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Coryn is a member of the Professional Liability Department where she focuses her practice on the defense of public entities, police, prison and correctional officers, as well as elected officials in civil rights, employment and land use matters. In addition to the core areas of her practice, Coryn also has experience with general liability, automobile liability, premises and retail liability, and property litigation matters. 

Coryn attended Arcadia University, where she graduated cum laude, with a Bachelor of Arts in Political Science and Pre-Law. Thereafter, she attended Penn State Dickinson Law, where she graduated cum laude with a juris doctor and a Certificate in Entrepreneurship Law – Concentration in Intellectual Property and Technology in 2023. 

While in law school, Coryn received CALI Excellence for the Future Awards (highest grade) in Insurance Law, Intro to Intellectual Property, Constitutional Law, and Family Law. She also served as a research assistant for the Associate Dean of Academic and Student Affairs and as the Vice President of the Intellectual Property Law Society. Upon graduation, Coryn was inducted into the Woolsack Honor Society for ranking in the top 15% of her class. 

    • Penn State Dickinson Law (J.D., cum laude, 2023)
    • Arcadia University (B.A., cum laude, 2018)
    • Pennsylvania, 2023
    • U.S. District Court Eastern District of Pennsylvania, 2023
    • U.S. District Court Middle District of Pennsylvania, 2023
    • Dauphin County Bar Association
    • Pennsylvania Bar Association

Results

Summary Judgment Won in a Premises Liability Action

We obtained summary judgment on behalf of two homeowners in a premises liability action. One of the homeowners called his father, the plaintiff, asking him to come to his house because he was having his roof replaced and had concerns about the work being done. The plaintiff arrived at the home and observed nails and other debris strewn about the entire property. Nonetheless, he entered the property to assess the roofing work and took care to avoid stepping on any nails. As he was leaving the property, he stepped on a nail, which went through his foot. The plaintiff asserted claims of negligence against both homeowners and also attempted to assert that, because his son requested that he come to inspect the roofing work, he was a business invitee rather than a licensee. We argued that the plaintiff was a licensee as he was a social guest who was merely providing advice to his son. They further argued that the homeowners owed no duty to the plaintiff as he knew the nails were strewn about the property and he understood the risk involved in walking there. We also argued that the plaintiff’s claim was barred by assumption of risk because as he was aware of the nails on the property and, nonetheless, voluntarily proceeded to walk onto the property. The court agreed and granted summary judgment in favor of the homeowners.

Summary Judgment Obtained for a Homeowners’ Association

We secured summary judgment for a homeowners’ association. The plaintiff owned an apartment in a planned community and sought to drill a hole through the exterior wall of the building to vent an HVAC unit. The HOA denied his request, and the plaintiff asserted claims of negligence and breach of the duty of good faith and fair dealings, alleging that the HOA treated him unfairly by denying his request. Despite providing numerous photos of other holes through the exterior wall of the building, the plaintiff admitted during his deposition that they did not know whether the HOA had ever permitted another unit owner to drill a hole in the exterior wall. We successfully argued that the plaintiff could not put forth any evidence demonstrating unfair treatment, or that the request had been denied in bad faith. 

Thought Leadership

Defense Digest

Highly Specific: Supreme Court Reiterates Exacting Standard for Clearly Established Constitutional Rights

June 30, 2026

Key Points: The United States Supreme Court continues to underscore the need for specific precedent to find a constitutional right “clearly established” for the purpose of qualified immunity. To satisfy this standard, courts generally need to identify a prior case where an officer acting under similar circumstances was held to have violated the Constitution. Clearly established rights cannot rest on broad or generalized propositions; they must be defined with a high degree of specificity. In the past decade, the United States Supreme Court strengthened qualified immunity protections for government actors in 42 U.S.C. § 1983 cases. Building on its 2015 decision in Mullenix v. Luna, the Supreme Court has increasingly emphasized the demanding nature of the “clearly established” prong. Under this framework, precedent must define constitutional rights with a high degree of specificity, such that every reasonable official is on notice of what conduct is unlawful. In Zorn v. Linton, 607 U.S. __, 146 S. Ct. 926 (2026), the Supreme Court reaffirmed this exacting standard. The case arose from a January 8, 2015, protest at a Vermont Statehouse, where approximately 200 individuals participated in a nonviolent sit-in. The plaintiff, Shela Linton, was among these protestors. At approximately 8:00 p.m., 29 protestors, including Linton, remained seated on the Statehouse floor with their arms linked. Law enforcement informed them that the Statehouse was closed, instructed them to leave, and warned that refusal would result in arrest for trespassing. When the protestors declined to comply, officers began arresting and removing them individually. Protestors who refused to comply thereafter were lifted and escorted, dragged, or carried out of the Statehouse chamber. After removing sixteen protestors, the defendant, Sergeant Zorn, approached Linton and asked her to stand. Linton refused, remaining seated with her arms interlocked with the other protestors. After several seconds, Sergeant Zorn and a second officer took hold of Linton’s arms and separated her from the group. Sergeant Zorn then placed Linton’s left hand behind her back in a rear wristlock and twisted her arm. As Linton cried in pain, Sergeant Zorn repeatedly asked her to stand. Linton refused to stand and verbally reinforced this refusal. In response, Sergeant Zorn warned Linton that he would ask her one more time to stand up prior to using more pain compliance. Linton again refused to stand, and Sergeant Zorn applied pressure to her wrist and lifted her. Linton screamed, briefly stood, and then fell back to the floor after jerking her arms. Sergeant Zorn and two other officers ultimately carried her out of the building. Linton subsequently brought a Section 1983 claim, alleging Sergeant Zorn used excessive force in violation of the Fourth Amendment. The District Court granted summary judgment to Sergeant Zorn, concluding it was not clearly established that lifting Linton while applying wrist pressure violated her Fourth Amendment rights. The Second Circuit reversed, relying on its decision in Amnesty America v. West Hartford for the proposition that the “gratuitous” use of pain compliance techniques against passively resisting protestors constitutes clearly established excessive force. The Supreme Court reversed, finding that the Second Circuit contravened the principles of a clearly established right by relying on Amnesty America as dispositive. The Court explained that government officials are shielded by immunity unless existing precedent places the constitutional question “beyond debate,” such that it is sufficiently clear that every reasonable official is on notice of what conduct is unlawful. This generally requires a court to identify a prior case where an officer acting under similar circumstances was found to have violated the constitution. Said case must further define the constitutional right with a high degree of specificity. According to the Court, Amnesty America did not meet these requirements. The Supreme Court identified three principal flaws in the Second Circuit’s analysis. First, Amnesty America involved a wide variety of alleged uses of force against passively resisting protestors, ranging from ramming a protestor’s head into the wall to using rear wristlocks to lift protestors up, and did not definitively hold that any of those actions violated the Fourth Amendment. Instead, the Amnesty court remanded the case because a reasonable jury could have found either excessive force or reasonable conduct, which is insufficient to define a clearly established right. Second, the conduct in Amnesty America differed in a key respect: there was no indication that officers warned protestors before using force. In contrast, Sergeant Zorn repeatedly warned Linton and gave her an opportunity to comply. The Court reasoned that a reasonable officer could not have interpreted Amnesty America to establish “that using a routine wristlock to move a resistant protester after warning her, without more, violates the Constitution.” Third, the Second Circuit relied on an overly general principle: “that the gratuitous use of pain compliance techniques—such as a rear-wristlock—on a protestor who is passively resisting arrest constitutes excessive force.” The Supreme Court emphasized that such generalizations are insufficient. Even if that principle was established by Anmesty America, it lacked the high degree of specificity necessary to clearly define what conduct is prohibited, particularly because it failed to delineate when force becomes “gratuitous.” Although brief, the Supreme Court’s opinion reinforces the stringent requirements for clearly established law. To overcome qualified immunity, there must be precedent that: (1) squarely governs the specific conduct at issue and places the constitutional question beyond debate; (2) is not materially distinguishable from the facts of the case; and (3) defines the right with a high degree of specificity rather than at a general level. Absent these elements, qualified immunity will shield government officials from liability. Coryn works in our Harrisburg, PA office. He can be reached at (717) 651-3703 or CDHubbert@mdwcg.com.

Firm Highlights

Thought Leadership

Pennsylvania Supreme Court to Review Whether Legal Malpractice Claims May Be Recast as Breach of Contract Claims

The Pennsylvania Supreme Court recently granted allowance of appeal to consider whether a plaintiff may pursue a breach of contract claim against an attorney based on allegations that the attorney failed to provide competent legal services. The issue is significant in professional liability litigation because it concerns whether a plaintiff may avoid the statute of limitations applicable to professional negligence claims by characterizing the alleged misconduct as a breach of contract. Antoine Poteat retained attorneys Gary Asteak and Nino V. Tinari to represent him in a criminal matter. After his conviction was subsequently overturned through a Post Conviction Relief Act proceeding, Poteat filed suit against his former attorneys alleging that they breached their retainer agreements by failing to provide competent legal services. The attorneys argued that the claims sounded in professional negligence, rather than breach of contract, and were therefore time-barred. The trial court dismissed Poteat’s complaint, but the Superior Court, sitting en banc, reversed. The Superior Court held that the gist-of-the-action doctrine did not bar Poteat’s breach of contract claim because the alleged failure to provide competent legal services could constitute a breach of the parties’ agreement. The Court further held that a legal-services agreement contains an implied duty requiring an attorney to provide competent legal services, even where the agreement does not contain an express provision requiring such services. The Pennsylvania Supreme Court granted review in July 2026 and will consider whether the Superior Court’s decision conflicts with Pennsylvania precedent distinguishing contract and tort claims, including Bruno v. Erie Insurance Co. The Supreme Court will also address whether a plaintiff may maintain a breach of contract claim based on an implied duty to provide competent legal services without identifying a specific contractual provision that was breached. The Supreme Court’s decision could have significant implications for professional liability litigation in Pennsylvania, particularly where plaintiffs seek to characterize claims arising from alleged professional negligence as contractual claims.

Thought Leadership

Two Tracks, No Preclusion: Ohio Supreme Court Preserves Separate Damages Claims After Chapter 2506 Appeals

The Supreme Court of Ohio has clarified that an administrative appeal under Ohio Revised Code Chapter 2506 does not bar a separate action for damages and declaratory relief that could not have been pursued in the administrative appeal. The Ohio Supreme Court considered Sheetz, Inc. v. Centerville (2026-Ohio-3531) as a result of a certified question from the Southern District of Ohio. The question was whether Sheetz, the gas station/convenience store brand, was barred from seeking damages in a separate action since damages were not sought in their administrative appeal. Ultimately, the Ohio Supreme Court ruled that res judicata does not bar a separate action for damages after ruling on an administrative appeal because R.C. Chapter 2506 is limited to judicial review and cannot grant affirmative relief. The case arose after Centerville’s city council rejected a site plan proposed by Sheetz, Inc. that had received unanimous approval from the City’s planning commission. Sheetz filed an administrative appeal pursuant to R.C. 2506 in the Montgomery County Court of Common Pleas, and two months later filed a complaint for damages and declaratory relief under 42 USC § 1983 as a takings action with the city, city council, and other objectors as improper takings and a violation of due process, as well as interference with business and contractual relationship. The city and city council removed the § 1983 action for damages to federal court. Montgomery County Court of Common Pleas reversed the city council’s denial, and allowed the Sheetz project to move forward. Upon that ruling, the federal court issued a show-cause order questioning whether the § 1983 action was barred by the doctrine of res judicata via claim preclusion (which includes all theories of recovery).  Sheetz argued that Ohio courts of common pleas do not have authority to award damages or declaratory relief as party of the R.C. Ch. 2506 appeal, therefore res judicata could not be triggered to apply to the § 1983 action. Additionally, Sheetz moved to certify the issue to the Ohio Supreme Court, citing differing results between the second and sixth districts on this same issue. Centerville approached the question, not from a claim preclusion standpoint, but from the holding in Grava v. Parkman, Twp which states that a final judgment rendered on the merits bars all subsequent action based on the same transaction or occurrence.  In yet another approach, an objector argued that claim preclusion was satisfied because Sheetz could have raised its damages claims in the administrative appeal – Sheetz disagrees. In their analysis, the Supreme Court of Ohio broke down the elements of a claim preclusion analysis: 1) a prior final, valid decision on the merits by a court of competent jurisdiction; (2) a second action involving the same parties, or their privies, as the first; (3) a second action raising claims that were or could have been litigated in the first action; and (4) a second action arising out of the transaction or occurrence that was the subject matter of the previous action. The Court held that R.C. Ch. 2506 does not permit a party to argue damages as R.C. Ch. 2506 limits the common pleas jurisdiction as if it were sitting on appeal, and therefore can only affirm, reverse, vacate, or modify the appealed order, or can remand the case to the administrative body. Further, the Court held that Grava’s conclusion that a final judgment precludes additional litigation for different relief is inapplicable under this fact pattern because it was meant only to apply to those matters in which the plaintiff brings the exact same case twice, but for new relief. The Court found Grava was inapplicable because Sheetz could have requested damages or declaratory relief in the R.C. 2506 appeal. Therefore, Grava would be nothing more than dicta if it even did apply. Going further, the Ohio Supreme Court disavowed Sixth Circuit precedent which, in reliance on Grava and other district court decisions, permitted an owner to seeking relief under 42 U.S.C. § 1983 alongside an administrative appeal. See Moore v Hiram Twp., 988 F.3d 353 (6th Cir.2021). The Ohio Supreme Court found that the Sixth Circuit had disregarded a critical decision in Community Concerned Citizens, Inc. v. Union Twp. Bd. of Zoning Appeals, 1993-Ohio-115, which clearly held that a R.C. Ch. 2506 appeal cannot be combined with a complaint seeking other claims for relief. Id. at ¶ 11. To that end, the Ohio Supreme Court has determined that the decisions Moore relied on (outside of Grava) are no longer good law, and that Moore was wrongly decided. The decision draws a clear procedural boundary: Chapter 2506 provides judicial review of an administrative decision, not a forum for independent claims seeking affirmative relief. Although Grava may place claims arising from a single transaction within the potential scope of claim preclusion, those claims are not barred unless the complete claim-preclusion test is satisfied. Because Sheetz could not have pursued damages or declaratory relief in its Chapter 2506 appeal, the separate action was not precluded. The remaining question for practitioners looking to apply or defend against this exception is when does the statute of limitations begin to run on damages and declaratory relief claims related to an administrative decision on appeal? A takings action in federal court has a 2-year statute of limitations, or as a state claim, 4 years (like the other tortious claims raised therein). Correlating this case with others, an administrative appeal will not likely toll the statute of limitations on claims based on a final decision by a municipal authority. Therefore, practitioners should look for these cases to be brought simultaneously.

Thought Leadership

The Search-Incident-to-Arrest Doctrine Does Not License Strip Searches

In Beatty v. Gardner, No. 25-2860 (3d Cir. Sept. 16, 2026), Kyle Beatty sued police officers Clinton Gardner and Calvin Irvin under 42 U.S.C. § 1983 after they stopped, arrested, and searched him three times during a drug investigation in Williamsport, Pennsylvania. The officers initially smelled marijuana coming from the car in which Beatty was sitting and observed marijuana residue, giving them probable cause to arrest him. Beatty consented to the first pat-down, and the second search was conducted incident to his lawful arrest; neither search uncovered weapons or contraband. The officers then transported Beatty to the police station solely to strip-search him, but the strip search also revealed nothing. The District Court granted the officers summary judgment, concluding that the initial stop, arrest, and first two searches were reasonable and that qualified immunity protected the officers from liability for the strip search. The Third Circuit affirmed, but held that the strip search itself violated the Fourth Amendment. The court concluded that the search-incident-to-arrest doctrine does not automatically permit officers to strip-search an arrestee outside the jail or prison setting. Because strip searches are highly intrusive and the traditional justifications for searches incident to arrest (officer safety and preservation of evidence) did not justify the search of Beatty, the officers generally needed either the arrestee’s consent, exigent circumstances, or a warrant supported by probable cause to believe that a search beneath the clothing would reveal weapons, contraband, or evidence. Here, the officers had none of those justifications. Nevertheless, the court held that qualified immunity barred damages liability because, at the time of the search, the right against a warrantless strip search of an arrestee outside the institutional setting was not clearly established by Supreme Court or Third Circuit precedent. The court likewise upheld qualified immunity on Beatty’s First Amendment retaliation claim and affirmed summary judgment for the officers.