylvania. First, after a lengthy discussion of the procedural history and statutory definitions, the Generette court rejected Donegal's argument that the injured party was unable to recover on the basis that she had rejected stacking. The Court in Generette determined that Section 1738 of the Motor Vehicle Responsibility Law (MVFRL), which only expressly allows an "insured" to waive stacking, did not apply in this case because guest passengers were not "insureds" as that term is defined in the MVFRL.
After ruling that the injured party was not barred from recovering by her waiver of the stacking option, the Generette Court then turned to the question of whether Donegal's "Other Insurance" clause served to preclude a recovery.
The Court in Generette found that the "Other Insurance" clause, in this context, violated the public policy mandating that UIM coverage be excess coverage rather than gap coverage. In other words, an application of the "Other Insurance" clause in this scenario would have prevented the injured party from securing the very excess insurance coverage she had paid premiums for in the event that she was injured by a tortfeasor with inadequate insurance coverage.
As such, the Supreme Court found that, in the context of Generette, the "Other Insurance" clause violated public policy and could not be utilized by Donegal Insurance to limit the injured party's recovery.
Turning back to the case before him, Judge Boyer noted that, while the facts presented in the Heller case were similar to those in the Generette case, the simiarities did not reach the level to where Generette had to be followed as binding precedent.
Most importantly, Judge Boyer noted that, whereas in Generette the Court held that the waiver of stacking was not valid in the case of a guest passenger who did not meet the definition of an "insured," in Heller the injured party was identified by name on the subject policy and, therefore, was an "insured" under the MVFRL who could validly waive stacking.
The Heller court went on rationalize that the valid waiver of coverage was the key distinction from the Generette case. Judge Boyer ruled that, to then find State Farm's "Other Insurance" clause to be a violation against public policy in spite of a valid waiver of stacking, would require him to rewrite the MVFRL, an option he refused to undertake.
Judge Boyer concluded his Opinion by noting that, in passing the MVFRL, the Pennsylvania Legislature attempted to contain the spiraling costs of automobile insurance by adopting provisions such as the waiver of stacking statute. The Heller court ruled that, by waiving stacking, the injured party paid a lower premium to receive a maximum of $100,000 in UIM coverage under the application of the "Other Insurance" coverage. Accordingly, the court held that State Farm acted properly in only paying $55,000 out of its available $100,000 in UIM policy limits under the facts presented.
Anyone desiring a copy of this trial court opinion out of Venango County may contact me at dancummins@comcast.net.
I thank the prevailing defense attorney in the Heller case, Attorney Tom McDonnell of the Pittsburgh law firm of Summers, McDonnell, Hudock, Guthrie & Skeel, P.C. for bringing this enlightening case to my attention.
As explained by Judge Boyer, intra-policy stacking involves one automobile insurance policy that covers multiple vehicles. An insured can pay a higher premium to purchase the stacking option, which enables the insured to increase the amount of coverage that he or she can receive in the event of an accident by totaling the UIM coverage for each vehicle on the policy.
For example, in the Heller case, the injured party had a stacked policy with Erie on three vehicles. The policy provided for $15,000 in UIM coverage. Since there were three vehicles under this one policy and since stacking was purchased, the injured party had $45,000 in UIM benefits potentially recoverable in the event of an accident.
The Heller court noted that, in Craley v. State Farm, 895 A.2d 530 (Pa. 2006), the Pennsylvania Supreme Court recognized another form of stacking which came to be known as inter-policy stacking. Inter-policy stacking occurs when a single insurance company has issued multiple policies covering separate vehicles in a household.
To illustrate, Craley involved a claimant who was killed in an auto accident. The Claimant's husband attempted to recover both under a State Farm policy that had been issued to the deceased claimant on one vehicle in the household as well as under a separate policy that had been issued by State Farm to the husband on his separate vehicle.
The decision in Craley had to do with the fact that both of the State Farm policies included a waiver of the stacking option executed by the insureds. In addition to recognizing the concept of inter-policy stacking, the Craley court also held that the waiver of stacking was valid in both intra-policy and inter-policy situations. It was therefore determined in Craley that, since stacked coverage was waived, a UIM recovery was only available under the decedent's insurance policy and not the husband's separate policy with the same carrier.
In the Heller case before Judge Boyer, the injured party had a State Farm policy that provided for non-stacked UIM coverage of $100,000. The Plaintiff also had a separate policy with Erie Insurance covering three vehicles with stacking UIM coverage of $15,000, i.e. a total of $45,000 in benefits available.
Erie tendered its $45,000 in UIM benefits to the injured party. State Farm then attempted to limit its exposure pursuant to its "Other Insurance" clause, which provided that, where the injured party had UIM coverage available from more than one policy, regardless of whether the other policies were provided by State Farm or another carrier, the injured party would be limited to the amount of the highest UIM policy limit among all of the available insurance policies.
Since the highest UIM policy limit at issue in Heller was the $100,000 limits in the State Farm policy, State Farm believed that, pursuant to its "Other Insurance" clause, it was correct in only having to pay another $55,000 above the $45,000 paid by Erie (i.e. $45K + $55K = the $100K highest policy limit).
Judge Boyer agreed with State Farm in Heller and, in doing so distinguished the plaintiff's strong reliance upon the case of Generette v. Donegal, 957 A.2d 1180 (Pa. 2008).
In Generette, the claimant was injured while riding as a guest passenger in a vehicle. The injured party recovered under the liability policy that covered the tortfeasor's policy and also obtained a tendering of the Nationwide $50,000 UIM policy limits covering the vehicle in which she was located at the time of the accident.
The injured party in Generette then turned to Donegal Insurance to recover the additionally available $35,000 in UIM limits she had purchased for herself on her own separate personal vehicle. The facts of that case confirmed that the injured party had waived the stacking option under her own policy.
Like the State Farm policy in Heller, the Donegal Insurance Company policy in Generette contained an "Other Insurance" clause, which implemented the waiver of stacked UIM benefits. In Generette, Donegal Insurance refused to pay any benefits under this clause, which like the clause in the State Farm policy in Craley, provided that the UIM carrier's maximum exposure across multiple, applicable insurance policies was the highest policy limit stated in any of the policies.
Since the Nationwide Insurance policy had the highest available limits of $50,000 and since those limits were already paid by Nationwide, Donegal refused to pay any of its lesser amount of $35,000 in available UIM benefits under an application of the "Other Insurance" clause.
In Generette, the Pennsylvania Supreme Court rejected Donegal Insurance's position as being in violation with the public policy of Pennsylvania. First, after a lengthy discussion of the procedural history and statutory definitions, the Generette court rejected Donegal's argument that the injured party was unable to recover on the basis that she had rejected stacking. The Court in Generette determined that Section 1738 of the Motor Vehicle Responsibility Law (MVFRL), which only expressly allows an "insured" to waive stacking, did not apply in this case because guest passengers were not "insureds" as that term is defined in the MVFRL.
After ruling that the injured party was not barred from recovering by her waiver of the stacking option, the Generette Court then turned to the question of whether Donegal's "Other Insurance" clause served to preclude a recovery.
The Court in Generette found that the "Other Insurance" clause, in this context, violated the public policy mandating that UIM coverage be excess coverage rather than gap coverage. In other words, an application of the "Other Insurance" clause in this scenario would have prevented the injured party from securing the very excess insurance coverage she had paid premiums for in the event that she was injured by a tortfeasor with inadequate insurance coverage.
As such, the Supreme Court found that, in the context of Generette, the "Other Insurance" clause violated public policy and could not be utilized by Donegal Insurance to limit the injured party's recovery.
Turning back to the case before him, Judge Boyer noted that, while the facts presented in the Heller case were similar to those in the Generette case, the simiarities did not reach the level to where Generette had to be followed as binding precedent.
Most importantly, Judge Boyer noted that, whereas in Generette the Court held that the waiver of stacking was not valid in the case of a guest passenger who did not meet the definition of an "insured," in Heller the injured party was identified by name on the subject policy and, therefore, was an "insured" under the MVFRL who could validly waive stacking.
The Heller court went on rationalize that the valid waiver of coverage was the key distinction from the Generette case. Judge Boyer ruled that, to then find State Farm's "Other Insurance" clause to be a violation against public policy in spite of a valid waiver of stacking, would require him to rewrite the MVFRL, an option he refused to undertake.
Judge Boyer concluded his Opinion by noting that, in passing the MVFRL, the Pennsylvania Legislature attempted to contain the spiraling costs of automobile insurance by adopting provisions such as the waiver of stacking statute. The Heller court ruled that, by waiving stacking, the injured party paid a lower premium to receive a maximum of $100,000 in UIM coverage under the application of the "Other Insurance" coverage. Accordingly, the court held that State Farm acted properly in only paying $55,000 out of its available $100,000 in UIM policy limits under the facts presented.
Anyone desiring a copy of this trial court opinion out of Venango County may contact me at dancummins@comcast.net.
I thank the prevailing defense attorney in the Heller case, Attorney Tom McDonnell of the Pittsburgh law firm of Summers, McDonnell, Hudock, Guthrie & Skeel, P.C. for bringing this enlightening case to my attention.
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