An unusual ruling occurred in a $3 million settlement in which an 83-year-old woman was struck by a truck driver in an automobile accident. The case was scheduled to be tried before United States District Judge James M. Munley in the Federal Court for the Middle District of Pennsylvania.
Shortly before the trial was to begin, Judge Munley held that a truck driver’s guilty plea to a summary charge of failing to stop for a red light was admissible under federal law. Under Pennsylvania law, evidence of a guilty plea to summary traffic offenses is inadmissible at trial. Despite the state statute, Judge Munley ruled that the evidence was admissible, declaring that the state statute was procedural and therefore, inapplicable in federal court.
Judge Munley’s ruling radically departs from Pennsylvania case law. If followed, Judge Munley’s decision would only apply to federal court cases. However, it is unclear whether other federal judges would agree with his reasoning. Judge Munley’s holding is clearly out of the mainstream. Previously, the courts have held that evidence of summary offenses are inadmissible because they lack the same procedural safeguards as a civil jury trial. The ramifications of this ruling may frustrate the public policy of encouraging swift resolution of summary offenses.
In the same case, Judge Munley refused to dismiss claims for punitive damages. He ruled that if the jury found that the driver had entered into the intersection without even braking for an obvious red light, the jury could then conclude that the driver was recklessly indifferent. By the doctrine of vicarious liability, the driver’s conduct could be imputed to the trucking company and form the basis for punitive damages under Pennsylvania law.
Traditionally, federal court has been viewed as a more favorable jurisdiction for defendants. Hopefully, Judge Munley’s ruling is an anomaly and not a harbinger of decisions to be rendered in the federal court system.
Grosek v. Panther II Transportation Inc., U.S.D.C. (M.D. PA), 3:07-CV-01592