Swartz v. Hillton Twp. Vol. Fire Co

In Swartz v. Hillton Twp. Vol. Fire Co., 721 A.2d 819 (Pa. Cmwlth. 1998), Ruth Swartz was seriously injured after a valve attached to the bumper of a fire truck fell onto the traveled roadway while the fire truck was driving along the road. A motorist drove over the valve and lost control of his vehicle, causing him to collide with Swartz's vehicle. Our court held that although the valve fell into the roadway while the fire truck was in motion, "Swartz's injuries were not caused by the movement of either the fire engine or its parts.... Once the valve fell from the fire engine, the valve remained a stationary object in the road for an undetermined amount of time before being struck by the other motorist's car. Ruth Swartz was then injured when the other vehicle crossed lanes and collided with her vehicle." Id. at 822.