Mannella ex rel. Mannella v. Port Authority of Allegheny County

In Mannella ex rel. Mannella v. Port Authority of Allegheny County, 982 A.2d 130, 132 (Pa. Cmwlth. 2009) a bus driver was alleged to have negligently deployed a wheelchair ramp unevenly with the ground, which caused the plaintiff to fall out of his wheelchair, even though the ramp was not in motion. The Court once again noted that Pennsylvania courts have consistently held that to meet the vehicle exception, any injuries must be caused by a vehicle, or a part of a vehicle, which is in motion. Mannella, 982 A.2d at 134. Thus, while the wheelchair ramp in Mannella was a moving part of the bus, much like the kneeling system on a SEPTA bus, the vehicle exception did not apply because the plaintiff, like Royal, was injured when the bus and the ramp were not in motion. Id.