.

Adam J. Fulginiti

Portrait of Adam J. Fulginiti

Adam concentrates his practice in medical malpractice and defends a variety of health care providers, including physicians and nurses, nursing homes and hospitals. He also serves as chair of the Telehealth and Telemedicine Practice Group, helping clients navigate the intersection of heath care, technology and the law. Additionally, Adam has an extensive practice in the arena of social services, where he represents foster care and adoption agencies, residential treatment facilities and community social service agencies.

Adam was selected to serve as the 2020 Board Observer for the Legal Clinic for the Disabled (LCD) as part of the Philadelphia Bar Foundation's Board Observer program. In this role, Adam attended board meetings and fundraisers and observed other events and activities of the organization. The LCD provides free, quality legal services to low income people with physical disabilities and to the deaf and hard-of-hearing in Philadelphia, Bucks, Chester Delaware and Montgomery Counties.

In May 2010, Adam received his juris doctor from the Rutgers University School of Law at Camden. While in law school, Adam worked as an associate editor for the Rutgers Journal of Law and Religion, where he published work addressing Constitutional implications for bioethical, philosophical and religious principles.   

Prior to beginning his legal career, Adam received his Bachelor's Degree in Biological Sciences from the University of Delaware, and performed clinical genetic research at the Children's Hospital of Philadelphia. During his time at CHOP, his work was published in the American Journal of Medical Genetics.

    • Rutgers Law School (J.D., 2010)
    • University of Delaware (B.A., 2007)
    • New Jersey, 2010
    • Pennsylvania, 2010
    • The Best Lawyers: Ones to Watch©, Health Care Law (2024-2025)
    • Pennsylvania Super Lawyers Rising Star (2016-2020)
    • American Bar Association
    • Pennsylvania Bar Association
    • Part of the defense team that successfully obtained a defense verdict during arbitration in a medical malpractice case. Our client performed major reconstructive surgery for a patient with a highly complex and longstanding history of severe right foot problems. The plaintiffs alleged that our client failed to properly evaluate the patient and perform the surgery at issue, causing complications that required three additional surgeries to correct. We argued that the plaintiff's postoperative course, including the clinical manifestations that developed and the subsequent surgeries he received, constituted a series of known complications/outcomes regarding the complex surgery he underwent. An arbitration verdict was made in favor of our client.
    • Successfully defended a long-term care facility in a nursing home malpractice matter, which involved claims of vicarious as well as corporate liability. After leveraging the case into binding arbitration, Adam obtained a complete defense verdict of “no negligence” on behalf of the facility and its corporate affiliates. 
    • Obtained a dismissal in a nursing home malpractice case. After removing the case to federal court, the EDPA judge granted the motion to dismiss the case on all counts, with prejudice. 
    •  Issues Impacting Telemedicine and Healthcare Claims, client webinar, December 17, 2024
    • What Claims and Telemedicine Professionals Should Know About the COVID-19 Public Health Emergency Transition, AM Best Insurance Law Podcast, March 23, 2023
    • Telehealth Providers and Controlled Substances: Navigating the Challenges of Telehealth Prescribing, Strafford webinar, August 10, 2022
    • Taking the Telemedicine Time-Out, Philadelphia Area Society of Healthcare Risk Management (PASHRM) webinar, May 13, 2022
    • Telemedicine Takeaways for 2022, Marshall Dennehey Trends in Health Care and Health Law Seminar, May 5, 2022
    • Staying Ahead of the Curve with Telehealth and Risk Mitigation: Navigating Legal Pitfalls in a Rapidly Expanding Industry, webinar, November 4, 2021
    • Charting the Course of Telehealth in the Post-COVID Landscape, ASHRM Webinar Series, April 27, 2021
    • Telehealth Emerging Legal and Regulatory Issues: Adopting and Implementing Innovative Solutions, Strafford webinar, November 5, 2020
    • Telehealth Update: Information and Best Practices to Protect Patients and Clinicians, webinar for Pennsylvania Association for Healthcare Risk Management 2020 Annual Fall Conference, September 11, 2020
    • Telehealth and Documentation in the Time of COVID-19: Information and Best Practices to Protect Patients and Clinicians webinar, April 23 and May 14, 2020 
    • Navigating Mental Health Issues in Professional Liability Litigation: Privacy, Privileges and Protections, Marshall Dennehey Health Care and Health Law Seminar, November 7, 2019
    • Recent Trends in Pennsylvania Medical Malpractice Litigation, Philadelphia Area Society for Healthcare Risk Management (PASHRM) monthly educational meeting, May 24, 2018

Results

Thought Leadership

The Quarterly Dose

Managing Risks in ER Psychiatric and Behavioral Health Treatment

May 1, 2024

As mental and behavioral health care grows more universal, and the delivery of healthcare services becomes more diverse, providers must be prepared to account for shifting landscapes regarding the standard of care. Given new trends emerging within this field, there are best practices providers can utilize to manage and mitigate risk in the emergency room setting. Vetting and Training Personnel Within the context of behavioral health emergency room treatment, vetting and training of personnel constitutes a key factor in litigation which often manifests in corporate negligence claims. Institutional providers may face exposure not only for the actions of their staff related to the patient, but also the operation of the facility itself. This includes factors such as the hiring and retaining of personnel, the adequacy of policies and procedures, adequacy of facilities and equipment, and notably, training and oversight of staff. While all licensed providers in the ER should ideally be proficient in handling behavioral health patients, treatment of these patients should be assigned to providers with relevant experience, given the unique challenges these patients present. Providers should be proficient in modalities germane to behavioral health, which include screening tools regarding depression, violent ideations, trauma, and substance abuse. They should also be competent in the performance of safety checks regarding risks for ligature, suffocation, and/or items that can be thrown, broken, or otherwise used to harm the patient or others. Proficiency should be demonstrated by physicians, nurses and other mid-level providers, as well as other “ancillary staff.” Behavioral health settings often include a safety observer and security personnel who can also be utilized in crisis cases involving agitation or risk/history of violence/self harm. Social workers and other crisis specialists may also be employed. Regardless of the role of the personnel involved, providers interacting with behavioral health patients in the ER should be proficient in observation, communication, and engagement. In addition to ensuring proper vetting and training of ER staff, documentation of these processes should be created and maintained in credentialing and/or personnel files. Examples of relevant materials include initial training/orientation, acknowledgment of receipt related to policies and procedures, and ongoing education and training.  Telemedicine in the Behavioral Health ER Logistically, telemedicine can and often is utilized to supplement staffing and maintain continuity of services. For larger institutions, daytime and evening shifts may employ in-person coverage but for overnight hours, psychiatric telemedicine services may be utilized. Smaller institutions, which typically have less access to in-person staff, may utilize psychiatric telemedicine with greater frequency. In either scenario, psychiatric telemedicine enhances the ability of healthcare institutions to service and treat a broader array of patients, irrespective of the staff physically present. While the benefits of psychiatric telemedicine may be obvious, they come at a cost, as the risks and exposure common to all telemedicine practice exist and, in fact, may be enhanced, within the setting of ER behavioral health treatment. This primarily derives from the lack of in-person contact, the quintessential element of telemedicine. Generally speaking, the inability of a provider to be physically present with a patient can impact the therapeutic dynamic. This “disconnect” between in-person care and telemedicine can be pronounced in the context of behavioral health treatment, where factors such as body language, eye contact, and other manifestations may be more difficult to appreciate. Lack of in-person contact may also impact the provider’s rapport with the patient, potentially limiting the patient’s trust. This may affect the patient’s candor with the provider, which may in turn diminish the provider’s ability to generate a properly-informed diagnosis and treatment plan. In light of these challenges, institutions should ensure telemedicine providers involved with behavioral health patients are proficient with this type of practice. Tactics such as maintaining patient engagement, conducting objective screening, and obtaining as detailed a history as possible are key to mitigating potential adverse outcomes. The institution should also maintain up-to-date telemedicine-related technology to minimize challenges associated with behavioral health telemedicine in the ER. In the event the telemedicine provider determines in-person care or admission is necessary, institutions must be prepared to handle such a recommendation, be it through on-site treatment or the facilitation of transfer to another facility. Subcontracted Services Larger healthcare institutions, especially those in an academic setting, maintain their own psychiatric medicine service, which is flush with attending physicians, fellows, residents, and other mid-level providers. Consequently, the need to subcontract outside providers to assist with behavioral health treatment in the ER is typically unnecessary. However, smaller healthcare institutions may not have access to in-house psychiatric services, or, may have limited access throughout a 24-hour time period. Smaller institutions may therefore need to subcontract with an outside psychiatric provider in order to furnish or supplement in-house psychiatric services. Additionally, the need for security services in the ER has been on the rise. In a 2022 American College of Emergency Physicians survey, 85% of those surveyed expressed that the rate of violence experienced in emergency departments has increased over the past five years. In this regard, 55% said they had been physically assaulted, almost all by patients, with a third of those resulting in injuries. Notwithstanding the societal stigma imposed upon psychiatric patients and those struggling with addiction, these same physicians reported that psychiatric patients, along with those seeking drugs or under the influence of drugs or alcohol, comprised over 80% of the assaults experienced. Given the increasing risk that ER providers face, institutions may opt to retain and/ or increase their security staff and technology, often through subcontracting with a third party. The importance of delineating parameters of the subcontractor relationship, particularly responsibility for certain tasks, is key. To the extent such companies are enlisted to provide services, institutions should understand what services these entities are obliged to perform and what they are not. This typically can be addressed through service agreements or similar contracts, which provide guidance regarding the apportionment of responsibilities. Within these contracts, indemnity provisions are critical to identifying exposure in the event of an adverse outcome and potential litigation. For example, when contracting with an outside provider to provide in-house psychiatry services, the parties must have a clear understanding of their respective roles in the hiring, orientation and training, credentialing, supervision, and control over the provider. The contract should clearly layout each party’s responsibilities. Such contracts typically require outside vendors to hire the provider and to ensure they are qualified for the proposed role in the ER. At the same time, the contract may significantly limit the vendor’s role regarding supervision/control over the care furnished by the provider. The hospital typically has responsibility for the orientation and credentialing of the provider, as well as supervision of their work pursuant to hospital/ER policies and procedures. The contract should address other issues such as scheduling, disciplinary action, removal or termination of the provider, and, of course, indemnity and contribution. For security staff, many of the same issues exist. There must be a clear delineation of responsibility for vetting and hiring the security staff, and responsibility for ensuring they are qualified and receive the proper and necessary training. The ability to discipline and/or terminate security staff should also be clearly stated. As for behavioral health, depending on the ratio of behavioral health patients in the ER, a healthcare provider should consider providing security staff with advanced training on how to manage patients with behavioral health issues, including those actively in crisis. Either way, the ER should have a sufficient number of properly trained security staff present at all hours to effectively manage a typical shift’s behavioral health caseload. Crisis Management and Facilities Behavioral health patients come with their own unique challenges, especially those who present to the ER in active crisis. Proper screening and assessment of patients in crisis is necessary to not only protect the patient and provide them with the proper treatment, but also to protect others. In addition to vetting and training personnel, the use of telemedicine, and the decision to subcontract certain functions, the ER must have comprehensive policies and procedures regarding provision of care to behavioral health patients. For patients in crisis, policies and procedures should include where the crisis patient should be located in the ER, the protocol for monitoring/surveillance, and the protocol for security (often dependent on the presence, or lack thereof, of a history of violence or indication of potential violence). If possible, a specific number of treatment rooms should be set up for patients in crisis, with all potentially harmful objects removed from the room. These rooms should be located in an area of the ER where security can be effectively provided and which do not allow easy access to exit points. Consideration should be given to security cameras to assist with monitoring, as surveillance footage may be pertinent in the event of an incident and potential, future litigation. If there are crisis intervention specialists in the ER, these specialists must be able to appropriately monitor and access patients in order to facilitate safety and treatment needs. If specific rooms cannot be designated for crisis patients, then the ER should have a plan for what to do when a crisis patient arrives in the building. This includes accounting for where patients are screened and assessed, where they are located, how they are monitored, how to make their environment safe and keep them safe, and how to protect the safety of others.  Reprinted with permission from the April 23, 2024, issue of the The Legal Intelligencer © 2024 ALM Media Properties, LLC. Further duplication without permission is prohibited. All rights reserved.    The Quarterly Dose – April 2024, has been prepared for our readers by Marshall Dennehey. It is solely intended to provide information on recent legal developments and is not intended to provide legal advice for a specific situation or to create an attorney-client relationship. We welcome the opportunity to provide such legal assistance as you require on this and other subjects. If you receive the alerts in error, please send a note to tamontemuro@mdwcg.com. ATTORNEY ADVERTISING pursuant to New York RPC 7.1. © 2024 Marshall Dennehey. All Rights Reserved.

Telemedicine Consequences Resulting from the End of the COVID-19 Public Health Emergency on May 11, 2023

February 9, 2023

On January 30, 2023, the White House issued a statement that the Biden Administration will end the COVID-19 public health emergency on May 11, 2023. President Biden confirmed this event during the February 7, 2023, State of the Union Address. Consequently, this will impact flexibilities created to expand access to telemedicine during the COVID-19 public health emergency, with some going away, and others continuing on a permanent or semi-permanent basis. The upcoming transition period requires health care providers and health care plans to assess current telehealth practices, identify how standards are changing, and determine how to make the necessary adjustments within the immediate future. Extension of Waivers Through the Consolidated Appropriations Act The Consolidated Appropriations Act of 2023 continues many telehealth-related flexibilities for Medicare patients. Some of these flexibilities will be extended on a permanent basis and some on a temporary basis. Key permanent changes under the Consolidated Appropriations Act will include: Federally Qualified Health Centers and Rural Health Clinics may serve as a distant site provider for behavioral/mental telehealth services. There will be no geographic restrictions applicable to the originating site for behavioral/mental telehealth services. Medicare patients may, therefore, continue to receive behavioral/mental telehealth services in their home. Rural hospital emergency departments will also be accepted as an originating site. Behavioral/mental telehealth services may be delivered using audio-only communication platforms. On the other hand, temporary changes, i.e., those extended through December 31, 2024, will include the following: Medicare patients may, in their home, receive telehealth services authorized in the Calendar Year 2023 Medicare Physician Fee Schedule. An in-person visit within six months of an initial behavioral/mental telehealth service will not be required. Telehealth services may be provided by a physical therapist, an occupational therapist, a speech language pathologist, or an audiologist. Increased Scrutiny of Telemedicine Practices to Ensure HIPAA-Compliance The U.S. Department of Health and Human Services Office for Civil Rights confirmed that it will roll back the HIPAA telehealth flexibilities established in the March 17, 2020, Notice of Enforcement Discretion. Following the conclusion of the COVID-19 public health emergency, the OCR will continue flexibilities for health care providers and health plans utilizing remote communication technologies for audio-only telehealth. For the most part, however, covered entities will be expected to return to pre-COVID-19 privacy measures related to telehealth use. This will require ensuring that telemedicine platforms are HIPAA-compliant, that telehealth practices meet the needs of disabled/non-English speaking patients, and that business associate agreements are in place with telemedicine platforms utilized by the covered entity. Nondiscrimination in Telehealth The Department of Health & Human Services Office for Civil Rights, along with the Department of Justice Civil Rights Division, issued guidance mandating that covered entities ensure that telemedicine practices provide accessibility to individuals with disabilities, and to Limited English Proficient (LEP) persons. Covered entities are expected to comport with this mandate, unless doing so would result in an undue financial or administrative burden, or a fundamental alteration of the health program. Covered entities must implement telemedicine practices that accommodate individuals who are disabled, including visually-impaired and hearing-impaired patients. Covered entities must also have HIPAA-compliant systems in place to secure interpreters for LEP persons. Conclusion The coming weeks require covered entities to assess PHE-related adjustments to telemedicine practices and to determine whether those adjustments will be permissible as the United States transitions out of the COVID-19 public health emergency. The failure to do so in the immediate timeframe may put covered entities at risk in the event that certain practices, once afforded during the COVID-19 public health emergency, are no longer permitted.   Legal Update for Telehealth and Telemedicine, February 9, 2023, is prepared by Marshall Dennehey to provide information on recent legal developments of interest to our readers. This publication is not intended to provide legal advice for a specific situation or to create an attorney-client relationship. We would be pleased to provide such legal assistance as you require on these and other subjects when called upon. ATTORNEY ADVERTISING pursuant to New York RPC 7.1 Copyright © 2023 Marshall Dennehey, all rights reserved. No part of this publication may be reprinted without the express written permission of our firm. For reprints or inquiries, or if you wish to be removed from this mailing list, contact tamontemuro@mdwcg.com.

Firm Highlights

Thought Leadership

Appellate Division Affirmed Trial Judge’s Orders Granting Summary Judgement for Defendants on COVID-19 Case

In Dunne v. Advanced Subacute Rehab Servs. at Sewell, LLC, et al., the plaintiffs appealed from two Law Division orders. By way of background, Louis Doto, Sr. (Doto) worked for BP & SC Services, Inc. (BP). BP leased Doto to Advanced Subacute Rehabilitation Center at Sewell, LLC (Advanced Subacute) and it had control of his work, paid wages, and had the power to hire or fire him. A BP employee was assigned to the facility to train and supervise him and BP was responsible for securing workers’ compensation coverage. Doto worked as an aide in the laundry department. Linen from COVID-19 residents were delivered in clearly marked bags and he had no direct contact with residents. A co-worker, Sheila Smith, was also an aide and she never contracted COVID-19 at the facility. Advanced Subacute did not require Doto to wear an N-95 mask, but instead a surgical mask, though N-95 masks were available to all employees. He was also required to attend period mandatory meetings with other high-risk employees, the last of which he attended was in November 2020. All employees were required to test for COVID-19 and there were no reported cases from June to October 2020. On December 23, 2020, Doto tested positive for COVID-19 and passed away on January 18, 2021. The last member of housekeeping that Doto may have encountered tested positive 22 days earlier. After his death, OSHA found two “serious” violations concerning the N-95 masks worn by housekeepers. In response, Advanced Subacute fit tested all non-clinical staff. Doto’s estate filed a workers’ compensation claim and named both BP and Advanced Subacute as his employer. The estate received an award. In July 2022, the plaintiffs filed a complaint in the Law Division, alleging wrongful death and survivor causes of action. In October 2024, the defendants moved for summary judgment, arguing: 1) immunity pursuant to the Emergency Health Powers Act: 2) the exclusive remedy provision of the Workers’ Compensation Act; 3) Doto’s inability to establish infection at the facility; 4) net expert opinions by the plaintiffs’ expert; and 5) inadmissibility of the OSHA report. The plaintiffs opposed and filed a cross-motion for summary judgment, arguing: 1) no immunity as Advanced Subacute engaged in gross negligent or willful misconduct; 2) no preclusion by the Workers’ Compensation Act as Doto was not Advanced Subacute’s employee; and 3) no net expert opinions. In February 2025, the judge issued a written decision granting the defendants’ motion. Specifically, he found Advanced Subacute’s COVID-19 immunity precluded the plaintiffs’ claim as no reasonable jury could find any gross negligence or utter disregard for Doto’s safety. He also addressed the other defenses for completeness. The plaintiffs moved for reconsideration and the judge issued another written decision denying the plaintiffs’ motion in April 2025. The plaintiffs then appealed both decision. The Appellate Division affirmed the orders for reasons stated by the judge in his written decisions. The Appellate Division only added: 1) Advanced Subacute acted consistently with the legislative grant of immunity; 2) there was no doubt Doto was an employee of both BP and Advanced Subacute and the latter may have inadvertently failed to follow some precautions; and 3) confirmed the plaintiffs’ experts did not identify a basis for their opinions. Ultimately, the Appellate Division found no reason to disturb the judge’s well-reasoned decisions and affirmed the judge’s orders.

Thought Leadership

Florida Supreme Court Adopts Traditionally More Expansive Concept of Occupational Causation

The Florida Supreme Court issued a significant decision rebuking the First District Court of Appeal (1st DCA) in the high-profile case of Bouayad v. Normandy Insurance Co., a case addressing the compensability of workplace injuries resulting from assaults by third-party tortfeasors. The Judge of Compensation Claims (JCC) found the claimant was entitled to workers' compensation benefits, relying in part on the Florida Supreme Court's earlier decision in Strother v. Morrison Cafeteria from 1980. In Strother, the Court upheld an award of benefits to a cashier who was assaulted and robbed by individuals who followed her home from work under the mistaken belief that she was carrying restaurant cash deposits. In Bouayad, the 1st DCA concluded that the claimant's injuries were not compensable because they did not arise out of his employment. The Florida Supreme Court disagreed, holding that the 1st DCA applied too narrow an interpretation of the "arising out of employment" requirement. In doing so, the Court reaffirmed a broader and more traditional view of occupational causation than that recently adopted by the 1st DCA. The claimant in Bouayad was the general manager of a car rental business operating from a hotel near an airport. Around midnight, while walking along a covered outdoor walkway from the hotel's atrium, where the rental kiosk was located, to an office near the pool, he was shot multiple times by an unidentified assailant. As part of his regular duties, the claimant carried rental agreements and cash receipts from the kiosk to the office at the end of each shift. After the shooting, the claimant managed to return to the hotel atrium, where he stated that he believed "Robert" had shot him, referring to an individual who had threatened the claimant's son the previous day. The assailant, however, was never identified. Consequently, the Supreme Court analyzed the case as involving an unknown third party while the claimant was acting within the course and scope of his employment. The central issue therefore was whether the injury "arose out of" the claimant’s employment. At the final hearing, the claimant presented evidence regarding the risks and hazards associated with his employment, including the nature of his duties, his late-night work schedule, and the location of the business in a high-turnover hotel near a major airport. His expert opined that these factors exposed him to an increased risk of becoming the victim of a crime while at work. In contrast, the employer/carrier's expert characterized the shooting as a targeted attack rather than a robbery and asserted that the risk of violent crime was actually higher near the claimant's residence than at the hotel. Based on that analysis, the expert concluded that the claimant was not exposed to an increased workplace risk. The 1st DCA focused narrowly on the specific activity the claimant was performing at the moment of injury. According to the court, the claimant's “work performed” at the time of the shooting was simply "walking" between two employer-operated locations, and that act of walking did not itself cause the injury. The Florida Supreme Court found this analysis far too myopic and inconsistent with decades of workers' compensation precedent. Reaffirming longstanding principles of workplace causation, the Court explained that the proper inquiry is not whether the precise physical task being performed at the moment of injury directly caused the harm. Rather, the relevant question is whether the employment, viewed as a whole, exposed the worker to risks and hazards that contributed to the injury. The decision is significant because it reinforces a broader conception of work-relatedness in the “arising out of” compensability analysis. Instead of limiting the causation analysis to the employee's discrete physical activity at the time of injury, courts must consider the totality of the employment circumstances, including the employee's duties, work environment, hours, and occupational risks. Under that framework, an injury may arise out of employment when the employment places the employee in a position of increased hazard, even if the specific task being performed at the moment of injury is not itself the direct cause of the harm.

News

106 Marshall Dennehey Attorneys Recognized in the 2027 Editions of The Best Lawyers in America® and the Best Lawyers: Ones to Watch® in America

Marshall Dennehey is proud to highlight the firm’s 106 attorneys who have been recognized in the 2027 editions of The Best Lawyers in America® and the Best Lawyers: Ones to Watch® in America. Less than 6% of all practicing lawyers in the U.S. were selected by their peers for this recognition. Additionally, four of the firm’s attorneys received the Best Lawyers® 2027 “Lawyer of the Year” awards in their respective practice areas and demographic regions. Since it was first published in 1983, Best Lawyers® has become universally regarded as the definitive guide to legal excellence. Best Lawyers lists are compiled based on an exhaustive peer-review evaluation. For more information, please visit https://www.bestlawyers.com/. OUR 2027 LAWYERS OF THE YEAR Harrisburg, PA Christopher Reeser, Personal Injury Litigation - Defendants Kacey Wiedt, Workers Compensation Law - Employers Roseland, NJ Justin F. Johnson, Medical Malpractice Law - Defendants Leonard Leicht, Personal Injury Litigation - Defendants   OUR 2026 BEST LAWYERS IN AMERICA Philadelphia, PA Nicholas D. Bowers, Personal Injury Litigation - Defendants Josh J. T. Byrne, Professional Malpractice Law - Defendants Jefferey J. Chomko, Insurance Law James H. Cole, Insurance Law John J. Delany III, Personal Injury Litigation - Defendants Laurianne Falcone, Personal Injury Litigation - Defendants John P. Gonzales, Employment Law - Management John Hare, Appellate Practice Daniel D. Krebbs, Personal Injury Litigation - Defendants Michele Punturi, Workers' Compensation Law - Employers Bradley D. Remick, Product Liability Litigation - Defendants Andrea Cicero Rock, Workers' Compensation Law - Employers Robin M. Romano, Workers' Compensation Law - Employers Daniel J. Ryan, Jr., Personal Injury Litigation - Defendants Gary M. Samms, Professional Malpractice Law - Defendants Christopher N. Santoro, Personal Injury Litigation – Defendants; Product Liability Litigation -Defendants Josh D. Scheets, Personal Injury Litigation - Defendants Robert P. Schenk, Workers' Compensation Law - Employers Robert E. Smith, Insurance Law Robin Snyder, Litigation - Health Care Michael L. Turner, Commercial Litigation; Criminal Defense: White-Collar; Mass Tort Litigation / Class Actions - Defendants Claire Breaux Ventola, Product Liability Litigation - Defendants Pittsburgh, PA Melissa Devich Cochran, Commercial Litigation; Mass Tort Litigation / Class Actions – Defendants; Product Liability Litigation - Defendants  John F. Deasy, Personal Injury Litigation – Defendants; Product Liability Litigation - Defendants Daniel W. Deitrick, Workers' Compensation Law - Employers Douglas C. LaSota, Litigation - Construction; Mass Tort Litigation / Class Actions - Defendants Joseph V. Lesinski, Product Liability Litigation – Defendants   Christian D. Marquis, Personal Injury Litigation - Defendants Patricia A. Monahan, Insurance Law; Litigation - Insurance Patrick T. Reilly, Commercial Litigation; Mass Tort Litigation / Class Actions – Defendants; Product Liability Litigation - Defendants Brett C. Shear, Medical Malpractice Law - Defendants Teresa O. Sirianni, Education Law; Employment Law – Management; Litigation - Labor and Employment Stuart Sostmann, Product Liability Litigation – Defendants Danielle M. Vugrinovich, Mass Tort Litigation / Class Actions - Defendants Scranton, PA Sarah E. Argo, Litigation - Insurance Michael J. Connolly, Personal Injury Litigation – Defendants; Professional Malpractice Law - Defendants Matthew Keris, Litigation - Health Care; Medical Malpractice Law - Defendants John T. McGrath, Jr., Insurance Law; Medical Malpractice Law – Defendants; Product Liability Litigation - Defendants William J. McPartland, Insurance Law John R. Nealon, Product Liability Litigation - Defendants Victoria Scanlon, Health Care Law; Litigation - Health Care; Medical Malpractice Law - Defendants Michael A. Sebastian, Workers' Compensation Law - Employers Thomas A. Specht, Insurance Law; Litigation - Insurance Suzanne Tighe, Litigation Insurance Harrisburg , PA Casey Alan Coyle, Administrative/Regulatory Law; Appellate Practice; Commercial Litigation Brittany E. Bakshi, Personal Injury Litigation - Defendants Shannon P. Fellin, Workers' Compensation Law - Employers Allison Krupp, Insurance Law John R. Ninosky, Litigation – Insurance; Personal Injury Litigation - Defendants Christopher Reeser, Personal Injury Litigation - Defendants Kacey Wiedt, Workers' Compensation Law – Employers King of Prussia, PA  Michael L. Detweiler, Construction Law Joseph L. Hoynoski III, Medical Malpractice Law - Defendants Gregory J. Kelley, Construction Law, Litigation - Construction Anthony Natale III, Workers' Compensation Law - Employers Francis X. Wickersham, Workers' Compensation Law - Employers A. Judd Woytek, Workers' Compensation Law – Employers Erie, PA Patrick M. Carey, Personal Injury Litigation - Defendants Joel M. Snavely, Health Care Law; Insurance Law New Haven, CT Michael Wrona, Commercial Litigation, Litigation - Bankruptcy  Mount Laurel, NJ David D. Blake, Litigation - Insurance Barbara Davis, Personal Injury Litigation - Defendants Lynne Nahmani, Litigation - Health Care John H. Osorio, Personal Injury Litigation - Defendants John L. Slimm, Legal Malpractice Law – Defendants; Professional Malpractice Law – Defendants Roseland, NJ Robert T. Evers, Medical Malpractice Law - Defendants Justin F. Johnson, Medical Malpractice Law - Defendants Julia Klubenspies, Medical Malpractice Law - Defendants Leonard C. Leicht, Personal Injury Litigation - Defendants Patricia M. McDonagh, Appellate Practice Sunny Sparano, Litigation - Construction Randall S. Watts, Health Care Law New York, NY Tonya M. Lindsey, Medical Malpractice Law - Defendants Tampa, FL Michael Archibald, Personal Injury Litigation - Defendants Lindsay G. McCormick, Litigation – Construction Orlando, FL Thomas F. Brown, Personal Injury Litigation - Defendants Dante C. Rohr, Commercial Litigation Fort Lauderdale, FL Kimberly Kanoff Berman, Appellate Practice Patrick M. Delong, Personal Injury Litigation – Defendants Jacksonville, FL  Heather Byrer Carbone, Workers' Compensation Law - Employers Linda Wagner Farrell, Workers' Compensation Law - Employers Elizabeth B. Ferguson, Litigation - Construction James P. Hanratty, Personal Injury Litigation – Defendants Wilmington, DE Sarah B. Cole, Litigation - Insurance Benjamin K. Durstein, Workers' Compensation Law - Employers Maria R. Granaudo, Medical Malpractice Law - Defendants  Keri L. Morris-Johnston, Workers' Compensation Law - Employers Cincinnati, OH Timothy B. Schenkel, Personal Injury Litigation - Defendants David E. Williamson, Personal Injury Litigation - Defendants Cleveland, OH Vincent E. Cononico, Litigation – Insurance, Personal Injury Litigation - Defendants Jillian L. Dinehart, Personal Injury Litigation - Defendants David J. Fagnilli, Insurance Law Jason P. Ferrante, Health Care Law, Litigation - Health Care Andrew H. Isakoff, Transportation Law Leslie M. Jenny, Litigation - Health Care; Medical Malpractice Law – Defendant OUR 2026 BEST LAWYERS: ONES TO WATCH Jacksonville, FL Sean J. Reeves, Personal Injury Litigation – Defendants; Product Liability Litigation - Defendants Orlando, FL Carolin A. Pacheco, Insurance Law Mount Laurel Stacey Gorin, Insurance Law Melville, NY Kimberly Gitlin, Personal Injury Litigation – Defendants Matthew A. Gray, Insurance Law; Personal Injury Litigation - Defendants Philadelphia, PA Holli K. Archer, Health Care Law; Medical Malpractice Law – Defendants; Professional Malpractice Law Emily Pritchyk, Commercial Litigation; Product Liability Litigation – Defendants Pittsburgh, PA Taylor E. Kosko, Mass Tort Litigation / Class Actions – Defendants; Personal Injury Litigation - Defendants Alana Staniszewski, Workers' Compensation Law - Employers Michael D. Winsko, Product Liability Litigation – Defendants; Transportation Law King of Prussia, PA Richard Lechette, Commercial Litigation; Insurance Law, Personal Injury Litigation – Defendants

Thought Leadership

Commonwealth Court Deemed Worker an Employee Despite Independent Contractor Agreement; Insurer Estopped from Denying Coverage

In this case, the claimant filed a Claim Petition for injuries sustained on October 28, 2019, naming J&S as his Employer, and alleging that the injuries occurred when he fell from a ladder while installing a satellite dish for Dish Network. Dish Network contracted with J&S to install satellite dishes. Subsequently J&S filed a Petition to Join Brickstreet Insurance Company and the claimant filed a Claim Petition against the Uninsured Employer Guaranty Fund. The Fund then joined Dish Network as another employer.  Before the Workers’ Compensation Judge (WCJ), the claimant testified that he was hired in 2015 by J&S and at the time signed an Independent Contractor Agreement (IC Agreement). J&S defended the case on the basis that the claimant was not an employee, but was an independent contractor, even after the IC Agreement expired. Additional evidence showed that, at the time of the October 28, 2019, work injury, J&S’ workers’ compensation insurance with Brickstreet had lapsed, even though a Brickstreet agent had been working to renew J&S’ policy and had a Certificate for coverage from September 25, 2019 to September 25, 2020 issued, with Dish Network listed as the Certificate Holder. A renewal policy was not in effect at the time the Certificate was issued and the agent learned on October 25, 2019 that Brickstreet was not going to renew their policy with J&S, due to an unpaid premium.    Ultimately, the WCJ found that the claimant was an employee of J&S at the time of the work injury and that J&S did not have a workers’ compensation policy in place at the time, due to their failure to pay the renewal premium to Brickstreet. The WCJ also found Dish Network was a Statutory Employer under Section 302(a) of the Act. The Claim Petition and the Guaranty Fund Claim Petition were both granted, as was the Guaranty Fund’s Petition to Join Dish Network. The WCJ also denied J&S’ Petition to Join Brickstreet, finding that neither J&S or Dish Network showed that Brickstreet was estopped from denying coverage. J&S and Dish Network appealed to the Workers’ Compensation Appeal Board (Board) and the Board affirmed. J&S and Dish Network appealed to the Commonwealth Court. The Commonwealth Court rejected J&S' argument that the claimant was an independent contractor. In doing so, the court noted that the claimant credibly testified that he worked for J&S full time, could not work for another company, and that J&S, scheduled his jobs, tracked him, and scheduled additional installations, if he finished early. Additionally, the court noted the claimant lacked discretion in the manner he performed his job, because all questions had to be referred to J&S.  As for Dish Network’s appeal, the court held that the WCJ erred in holding that Brickstreet was not estopped from denying coverage as to Dish Network. According to the court, the insurance agent was an authorized representative of Brickstreet and, at the direction of J&S, issued the Certificate of Insurance that he knew was not accurate at the time, and was aware would be presented as proof of coverage for J&S. Dish Network relied upon that information and continued to use J&S, ultimately leading to Dish Network being named as the Statutory Employer liable for payment of benefits because of J&S’ uninsured status. The court held that the Board erred in affirming the WCJ ’s conclusion that Dish Network did not establish that Brickstreet was equitably estopped from denying coverage, reversed the decision below, and remanded the case to the WCJ.