Swartz v. Hilltown Township Volunteer Fire Co

In Swartz v. Hilltown Township Volunteer Fire Co., 721 A.2d 819 (Pa. Cmwlth. 1998), the Court held that the vehicle exception did not apply when a five-way diverter valve fell off the back of a Township fire engine causing a car accident. Stated otherwise, the movement of a vehicle, or its parts, that is merely ancillary to that vehicle's normal operation does not trigger the motor vehicle exception. Swartz, 721 A.2d at 822.