Slip and Fall Injury After Exiting a Bus In Pennsylvania

In Gielarowski v. Port Authority of Allegheny County, 159 Pa. Commw. 214, 632 A.2d 1054 (Pa. Cmwlth. 1993), a plaintiff slipped and fell and was injured after he exited a Port Authority bus. He sued for first-party benefits under the Motor Vehicle Financial Responsibility Law (MVFRL) (limited to medical benefits, income loss benefits, accidental death benefits and funeral benefits) and argued that a governmental agency that is self-insured for first-party benefits for its vehicles is stripped of immunity defenses. The trial court held that the action was barred by sovereign immunity and that the plaintiff failed to provide notice of the claim within six months as required by statute. The Court affirmed.