Court affirms granting motion for summary judgment for defendants following the death of an individual in a workplace accident.

After Rickie Lee Grimsley was killed in a workplace accident, his wife filed suit asserting claims of negligence against the Manitowoc Company, Inc. and its subsidiary, Grove U.S. L.L.C. The court granted summary judgment for Grove, who was held to be Mr. Grimsley’s employer, upon holding that there was not a genuine issue of material fact regarding the fact that Mr. Grimsley’s work “furthered the functions of Grove,” and upon holding that the location of the alleged incident was under the control of Grove, Manitowoc’s subsidiary. Thus, summary judgment was granted as to Grove upon holding that claims were barred under Pennsylvania’s Workers' Compensation Act, as Grove was determined to be Mr. Grimsley’s employer. The court also granted summary judgment as to the plaintiff’s claims against Manitowoc upon holding that Manitowoc did not owe a duty to the decedent and did not undertake such a duty. This holding of the Superior Court appears to demonstrate the expansive reach of Pennsylvania’s Workers’ Compensation Act in barring claims against an injured plaintiff’s employer and appears to show the court’s willingness to grant motions for summary judgment for employer defendants.

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