eNotes: Liability – February 2024 – Federal

SIGNIFICANT CASE SUMMARIES

FEDERAL CASE SUMMARY

Villagran v. Freightbull, Inc.
United States District Court for the Eastern District of Pennsylvania
No. 22-2159, 2023 U.S. Dist. LEXIS 184637

Decided: October 12, 2023

Court grants partial summary judgment as to claims for punitive damages.

Background

Plaintiff brought suit as the administratrix of the estate of her Decedent-husband. Decedent collided with the side of a tractor trailer owned by Defendant Freightbull and driven by Co-Defendant Watkins. The truck was executing a left turn when the Decedent struck the trailer “close to the rear.” Dashcam video from a nearby truck showed Defendant driver stop, turn on their left turn signal, and operate a slow and controlled left turn to near completion across two lanes before the trailer was struck. Decedent’s widow asserted claims for personal and vicarious liability arising from the driver’s actions, and claims against Defendant Freightbull for negligent entrustment, supervision, hiring, and retention. Plaintiff characterized Defendant Freightbull’s actions as “egregious conduct” warranting punitive damages. Defendants filed for summary judgment on the punitive damages claim.

Holding

The District Court granted summary judgment, dismissing the claims for punitive damages against the driver and company, and the direct liability claims against Freightbull. The Court held that although the driver may have misjudged the closing distance and speed of Decedent, he did nothing observable or otherwise discovered which rose to the rigorous standard required to form a basis for punitive damages. The Court also granted summary judgment dismissing punitive damages claims against Freightbull. It held that Freightbull’s safety officer’s lack of education, Freightbull’s failure to provide “trip planning” training, and its failure to internally investigate the accident, were not egregious conduct. The Court found that these errors were in between mere quibbles and ordinary negligence, inadequate to support punitive damages. The direct liability claims were also dismissed against Freightbull.

Questions about this case can be directed to Logan Nagle at (717) 255-7234 or lnagle@tthlaw.com.