Breach of Duty in Pennsylvania and New Jersey Tort Law

Breach of Duty in Pennsylvania and New Jersey Tort LawStandards of Care, Negligence Per Se, and Res Ipsa Loquitur

Posted By Brian E. Fritz, Esquire | Fritz and Bianculli, LLC | Philadelphia, PA

Introduction

In any negligence action, the plaintiff bears the burden of establishing four essential elements: duty, breach, causation, and damages. Once a legal duty has been identified—whether arising from the common law, statute, contract, or a special relationship—the inquiry turns to whether that duty was violated. Breach of duty is the second and often most contested element of a negligence claim. It asks a deceptively simple question: did the defendant fail to meet the standard of care that the law demands under the circumstances?1

Pennsylvania and New Jersey both evaluate breach through the lens of the reasonable person standard—a flexible, objective measure against which a defendant’s conduct is compared. In some cases, however, the law provides additional tools for establishing breach without the need to reconstruct precisely what the defendant did wrong. Two of the most important such tools are negligence per se, which arises when a defendant violates a statute or regulation, and res ipsa loquitur, which permits an inference of negligence from the very nature of the accident itself.2

This article examines the general standard for breach of duty and then turns to the application of these two doctrines in Pennsylvania and New Jersey personal injury practice, with particular attention to how they bear on cases arising in the Philadelphia region and South Jersey.

Part One: The Reasonable Person Standard and the General Concept of Breach

The foundation of breach analysis is the reasonable person standard. A defendant breaches a duty of care when their conduct falls below the standard that a reasonably prudent person would observe under the same or similar circumstances.3

The reasonable person is not a perfect person, nor an extraordinarily cautious one. The standard is objective: it does not ask what this particular defendant believed was reasonable, but what a hypothetical reasonable actor would have done in the same situation. Courts and juries assess breach by weighing the likelihood of harm, the severity of potential injury, and the burden of taking precautions against the risk.

Pennsylvania applies the Restatement (Second) of Torts formulation, asking whether the defendant exercised the care of a reasonably prudent person under the circumstances.4

New Jersey similarly employs the reasonable person standard, with the jury serving as the arbiter of whether the defendant’s conduct measured up.5

In practice, establishing breach often requires expert testimony—particularly in cases involving professional standards, construction practices, or medical care. However, in some situations the conduct is so obviously deficient that expert testimony is unnecessary. And in others, the doctrines of negligence per se and res ipsa loquitur provide alternative pathways to establishing breach.

Part Two: Negligence Per Se

A. The Doctrine Defined

Negligence per se is a doctrine that converts a statutory or regulatory violation into conclusive or presumptive evidence of breach of duty. Rather than asking whether the defendant’s conduct met the reasonable person standard, the court asks whether the defendant violated a specific legal standard enacted by the legislature or a regulatory body. If the plaintiff was within the class of persons the statute was designed to protect, and the harm suffered was of the type the statute was designed to prevent, the violation establishes breach as a matter of law.6

The doctrine serves an important function in personal injury litigation. Statutes and regulations often codify existing standards of reasonable care. When a defendant violates those standards, the law does not require the jury to re-determine what reasonable conduct looked like—the legislature has already decided.

B. Application in Pennsylvania

In Pennsylvania, a statutory violation constitutes negligence per se when: (1) the statute was intended to protect against the type of harm suffered; (2) the statute or regulation must clearly apply to conduct of defendant; (3) defendant must violate the statute or regulation; and (4) the violation of the statute or regulation must be the proximate cause of plaintiff’s injuries.7

Pennsylvania courts have applied negligence per se across a wide range of contexts. Traffic code violations—failure to stop at a red light, exceeding posted speed limits, failure to yield—are among the most frequently litigated. Violations of the Pennsylvania Motor Vehicle Code regularly give rise to negligence per se in cases involving automobile accidents on routes such as I-95, Route 30, or the Schuylkill Expressway in the Philadelphia region.8

Beyond traffic cases, negligence per se has been applied in premises liability actions under the Pennsylvania Liquor Code, building code violations, and violations of the Older Adults Protective Services Act in elder care contexts.9

It is important to note that in Pennsylvania, negligence per se establishes breach—it does not eliminate the need to prove causation and damages. The plaintiff must still demonstrate that the statutory violation caused the harm in question.

C. Application in New Jersey

New Jersey likewise recognizes negligence per se when a defendant violates a statute enacted for the safety of others, the plaintiff is within the class of persons the statute was designed to protect, and the violation proximately caused the injury.10

New Jersey courts have applied the doctrine in motor vehicle accident cases arising under the New Jersey Motor Vehicle Code, dram shop liability under the New Jersey Licensed Alcoholic Beverage Control Act, and landlord obligations under the New Jersey Hotel and Multiple Dwelling Act. OSHA violations have also been held to constitute negligence per se in appropriate circumstances in New Jersey.11

One nuance in New Jersey is the distinction between statutes that create a private right of action and those that merely establish a standard of care. Where a statute does not expressly authorize a private civil suit, its violation may still be offered as evidence of negligence—falling just short of negligence per se—if the court determines the legislature did not intend to create a private cause of action.12

D. Practical Significance for Personal Injury Claims

For personal injury attorneys practicing in the Philadelphia area and South Jersey, negligence per se is a powerful tool. When a defendant’s conduct violates an applicable statute or regulation, and that violation caused the client’s injury, the doctrine can simplify trial by removing breach from the jury’s deliberations. The focus then turns to causation and damages. Contact Fritz & Bianculli to evaluate your case.

In multi-vehicle accident cases, construction site injuries, slip and fall actions arising from building code noncompliance, and cases involving intoxicated defendants, diligent counsel should identify all applicable statutory and regulatory standards at the outset and evaluate whether a per se violation can be pled.

Part Three: Res Ipsa Loquitur

A. Historical Origins and Doctrinal Foundations

Res ipsa loquitur—Latin for “the thing speaks for itself”—emerged from the English case Byrne v. Boadle (1863), in which a barrel of flour rolled out of a warehouse window and struck a pedestrian below. The plaintiff could not identify the specific negligent act that caused the barrel to fall, but Baron Pollock observed that barrels do not ordinarily fall from warehouse windows absent some failure of care.13 The circumstances themselves, he reasoned, warranted an inference of negligence.14

The doctrine crossed the Atlantic and became firmly embedded in American tort law by the early twentieth century. Pennsylvania adopted res ipsa loquitur under the Restatement (Second) of Torts § 328D, and New Jersey courts likewise embraced it as a means of addressing the evidentiary imbalance that arises when defendants possess exclusive knowledge of the circumstances surrounding an accident.15

At its core, res ipsa loquitur rests on two complementary rationales. The first is probabilistic: certain types of accidents are so strongly associated with negligence that their occurrence alone justifies an inference of fault. The second is equitable: when a defendant controls the instrumentality that caused harm and possesses superior access to information about what occurred, it would be unjust to require the plaintiff to prove facts that lie exclusively within the defendant’s knowledge. The doctrine thus operates as a corrective to informational asymmetry, shifting the burden of production to the party best positioned to explain what happened.16

B. The Three-Element Framework

Both Pennsylvania and New Jersey articulate res ipsa loquitur through a three-element test, though the precise formulation varies slightly between jurisdictions. Understanding each element—and how courts have interpreted it—is essential to evaluating whether the doctrine applies in a given case.

1. The Accident Is of a Kind That Ordinarily Does Not Occur Absent Negligence

The first element requires the plaintiff to show that the accident belongs to a category of events that, in the ordinary course, do not happen without someone’s failure to exercise due care. This is a probabilistic inquiry: courts ask whether common experience teaches that the type of accident at issue is more likely than not the product of negligence.17

Classic examples include surgical instruments or sponges left inside a patient’s body after surgery, elevators that suddenly free-fall, commercial products that explode or fail catastrophically during normal use, and objects that fall from buildings onto pedestrians below. In the Philadelphia region, res ipsa arguments frequently arise in cases involving malfunctioning escalators in Center City commercial buildings, SEPTA transit vehicle incidents where equipment failure is suspected, and warehouse or loading dock accidents along the I-95 industrial corridor.

Pennsylvania courts have emphasized that the first element does not require absolute certainty that negligence occurred—only that negligence is the most likely explanation. In Gilbert v. Korvette’s Inc. (1974), the Pennsylvania Supreme Court confirmed that res ipsa loquitur creates a permissible inference when the balance of probabilities points toward negligence, even if other explanations remain theoretically possible.18

New Jersey takes a similar approach. In Buckelew v. Grossbard (1981), the New Jersey Supreme Court explained that the first element is satisfied when the plaintiff can demonstrate that the injury-producing event is one that common knowledge or expert testimony would identify as typically caused by negligence.19

Importantly, expert testimony is not always required to establish the first element. Where the connection between the type of accident and negligence falls within common understanding—a falling barrel, a retained surgical sponge, an elevator that drops unexpectedly—the jury may draw the inference without expert assistance. However, in cases involving complex machinery, medical procedures, or specialized industrial processes, expert testimony may be necessary to establish that the accident would not ordinarily occur absent negligence.

2. The Instrumentality Was Within the Defendant’s Exclusive Control

The second element requires the plaintiff to demonstrate that the instrumentality or condition that caused the harm was within the defendant’s control. Traditionally, this meant exclusive physical control—the defendant, and only the defendant, had access to and responsibility for the thing that caused the injury.20

However, both Pennsylvania and New Jersey have relaxed the strict “exclusive control” requirement in recognition of modern commercial realities. In many cases, multiple parties may have had some degree of access to an instrumentality—manufacturers, distributors, maintenance companies, and property owners may all have touched a product or system at various points. Requiring literal exclusive physical control would defeat res ipsa claims in precisely the circumstances where the doctrine is most needed.

Pennsylvania courts have moved toward a “responsibility” or “right of control” standard. The relevant inquiry is not whether the defendant was the only person who ever touched the instrumentality, but whether the defendant bore responsibility for the condition that caused the harm at the time the negligence likely occurred. In Loch v. Confair (1953), the court permitted a res ipsa instruction even though multiple parties had handled the product, because the evidence sufficiently narrowed responsibility to defendants.21

New Jersey’s approach is particularly notable. In Anderson v. Somberg (1975), the New Jersey Supreme Court confronted a surgical case in which a pituitary rongeur broke during an operation, leaving a metal fragment in the plaintiff’s spinal canal. Multiple defendants—the surgeon, the hospital, the instrument manufacturer, and the distributor—could have been responsible for the defect. Rather than deny res ipsa loquitur entirely, the court held that where each defendant had some degree of control or responsibility, and the plaintiff was clearly blameless, the doctrine could apply and the burden of explanation shifted to all defendants. This approach reflects New Jersey’s willingness to use res ipsa loquitur as an equitable tool to prevent injustice when the plaintiff cannot identify which defendant’s negligence caused the harm.22

3. The Plaintiff Did Not Contribute to the Accident

The third element requires the plaintiff to show that their own conduct did not contribute to the accident. This ensures that the inference of defendant negligence is not undermined by evidence that the plaintiff’s own negligence may have been the cause.23

In Pennsylvania and New Jersey, this element is generally straightforward in cases where the plaintiff was entirely passive—an unconscious surgical patient, a pedestrian struck by a falling object, or a passenger in a malfunctioning elevator. The challenge arises in cases where the plaintiff had some interaction with the instrumentality before the accident.

Courts have clarified that the third element does not require the plaintiff to prove they were completely uninvolved with the instrumentality—only that their conduct did not contribute to the specific failure or condition that caused the harm. A driver whose brakes fail is not disqualified from invoking res ipsa merely because they were operating the vehicle; the question is whether their driving contributed to the brake failure itself.

C. Application in Pennsylvania

Pennsylvania applies res ipsa loquitur under the Restatement (Second) of Torts § 328D. The doctrine requires: (1) the event is of a kind that ordinarily does not occur in the absence of negligence; (2) other responsible causes, including the conduct of the plaintiff and third persons, are sufficiently eliminated by the evidence; and (3) the indicated negligence is within the scope of the defendant’s duty to the plaintiff.24

Critically, in Pennsylvania, res ipsa loquitur creates an inference—not a presumption—of negligence. This distinction has significant procedural implications. An inference permits the jury to find negligence but does not require it to do so. The defendant retains the right to offer evidence of a non-negligent explanation, and if that evidence is credible, the jury may reject the res ipsa inference. The burden of persuasion remains with the plaintiff throughout.25

1. Medical Malpractice Applications

Pennsylvania courts have applied res ipsa loquitur most readily in medical malpractice cases involving retained foreign objects. When a surgical sponge, clamp, or instrument is discovered inside a patient’s body after surgery, the inference of negligence is compelling: such objects do not ordinarily remain in patients absent a failure to count instruments or inspect the surgical field. The plaintiff need not prove the specific moment at which the operating team erred—the retained object speaks for itself.26

The doctrine has also been applied to cases involving injuries to parts of the body outside the surgical field. In Jones v. Polyclinic Hospital (1981), the Pennsylvania Supreme Court confirmed that res ipsa loquitur may apply when a patient suffers injury to a body part remote from the treatment site, as such injuries are not expected outcomes of competent medical care.27

However, Pennsylvania courts have been more cautious in medical cases involving diagnostic judgment or complex treatment decisions. Res ipsa loquitur is most powerful when the negligence inference arises from a physical event—an object left behind, an instrument that broke, a patient positioned improperly—rather than from a claimed error in medical judgment.

2. Premises Liability Applications

Res ipsa loquitur appears frequently in Pennsylvania premises liability cases. Elevator and escalator malfunctions are classic examples: when a properly maintained elevator does not suddenly drop between floors, a free-fall incident creates a powerful inference that maintenance was deficient. Similar reasoning applies to collapsed ceilings, falling light fixtures, and structural failures in commercial buildings.

In the Philadelphia region, cases involving aging infrastructure in Center City office buildings, historic properties, and commercial facilities along City Avenue and the Main Line routinely raise res ipsa issues. Property owners and management companies often possess maintenance records, inspection reports, and service contracts that remain inaccessible to injured plaintiffs absent discovery—making res ipsa loquitur an important tool for surviving early dispositive motions.

3. Product Liability Applications

Pennsylvania courts have applied res ipsa loquitur in product liability cases where a product fails catastrophically under normal use conditions. When a tire blows out on a properly maintained vehicle, when a consumer appliance catches fire during ordinary operation, or when industrial equipment fails without warning, the doctrine permits an inference that the product was defectively manufactured or designed.28

The exclusive control element is often contested in product cases, as the product may pass through multiple hands before reaching the consumer. Pennsylvania courts have addressed this by focusing on whether the evidence sufficiently eliminates alternative causes—improper maintenance, misuse, or tampering by third parties—such that the defect most likely originated with the defendant.

D. Application in New Jersey

New Jersey recognizes res ipsa loquitur and applies the traditional three-element test: the occurrence is one that ordinarily does not happen without negligence; it was caused by an instrumentality within the defendant’s exclusive control; and no act or negligence on the plaintiff’s part contributed to the occurrence.29

New Jersey courts have been notably progressive in adapting the doctrine to modern circumstances, particularly regarding the exclusive control element.

1. The Anderson v. Somberg Innovation

The New Jersey Supreme Court’s decision in Anderson v. Somberg (1975) represents a significant doctrinal development. In that case, the plaintiff was injured during spinal surgery when a pituitary rongeur broke, leaving a metal fragment lodged in his spine. Multiple defendants—the surgeon, the hospital, the instrument manufacturer, and the distributor—each had some potential responsibility for the condition of the instrument.30

Rather than deny the plaintiff the benefit of res ipsa loquitur because he could not identify which defendant’s negligence caused the break, the court held that all defendants could be held to a burden of explanation. The practical effect was to shift the burden of production to the defendants collectively: each had to come forward with evidence explaining why they were not responsible, or face the inference of negligence.

Anderson reflects New Jersey’s equitable approach to res ipsa loquitur. When a plaintiff is clearly blameless, and when the harm-causing instrumentality passed through multiple potentially responsible parties, the doctrine operates to prevent all defendants from pointing fingers at each other while the injured plaintiff recovers nothing.

2. Medical Malpractice Applications

New Jersey applies res ipsa loquitur in medical malpractice cases under similar circumstances as Pennsylvania: retained foreign objects, injuries to non-treatment sites, and egregious departures from standard care that speak for themselves. In Buckelew v. Grossbard (1981), the New Jersey Supreme Court confirmed the availability of res ipsa in medical contexts while emphasizing that the plaintiff must still establish that the injury does not occur in the ordinary course of competent medical treatment.31

South Jersey medical malpractice cases, including those arising at major hospital systems in Camden, Cherry Hill, and the surrounding Burlington and Gloucester County communities, frequently involve res ipsa arguments where surgical complications cannot be explained by the inherent risks of the procedure.

3. Premises and Product Liability Applications

New Jersey courts have applied res ipsa loquitur broadly in premises liability cases—elevator and escalator failures, falling merchandise in retail stores, and structural collapses. The doctrine is particularly useful in cases involving casino properties in Atlantic City, commercial complexes along Route 70 and Route 73, and industrial facilities in the port and refinery areas of South Jersey.

In product liability cases, New Jersey has recognized that res ipsa may apply even when the product has passed through multiple hands, provided the evidence sufficiently narrows the source of the defect to the defendant. The Anderson approach extends naturally to product liability: when a product fails catastrophically, and multiple parties in the distribution chain could bear responsibility, the burden shifts to each defendant to explain why they were not at fault.32

E. Evidentiary Effect: Inference Versus Presumption

A critical distinction in res ipsa loquitur jurisprudence is whether the doctrine creates a permissible inference or a mandatory presumption of negligence. This distinction affects the procedural posture of the case, the burden of production, and the jury instructions.

1. Pennsylvania: Inference Only

Pennsylvania treats res ipsa loquitur as creating a permissible inference. When the elements are satisfied, the jury is entitled—but not required—to find that the defendant was negligent. The defendant may offer rebuttal evidence, and if the jury credits that evidence, it may decline to find negligence. The burden of persuasion never shifts to the defendant.33

From a practical standpoint, this means that Pennsylvania defendants facing a res ipsa claim can still prevail by offering a credible non-negligent explanation. The res ipsa instruction permits the jury to draw the inference, but does not compel it.

2. New Jersey: Conditional Presumption

New Jersey has at times described res ipsa loquitur as creating a presumption of negligence, though the presumption is rebuttable. When the plaintiff establishes the elements of res ipsa, a presumption of negligence arises, and the burden of production shifts to the defendant to offer evidence of due care or a non-negligent explanation.34

The practical effect of this distinction can be significant at summary judgment. In New Jersey, a plaintiff who establishes the res ipsa elements may be entitled to survive summary judgment even without direct evidence of negligence, because the presumption requires the defendant to come forward with contrary evidence. In Pennsylvania, the inference approach offers the plaintiff somewhat less procedural protection, though courts have recognized that a strong res ipsa case can still defeat summary judgment.

F. Limitations and Defenses

Res ipsa loquitur is a powerful doctrine, but it is not unlimited. Understanding its boundaries is essential for both plaintiff and defense counsel.

1. Rebuttal Evidence

The defendant may rebut the res ipsa inference by offering evidence of due care—testimony from employees about safety procedures, maintenance records, inspection reports, or expert opinions establishing that the defendant’s conduct met or exceeded industry standards. If the defendant produces sufficient rebuttal evidence, the inference may be weakened or eliminated, and the case proceeds as an ordinary negligence action.35

2. Alternative Explanations

The defendant may also defeat res ipsa loquitur by demonstrating plausible alternative causes for the accident—third-party tampering, unforeseeable intervening events, or plaintiff conduct that contributed to the harm. If the evidence shows that the accident could have occurred without negligence, the first element fails.

3. Res Ipsa Does Not Establish Causation

It is important to remember that res ipsa loquitur addresses only the breach element of a negligence claim. Even where the doctrine applies, the plaintiff must still prove causation (that the defendant’s negligence caused the harm) and damages. Res ipsa creates an inference that the defendant was negligent; it does not create an inference that the negligence caused any particular injury.

4. Statutory Limitations in Medical Malpractice

Both Pennsylvania and New Jersey have enacted medical malpractice statutes that affect the application of res ipsa loquitur in healthcare contexts. Pennsylvania’s MCARE Act requires expert testimony in most medical malpractice cases, which can interact with res ipsa arguments in complex ways. Counsel should carefully analyze whether expert testimony is required to establish that the alleged injury does not ordinarily occur absent negligence.

G. Practical Considerations for Philadelphia and South Jersey Practice

For personal injury attorneys practicing in the Philadelphia region and South Jersey, res ipsa loquitur provides an essential evidentiary tool in cases where direct proof of negligence is unavailable or incomplete.

1. Case Identification

At intake, counsel should consider whether the circumstances of the accident suggest a res ipsa claim. Classic res ipsa scenarios include: surgical injuries with retained foreign objects or damage to non-treatment sites; elevator, escalator, and HVAC system malfunctions in commercial buildings; product failures during normal use; falling objects from commercial or construction sites; and vehicle mechanical failures such as brake system or steering failures.

2. Preservation of Evidence

Because res ipsa cases often turn on demonstrating that the defendant controlled the instrumentality and that alternative causes have been eliminated, early evidence preservation is critical. Counsel should issue spoliation letters, seek emergency inspections or testing of failed equipment, and retain experts capable of examining the instrumentality before it is repaired, discarded, or altered.

3. Pleading and Motion Practice

Res ipsa loquitur should be specifically pleaded in the complaint where applicable. Pennsylvania and New Jersey courts have different procedural approaches to res ipsa issues at summary judgment, and counsel should be prepared to brief the applicability of the doctrine at both the pleading and dispositive motion stages.

4. Jury Instructions

Securing a proper res ipsa instruction is essential to trial success. Pennsylvania Standard Jury Instruction 13.30 and its New Jersey counterpart provide the framework for instructing juries on the permissible inference. Counsel should be prepared to argue for the instruction at the charge conference and to object if the instruction is improperly denied or misstated.

H. The Distinction Between Res Ipsa Loquitur and Negligence Per Se

Negligence per se and res ipsa loquitur serve related but distinct functions. Negligence per se applies when a specific statutory or regulatory standard has been violated and that violation can be identified. Res ipsa loquitur applies when the cause of the accident is unknown but the circumstances compel an inference of negligence.

In some cases, both doctrines may be argued in the alternative: a defendant may have violated a safety regulation (negligence per se), and even if the specific violation cannot be proven, the accident is of a type that does not ordinarily occur without negligence (res ipsa loquitur).

Competent counsel should evaluate every case for the potential application of both doctrines, as they provide independent pathways to establishing breach and may strengthen the case when pleaded together.

Conclusion

Breach of duty is the hinge on which most personal injury cases turn. Establishing that a defendant’s conduct fell below the applicable standard of care—whether measured by the reasonable person test, a specific statutory violation, or the very nature of the accident itself—requires careful analysis at every stage of litigation.

Res ipsa loquitur occupies a particularly important role in cases where the plaintiff lacks direct access to evidence of the defendant’s negligence. By permitting an inference of fault from the circumstances of the accident itself, the doctrine corrects for informational asymmetry and prevents defendants from escaping liability simply because they possess exclusive knowledge of what went wrong. In Pennsylvania and New Jersey, res ipsa loquitur remains a vital tool for personal injury practitioners, applicable across medical malpractice, premises liability, and product liability contexts.

In Pennsylvania and New Jersey personal injury practice, counsel should approach every case with three questions in mind: What standard of care governed the defendant’s conduct? Was that standard violated by a specific act or omission? And if the specific act cannot be identified, do the circumstances give rise to a res ipsa inference? Rigorous attention to these questions at intake and throughout litigation ensures that breach—often the most fact-intensive element of a negligence claim—is developed and presented to its fullest potential.

About Brian E. Fritz, Esquire

BRIAN E. FRITZ, ESQUIRE has represented seriously injured clients in Pennsylvania and New Jersey for almost 30 years. He has dedicated his practice to providing hope to the victims of others’ negligence and helping them navigate the challenges they now face. His primary focus includes: construction and premises liability; corporate direct liability for negligence; motor vehicle and trucking accidents; dangerous and defective products; unsafe modification of products and machinery; medical malpractice with an emphasis on birth-related injuries and cerebral palsy; exposing liability caused by disguised and hidden corporate decision-makers; establishing vicarious liability where companies have mislabeled workers as independent contractors; securing third-party liability for catastrophically injured workers whose recoveries would otherwise be limited to workers’ compensation; and providing second opinions to seriously injured clients whose cases were initially rejected on mistaken assumptions.

He is admitted to practice law in the State and Federal Courts of Pennsylvania and New Jersey and has handled cases in other jurisdictions on a pro hac vice basis. Based in Philadelphia, he represents clients throughout Pennsylvania and New Jersey. He is a member of the Board of Directors of the Philadelphia Trial Lawyers Association.

He has been recognized annually by his peer attorneys for inclusion in Super Lawyers and has been named one of the Top 100 Attorneys in Philadelphia in the Super Lawyers rankings. He has annually been selected for inclusion in The Best Lawyers in America. His case results have achieved annual national and state recognition by Best of the Bar, reserved for only the top 100 resolutions in any given year. He has annually received Martindale-Hubbell’s AV Preeminent rating for Legal Ability and Ethical Standards based on voting by peer attorneys and members of the Judiciary (Judicial Edition).

Disclaimer: This article is for educational and informational purposes only and does not constitute legal advice. Every case is unique, and the information presented here should not be relied upon as a substitute for consultation with a qualified attorney. If you have been injured, please contact a licensed personal injury attorney in your jurisdiction to discuss the specific facts and circumstances of your situation.