In Czajhowski v. City of Philadelphia, 537 F. Supp. 30, 33 (E.D. Pa. 1981), the plaintiff was injured when he fell on a staircase connecting his work-site to a parking garage. He brought a lawsuit against the city as the owner of the staircase, and the city filed a third-party complaint against the plaintiff's employer and its insurer. The federal court held that plaintiff's injuries did not arise out of his employer's operations because there was no connection to the injury and the operations of the employer. The court held further that it did not follow necessarily that his injuries were caused by his employer's acts or omissions or that they arose out of the employer's occupation and operation. Thus, the city was not covered under the employer's liability policy. 537 F. Supp. at 32.