Julianna is a member of the Health Care Department, concentrating her practice on the defense of health care practitioners and medical providers against all manner of medical malpractice suits. Her clients include physicians and other health care providers, as well as physicians’ offices, nursing homes, outpatient centers, hospitals and health systems.
Born and raised in Seattle, WA, Julianna graduated from Western Washington University with a bachelor’s degree in Sociology. She went on to earn her Masters in Criminology and Criminal Justice from Arizona State University, and her law degree with a Health Law Concentration from Villanova University’s Charles Widger School of Law. While at Villanova, Julianna served as president of the Health Law Society and was a staff writer for the Jeffrey S. Moorad Sports Law Journal.
Outside of work, Julianna enjoys Pilates, reading all genres of fiction (although murder mystery is her favorite), and spending time with her husband and their two dogs, Stanley and Ollie.
Thought Leadership
Case Law Alerts
Pennsylvania Superior Court Reaffirms Liberal Pleading Standard in Medical Malpractice Actions
July 21, 2026
The Pennsylvania Superior Court has reinforced a broader fact-pleading approach that may make it more difficult for healthcare defendants to obtain dismissal at the preliminary objection stage. In DaSilva v. Abington Memorial Hospital, the court held that the plaintiffs’ second amended complaint satisfied Pennsylvania’s fact‑pleading requirements despite the absence of individually named negligent actors. In DaSilva, the plaintiffs filed a second amended complaint alleging that Abington Memorial Hospital was directly and vicariously negligent after the patient, who was experiencing a mental health crisis, was left unattended by hospital staff, exited the emergency department, and was struck by a vehicle, suffering serious injuries. The trial court sustained the hospital’s preliminary objections and dismissed the complaint with prejudice, stating plaintiffs “failed to plead any material factual allegations in support of their claims of negligence [and] set forth vague allegations of negligence and unidentified agency.” Id. at *5. The plaintiffs appealed. On appeal, the Superior Court reversed, holding that the complaint sufficiently pled negligence and vicarious liability claims under Pa.R.C.P. 1019(a). The court concluded that allegations describing the patient’s condition, the hospital’s awareness of that condition, and the alleged failure to monitor or prevent elopement were adequate to satisfy Pennsylvania’s pleading requirements. Significantly, the court rejected the hospital’s argument that the complaint failed because it did not identify the specific employees responsible for the alleged negligence. Instead, the court found that generalized references to “emergency room staff” were sufficient to place the hospital on notice of the claims because “the names of those who performed services for the plaintiff are known to the defendant or can be ascertained during discovery.” Id. at *12 (citing Est. of Denmark ex rel. Hurst v. Williams, 117 A.3d 300, 307 (Pa. Super. 2015)). The effect of DaSilva is that plaintiffs may proceed past the pleading stage with relatively generalized allegations, particularly in cases involving institutional defendants where relevant details are uniquely within the defendant’s control. As a result, healthcare defendants should anticipate that challenges to claim sufficiency may be resolved in the later stages of litigation, including discovery and summary judgment.
The Quarterly Dose
LEGAL ROUNDUP – Pennsylvania
February 25, 2026
Pennsylvania Supreme Court Broadens MHPA Immunity to Include Ordinary Negligence in Physical Care During Involuntary Commitment Wunderly v. Saint Luke’s Hospital of Bethlehem, 345 A.3d 692 (Pa. 2025) The Pennsylvania Supreme Court has recently expanded the scope of provider immunity under the Mental Health Procedures Act (MHPA), holding that the statute can shield providers from ordinary negligence claims arising from medical care for physical ailments provided during involuntary commitment. The case arose from a wrongful death and survival action following the death of a patient involuntarily committed for dementia-related aggression who developed severe pressure ulcers. Under 50 P.S. § 7114(a), facilities and practitioners participating in decisions to examine or treat individuals under the MHPA are immune from civil and criminal liability, absent a showing of willful misconduct or gross negligence. As § 114 does not define “treat,” the court looked to Section 104 of the MHPA, interpreting “treatment” to include medical care necessary to maintain “decent, safe, and healthful living conditions.” The court concluded that care for physical conditions is covered when it is coincident to the patient’s mental health treatment, even if the condition did not result from psychiatric care or advance psychiatric recovery. This decision significantly broadens the precedent established in Allen v. Montgomery Hospital, 696 A.2d 1175 (Pa. 1997). While Allen provided immunity for physical conditions caused by psychiatric care (such as medication side effects), Wunderly extends that protection to general medical care that simply occurs during the same timeframe as the commitment (such as treatment for pressure ulcers). The dissent warned that the majority’s interpretation risks lowering the standard of care for involuntarily-committed patients by immunizing ordinary medical malpractice based solely on commitment status. The dissent argued that the patient’s pressure ulcers arose independently of his mental health condition and should not fall within MHPA immunity.
