Litwak v. Our Lady of Victory Hospital of Lackawanna
This medical malpractice action stemmed from the death of a plaintiff's decedent after hospital emergency room treatment. The plaintiff appealed an order granting summary judgment to defendant Dr. Kenneth H. Eckhert, Jr., who argued the claim was barred by workers' compensation. The appellate court analyzed whether the medical services were generally available and if the treatment occurred within the scope of employment for both the decedent (a Ford Motor Company employee) and Dr. Eckhert. The court determined that neither was acting within the scope of employment during the treatment, thus the Workers' Compensation Law's exclusive remedy did not apply. The order was reversed, the complaint and cross claims against Dr. Eckhert were reinstated, and summary judgment was granted to the plaintiff, dismissing the workers' compensation defense.