Betskoff v. Saia Motor Freight Line LLC et al

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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
KEVIN C. BETSKOFF 	*
Plaintiff, 	*
v. 	* 	Civil Case No. 1:25-cv-02306-JMC
SAIA MOTOR 	*
FREIGHT LINE, LLC, et al.
*
Defendants.
* * * * * * *
MEMORANDUM OPINION AND ORDER
Pro se Plaintiff Kevin Betskoff filed the instant case on July 16, 2025, against Defendants
Saia Motor Freight Line, LLC and Pedro V. Trinidad Holguin. (ECF No. 1). The Complaint raises
claims of negligence against Defendant Trinidad Holguin (“Count I”), vicarious liability against
Defendant Saia Motor Freight Line (“Count II”), and negligence against Defendant Saia Motor
Freight Line (“Count III”). (ECF No. 1). Presently before the Court is Defendants’ Motion for
Summary Judgment. (ECF No. 12). The Motion is fully briefed (ECF Nos. 12, 30, 33), and no
hearing is necessary. See Loc. R. 105.6 (D. Md. 2025). 	For the reasons set forth immediately
below, Defendants’ Motion for Summary Judgment (ECF No. 12) is GRANTED in part and
DENIED in part.
I. 	BACKGROUND
This case arises from a motor vehicle accident that occurred on January 4, 2024 at the
intersection between Main Street and 5 th Street in McSherrytown, Pennsylvania. (ECF Nos. 1 at 2,
12-7 at 2). Plaintiff is an individual who was driving a 2008 GMC Envoy during the accident.
(ECF No. 12-7 at 1). Defendant Tinidad Holguin was driving Defendant SAIA Motor Freight
LLC’s 2018 Volvo Fleet Truck. 	Id. Just before the accident, Defendant Trinidad Holguin was
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traveling westbound on Main Street. Id. at 2. An independent third party named Gary Linebaugh
would testify he was driving directly behind Defendant Holguin.1 (ECF No. 12-4 at 1). At the
same time, Plaintiff was driving at some distance behind Mr. Linebaugh. (ECF Nos. 12-7 at 2; 12-
4 at 1-2). Moreover, an independent third party named Francis Filemyr would testify he was he
was inside a nearby store. (ECF No. 30-2).
As Defendant Holguin approached the intersection between Main Street and 5 th Street, he
slowed to a stop. (ECF Nos. 1 at 3; 12-4 at 1). According to Plaintiff, Defendant Holguin “was
stopped in the middle of the street with its four-way flashers on.” (ECF No. 1 at 2). By contrast,
Defendants, the police report, and Mr. Linebaugh indicate that Defendant Holguin had his left turn
signal on when he slowed to a stop. 	(ECF Nos. 12-4 at 1; 12-5 at 2; 12-7 at 2). Defendants’
dashcam footage does not show whether the four-way flashers or left turn signal were on. 	See
(ECF No. 12-3). Plaintiff “came up behind the semi-truck heading west on his way toward
Gettysburg from Hanover.” 	(ECF No. 1 at 3). 	He “proceeded to go around the semi like one
would do with any other delivery truck stopped in the middle of the street.” Id. To do so, the dash-
cam footage makes clear that Plaintiff crossed over a double yellow line into the oncoming traffic
lane headed eastbound and attempted to drive back over the double yellow line into the westbound
traffic lane. (ECF No. 12-3). 2 Plaintiff asserts Defendant Holguin “turned left and accelerated
and maliciously hit [Plaintiff’s] passenger vehicle.” (ECF No. 1 at 3). The dashcam footage shows
that at the same time Defendant Holguin started to turn left onto 5th Street, Plaintiff came out from
behind him in the eastbound lane and attempted to veer back into the westbound lane, at which
1 There is some factual dispute as to when Mr. Linebaugh was driving behind Defendant Holguin. Plaintiff’s witness,
Mr. Francis Filemyr, signed an affidavit indicating he did not see the accident, but he saw the aftermath when walking
out of a nearby store. (ECF No. 30-2). He indicated that when he walked out of the store and the accident already
occurred, he watched Mr. Linebaugh “pull up[,] get out of his vehicle[,] and run directly to the cop and talk with him.”
Id.
2 Defendants’ dashcam footage is twelve seconds and on file with the Clerk of the Court.
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point the two vehicles collided. 	(ECF No. 12-3). Plaintiff asserts he did not believe Defendant
Holguin could have made a lawful left turn at the intersection between Main Street and 5 th Street
because 5 th Street is a “no trucks” street. (ECF No. 30 at 8). Plaintiff’s footage of the intersection
between Main Street and 5th Street confirms that there is a “no trucks” sign at the corner of the
intersection. (ECF No. 31-1).
Upon impact, Plaintiff asserts “the enormous size and weight of the tractor trailer…was
earth shattering” and Plaintiff “flipped up in the air and landed on the other side of the street on
the sidewalk.” Id. There exists some argument as to whether Plaintiff’s vehicle “flipped up into
the air” and landed on the other side of the street on the sidewalk.3 See (ECF No. 12-3). Careful
review of the dashcam footage shows the impact to Plaintiff’s vehicle caused its weight to shift to
the left side and lift the right-side tires off the ground before both vehicles stopped. Id. Plaintiff’s
car veered back over the double-yellow line and eventually stopped on the westbound side of Main
Street. (ECF No. 12-3). The chain of events occurred in roughly twelve seconds. Id.
Plaintiff asserts claims of negligence, vicarious liability, and negligent hiring, training, or
supervision. (ECF No. 1). In response, Defendants filed the present Motion for Summary
Judgment. (ECF No. 12). Plaintiff filed his Opposition Motion (ECF No. 30) on October 28, 2025.
On November 19, 2025, the Court identified a choice-of-law issue implicated by Plaintiff’s
3 Defendants seek attorneys fees and costs pursuant to Fed. R. Civ. P. 11 because “Plaintiff’s claims are knowingly
false and asserted, or maintained, in bad faith.” (ECF No. 12-2 at 7). In their summary judgment memorandum,
Defendants point to the allegation that Plaintiff flipped into the air and landed on the other side of the street as one
such false assertion. (ECF No. 12-2 at 6-7). The Court recognizes the misleading nature of Plaintiff’s phrasing when
compared to the dashcam footage, which depicts one or two tires lifted slightly off the ground immediately after
impact. Plaintiff indicates in his Response in Opposition to Defendants’ Motion for Summary Judgment, “The video
does show the right side of my vehicle seriously elevated from the impact and to me as the occupant, it felt like I was
in the air…I drafted my Complaint prior to my knowledge a video existed.” (ECF No. 30 at 8). At this juncture, the
Court trusts Plaintiff’s representation. The Court declines to find that he made the assertion in bad faith. There does
exist some support for Plaintiff’s representation that it felt like he was in the air in the dashcam footage. Moreover,
simply because Plaintiff did not drop his claims after Defense counsel recommended that he do so does not mean he
has pursued them in bad faith. Therefore, the Court declines to find a Rule 11 violation. See Fed. R. Civ. P. 11.
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arguments. 	Accordingly, the Court requested a Reply brief from Defendants on the issue of
whether Pennsylvania law governs, and if it does, how does comparative negligence impact
Defendants’ view of the case. (ECF No. 32). Defendants so replied on November 21, 2025 (ECF
No. 33).
II. 	STANDARD OF REVIEW
Defendants’ motion is styled as a motion for summary judgment under Federal Rule of
Civil Procedure 56. (ECF No. 12). Summary judgment “is a device to make possible the prompt
disposition of controversies if in essence there is no real dispute as to the salient facts.” Blakely v.
Wards, 738 F.3d 607, 611 (4th Cir. 2013), as amended (Oct. 22, 2013). Summary judgment is
improper when “the nonmoving party has not had the opportunity to discover information that is
essential to his opposition.” Harrods Ltd. v. Sixty Internet Domain Names, 302 F.3d 214, 246-47
(4th Cir. 2002); see also Evans v. Techs. Applications & Serv. Co., 80 F.3d 954, 961 (4th Cir. 1996)
(noting that summary judgment generally requires “adequate time for discovery” (quoting Celotex
Corp. v. Catrett, 477 U.S. 317, 322 (1986))).
All parties must be given some indication by the Court that it is treating a pleading filed in
respone to a complaint as one for summary judgment, “with the consequent right in the opposing
party to file counter affidavits or pursue reasonable discovery.” Gay v. Wall, 761 F.2d 175, 177 (4th
Cir. 1985). 	When the moving party styles its responsive motion as a motion for summary
judgment, as is the case here, and attaches additional materials to its motion, the non-moving party
is considered notified, and the Court may treat the motion as one for summary judgment. See
Laughlin v. Metropolitan Wash. Airports Auth., 149 F.3d 253, 260–61 (4th Cir. 1998).
“Ordinarily, summary judgment is inappropriate where the parties have not had an
opportunity for reasonable discovery.” Id.; see also Sol v. M&T Bank, No. 8:22-CV-02999-AAQ,
2024 WL 327086, at *4 (D. Md. Jan. 29, 2024) (collecting cases). 	Under such circumstances, it
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may be that the filing of such a motion “forces the non-moving party into a fencing match without
a sword or a mask.” McCray v. Md. Dep’t of Transp., Md. Transit Admin., 741 F.3d 480, 483 (4th
Cir. 2014). “Generally, if a party believes that summary judgment is procedurally inappropriate
because the party needs discovery to properly oppose the motion, the party should file a Rule 56(d)
affidavit informing the court of such.” 	Sol, 2024 WL 327086, at *4. However, “‘[e]ven in the
absence of a Rule 56(d) affidavit,’ a judge maintains ‘complete discretion’ to decline to convert a
motion to dismiss to one for summary judgment.” Id. (quoting Woodbury v. Victory Van Lines,
286 F. Supp. 3d 685, 693 (D. Md. 2017)). Plaintiff has provided notice in his Response that he
seeks extensive discovery including the opportunity to review Defendants’ GPS data, internal
policies, route information, and to take expert depositions. (ECF No. 30 at 6-7).
However, in light of the videos and documents already provided, the Court does not find
that accepting Defendant’s motion as a motion for summary judgment is premature at this time as
to all issues; It cannot be said that Plaintiff is forced into a fencing match without a sword or mask.
McCray, 741 F.3d at 483. Both parties attached videos, affidavits, and documents to their filings
for the Court’s consideration. (ECF Nos. 12-3; 12-4; 12-5; 12-6; 12-7; 30-1–13-12; 31-1). The
reports contain numerous records, including dashcam footage, video footage of the intersection
between Main Street and 5 th Street, multiple witness affidavits, map images, and more. At this
juncture, Plaintiff has provided reasonable evidence such that a summary judgment standard is
proper.
Accordingly, Rule 56 requires the Court to “grant summary judgment if the movant shows
that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a
matter of law.” A dispute as to a material fact “is genuine if the evidence is such that a reasonable
jury could return a verdict for the nonmoving party.” 	J.E. Dunn Const. Co. v. S.R.P. Dev. Ltd.
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P’ship, 115 F. Supp. 3d 593, 600 (D. Md. 2015) (quoting Anderson v. Liberty Lobby, Inc., 477 U.S.
242, 248 (1986)). 	A nonmoving party “opposing a properly supported motion for summary
judgment ‘may not rest upon the mere allegations or denials of [his] pleadings,’ but rather must
‘set forth specific facts showing that there is a genuine issue for trial.’” Bouchat v. Balt. Ravens
Football Club, Inc., 346 F.3d 514, 522 (4th Cir. 2003) (quoting Fed. R. Civ. P. 56(e)).
The Court is “required to view the facts and draw reasonable inferences in the light most
favorable to” the nonmoving party. Iko v. Shreve, 535 F.3d 225, 230 (4th Cir. 2008) (citing Scott
v. Harris, 550 U.S. 372, 377 (2007)). 	However, the Court must also “abide by the ‘affirmative
obligation of the trial judge to prevent factually unsupported claims and defenses from proceeding
to trial.’” 	Heckman v. Ryder Truck Rental, Inc., 962 F. Supp. 2d 792, 799–800 (D. Md. 2013)
(quoting Drewitt v. Pratt, 999 F.2d 774, 778–79 (4th Cir. 1993)). 	Consequently, a party cannot
create a genuine dispute of material fact through mere speculation or compilation of inferences.
See Deans v. CSX Transp., Inc., 152 F.3d 326, 330–31 (4th Cir. 1998).
III. 	ANALYSIS
Defendant points to several inconsistencies between Plaintiff’s allegations and the dashcam
footage in support of their request for summary judgment. See (ECF No. 12-2) (“The undisputed
evidence shows that the numerous allegations of Plaintiff’s Complaint are completely false and
Defendants…are therefore entitled to judgment as a matter of law.”). Plaintiff’s response addresses
a number of the factual issues Defendants raise and specifically argues that (1) Pennsylvania law
permits passing a double yellow line to circumvent an object in the road, (2) Defendant Trinidad
Holguin was negligent because he was making an illegal left turn onto a “no trucks” road, and (3)
Plaintiff believed Defendant was stopped because he knew trucks were not supposed to turn left
onto 5 th Street and thought his hazards were on. (ECF No. 30 at 8-9). In Defendants’ Reply, they
indicate the “no trucks” sign is irrelevant because Defendant was making a local delivery at the
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end of 5th Avenue. (ECF No. 33 at 1). Defendants further argue that Pennsylvania “no truck” signs
do not prevent a truck from making a local delivery to a destination beyond the sign. Id.
Accordingly, Defendants argue that “Plaintiff was the sole proximate cause of the accident, but
certainly at least 51%, which bars him from recovery either way.” Id.
A. 	Pennsylvania Law Governs Plaintiff’s Complaint.
There exists a conflict between Pennsylvania and Maryland law on the issue of negligence.
See Knight v. Avco Corp., No. 4:21-CV-00702, 2025 WL 2677533, at *4 (M.D.Pa. Sept. 18, 2025)
(discussing the difference between modified comparative negligence and the doctrine of
contributory negligence). To be sure, a federal court sitting in diversity applies the choice of law
rules of the forum state in which it sits. Klaxon Co. v. Stentor Elec. Mfg. Co., 313 U.S. 487, 496,
61 S.Ct. 1020, 85 L.Ed. 1477 (1941). Generally speaking, Maryland adheres to the lex doci delicti
rule in analyzing choice of law problems with respect to causes of action sounding in tort. Erie
Ins. Exch. v. Heffernan, 399 Md. 598, 925 A.2d 636, 648–49 (2007); Lab. Corp. of Am. v. Hood,
395 Md. 608, 911 A.2d 841, 844 (2006); Wells v. Liddy, 186 F.3d 505, 521 (4th Cir.1999). Under
the lex loci delicti choice of law principle, the substantive rights of the parties “are to be determined
by the law of the state in which the alleged tort took place.” Philip Morris Inc. v. Angeletti, 752
A.2d 200, 230 (Md. 2000) (quoting White v. King, 223 A.2d 763, 765 (Md. 1966)). “The tort is
complete only when the harm takes place, for this is the last event necessary to make the actor
liable for the tort.” Herbert F. Goodrich, Handbook of the Conflict of Laws § 93, at 263–64 (3d ed.
1949), quoted in Angeletti, 752 A.2d at 232. Where the events giving rise to a tort action occur in
more than one state, the court must apply “the law of the State where the injury—the last event
required to constitute the tort—occurred.” Heffernan, 925 A.2d at 649; see also Hood, 911 A.2d at
845. There exists a public policy exception, which permits the application of Maryland law if
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application of the law of the state in which the injury occurred violates a “clear, strong, and
important Maryland public policy.” 	Lab. Corp. of Am., 911 A.2d at 849 (applying the public
policy exception to lex loci delicti to tort causes of action). In the personal injury context, this
Court has considered policy issues including the parties’ ties to Maryland at the time the injury
occurred. 	Harvard v. Perdue Farms, Inc., 403 F. Supp. 2d 462, 466 (D. Md. 2005) (discussing
Hutzell v. Boyer, 252 Md. 227, 249 A.2d 449 (1969), in which Maryland law applied to a Virginia
workmen’s compensation dispute because both parties were Maryland residents returning to their
Maryland homes).
Lex loci delicti requires the application of Pennsylvania law to this tort action. Heffernan,
925 A.2d at 649. 	The accident took place in Pennsylvania. (ECF No. 1 at 2) (“On that day in
January, Plaintiff Betskoff was driving to Gettysburg from Hanover by way of PA route 116.”).
Further, Plaintiff is domiciled in Maryland and owns property in Pennsylvania. (ECF Nos. 1 at 2,
30 at 8). Defendant Trinidad Holguin is a Pennsylvania resident. (ECF No. 1 at 2). Review of the
record shows the parties have ties to Pennsylvania, Plaintiff was traveling out of Maryland to
Pennsylvania, and the accident occurred miles past the Maryland-Pennsylvania border. (ECF No.
1). 	There is no public policy reason that compels the Court to apply Maryland law. 	Thus,
Pennsylvania law governs this action. Heffernan, 925 A.2d at 649.
B. 	There Exists a Genuine Issue of Material Fact on the Issue of Comparative
Negligence.
Pennsylvania courts frequently reject invitations to grant summary judgment in motor
vehicle accidents in which there exist factual disputes regarding negligence and comparative
negligence as a matter of law. Doland v. Berrios, Civil No. 1:11-CV-1783, 2015 WL 433598, at
*5 (M.D.Pa. 2015); see also Burke v. TransAm Trucking, Inc., 605 F.Supp.2d 647, 649 (M.D.Pa.
2009); Sonnenberg v. Erie Metro. Transit Auth., 586 A.2d 1026, 1027 (1991); LeGrand v. Lincoln
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Lines, Inc, 384 A.2d 955, 956 (1978). To prevail on his negligence claim against Defendant
Trinidad Holguin, Plaintiff must show (1) a duty that the law recognizes, (2) a failure on the
defendant's part to comport to that duty, or a breach of it, (3) a causal connection between the
defendant's breach and the resulting injuries and (4) actual loss or damage that the plaintiff
suffered. Alcovitz v. Gulph Mills Tennis Club, Inc., 812 A.2d 1218, 1222 (Pa. 2002). With respect
to Count II (vicarious liability) against Defendant SAIA Motor Freight Line, Inc., “[u]nder
Pennsylvania law, to establish vicarious liability, a plaintiff must show a master-servant
relationship existed.” Ciotola v. Star Trans. & Trucking, LLC, 481 F. Supp. 3d 375, 390 (M.D. Pa.
2020). That much is not in dispute. Accordingly, if there exists a genuine issue of material fact
with respect to Defendant Trinidad Holguin’s alleged negligence, there exists a genuine issue of
material fact with respect to Defendant SAIA Motor Freight Line, Inc.’s liability. See id.
Defendants insist that as a matter of law Plaintiff’s own conduct was the sole proximate
cause of the accident because he crossed the double-yellow line to drive around Defendant
Trinidad Holguin. 	(ECF No. 33 at 1). That could very well be a jury’s view of the case. 	But
Plaintiff argues that Defendant Trinidad Holguin had his hazards on and therefore Plaintiff did not
act unreasonably by crossing the double-yellow line. (ECF No. 30 at 4). Indeed, 75 Pa. C.S.A. §
3301(a)(2) provides that a driver may cross onto the left-side of the roadway “[w]hen an
obstruction exists making it necessary to drive to the left of the center of the roadway, provided
the driver yields the right-of-way to all vehicles traveling in the proper direction upon the
unobstructed portion of the roadway.” 75 Pa. C.S.A. § 3301(a)(2). 	Moreover, Plaintiff asserts that
after years of driving on Main Street, he “had no expectation or belief that a professionally driven
commercial tractor trailer would be turning left or right onto 5th Street…[b]ecause no trucks are
allowed.” (ECF No. 30 at 8). As Defendants correctly point out, 75 Pa. C.S.A. § 4902 provides
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“vehicles making local deliveries or pickups may be exempted from restrictions on the use of
highways imposed under this subsection.” 75 Pa. C.S.A. § 4902. Accordingly, Defendants argue
that Defendant Trinidad Holguin, who was making a delivery on 5 th Street, made a lawful turn.
(ECF No. 33 at 1). That may be, and such lawfulness goes to the reasonableness of Defendant
Trinidad Holguin’s actions. At the same time, the reasonableness of Plaintiff’s actions in part rely
on the reasonableness of Plaintiff’s assumptions about the situation he was likely encountering.
Correspondingly, his knowledge that the street in question was a “no trucks” street in part goes to
the reasonableness of his judgment that the truck was not turning left.
In the Court’s view, whether it was Defendant Trinidad Holguin or Plaintiff who acted
unreasonably and caused the accident, at least in part depends on which light signals were active
before Plaintiff drove over the double-yellow line. Based on the record before it, there are varying
perspectives as to whether Defendant Trinidad Holguin engaged his left turn signal or whether he
had his hazards on. While the dashcam video does not show which lights were on before the
collision, Plaintiff’s video footage immediately after the accident depicts flashing hazard lights.
(ECF No. 31-1). Defendants included an affidavit from Mr. Gary Linebaugh, who would testify
he saw “the SAIA tractor-trailer approach[] the intersection with 5 th Street” and “slow[] down and
initiate[] its left turn signal before coming to a complete stop.” 	(ECF No. 12-4 at 1). 	Plaintiff
would testify he saw hazard lights activated, and Defendant Trinidad Holguin and Mr. Linebaugh
would testify otherwise. See (ECF No. 12-4). Moreover, Plaintiff seeks to impeach Mr.
Linebaugh’s testimony through that of Mr. Filemyr, who would testify that he saw Mr. Linebaugh
arrive well after the accident occurred. (ECF No. 30-2). It may well be the case that Defendant
Trinidad-Holguin and Mr. Linebaugh present credible testimony, a jury concludes Defendant
Trinidad Holguin had his left blinker on, and subsequently finds in favor of Defendants. However,
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based on the facts available for the Court’s review, a reasonable jury could reject Mr. Linebaugh’s
testimony in favor of Plaintiff’s and Mr. Filemyr’s and conclude that Defendant Trinidad Holguin
slowed to a stop with his hazards on. Therefore, in consideration of the existing factual dispute,
the Court cannot conclude that Plaintiff’s negligence claim fails as a matter of law. Doland, 2015
WL 433598, at *5; see also Burke, 605 F.Supp.2d at 649. Defendant’s Motion for Summary
Judgment with respect to Counts I and II is DENIED.
C. 	Even taken in the light most favorable to Plaintiff, Count III fails as a Matter
of Law
“Negligent screening, hiring, training, supervision, or retaining holds an employer directly
liable for its own negligent failure to protect a plaintiff from an employee that it knows, or has
reason to known, is likely to cause injury.” Adams v. U.S. Airways Group, Inc., 978 F. Supp. 2d
485, 496 (E.D. Pa. 2013) (citing Restatement (Second) of Torts § 317). The Third Circuit Court of
Appeals made clear that such claims are “specifically predicated upon two duties of an employer:
the duty to reasonably monitor and control the activities of an employee, and the duty to abstain
from hiring an employee and placing that employee in a situation where the employee will harm a
third party.” Belmont v. MB Inv. Partners, Inc., 708 F.3d 470, 487-88 (3rd Cir. 2013). Importantly,
unlike a vicarious liability claim, “[a] claim for negligent supervision provides a remedy for
injuries to third parties who would otherwise be foreclosed from recovery under the principal-
agent doctrine of respondeat superior because the wrongful acts of employees in these cases are
likely to be outside the scope of employment or not in furtherance of the principal's business.” Id.
at 489.
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At the same time, where, as here, both vicarious liability and negligent hiring/retention are
brought against an employer, both cannot proceed where, as here, SAIA does not dispute4
Defendant Trinidad Holguin’s employment status. 	In Holben v. Midwest Emery Freight System,
Inc., 252 F.Supp. 1224, 1224-25 (W.D.Pa. 1981), the Western District of Pennsylvania clarified
that “[n]othing can be gained from it when the defendant employer has admitted the agency of the
driver, and to permit the action to proceed on both counts would allow the introduction of evidence
of prior accidents of the driver, highly prejudicial, irrelevant and inadmissible in the cause of action
based on the imputed negligence of the driver. Id. at 1224-25.
It is true that since Holben, other Pennsylvania courts have denied summary judgment
motions when a punitive damages claim is viable. E.g., Sterner v. Titus Transp., LP, Civ. No. 10-
2027, 2013 WL 6506591, at *3-4 (M.D. Pa. Dec. 12, 2013); see also Fields v. Lebert, CIVIL
ACTION NO. 24-447, 2025 WL 2404247, at *5 (E.D.Pa. Aug. 19, 2025). Therefore, “where in a
negligent entrustment case the plaintiff alleges that defendant's action was indifferent to the
consequences and claims punitive damages, this becomes an important additional element to his
case.” Holben, 252 F.Supp. at 1225. Thus, the Court first considers the issue of punitive damages.
In Pennsylvania, punitive damages “are awarded only for outrageous conduct, that is, for
acts done with a bad motive or with a reckless indifference to the interests of others.” SHV Coal,
Inc. v. Cont'l Grain Co., 526 Pa. 489, 587 A.2d 702, 705 (Pa.1991). Indeed, punitive damages “are
not justified where the defendant’s mental state rises to no more than gross negligence.” Id. To
prevail on a punitive damages claim, a plaintiff must prove (1) a defendant had a subjective
appreciation of the risk of harm to which the plaintiff was exposed and (2) he acted, or failed to
act in conscious disregard of that risk. 	See Calhoun v. Van Loon, No. 3:12–CV–458, 2014 WL
4 Defendants would testify Defendant Trinidad Holguin was acting in the scope of his employment, as he was making
a delivery when the accident occurred. See (ECF Nos. 12-5 at 2, 4; 33 at 1-2).
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3428876, at *2 (M.D.Pa. July 11, 2014). “Pennsylvania cases have adopted a very strict
interpretation of reckless indifference to the rights of others” Burke v. Maassen, 904 F.2d 178, 181
(3d Cir.1990) (cleaned up). In Holben v. Midwest Emery Freight System, Inc., the plaintiff’s
punitive damages claim survived summary judgment because there was evidence that the
defendant employer “was aware of its employee’s driving record, including several accidents,
traffic violations, and a discharge by a prior employee because of his accident record while
employed by it.” 	Holben, 252 F.Supp. at 1225. The court there reasoned that the defendant’s
evidence of certain investigative hiring efforts “may ultimately be sufficient in the mind of the trier
of fact to disprove both the claims of negligent entrustment and reckless indifference, [but] they
do not remove these issues from trial.” Id.
The same cannot be said here. 	Plaintiff seeks punitive damages, but there exists no
evidence showing Defendant SAIA Motor Freight Line, Inc. acted with “such indifference to the
consequences as to merit punitive damages.” Id. After careful review of the Complaint, Plaintiff
failed to plead the same. See generally (ECF No. 1). Under Pennsylvania’s strict interpretation of
reckless indifference to the rights of others, it cannot be said that there exists a genuine issue of
material fact as to whether Defendant SAIA Motor Freight Line, Inc. acted with reckless
indifference when it retained Defendant Trinidad Holguin. To the contrary, Defendants offered
evidence that he has a clean driving record and has never been in an accident before. (ECF No. 12-
5 at 1). Plaintiff has neither raised allegations in the complaint nor offered evidence to the contrary.
See (ECF Nos. 1, 30). Therefore, under Pennsylvania’s high bar for punitive damages, Defendant’s
Motion for Summary Judgment is GRANTED with respect to Count III and as to any claim aginast
SAIA for punitive damages.
IV. 	CONCLUSION
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For the reasons stated, Defendants’ Motion for Summary Judgment (ECF No. 12) is hereby
GRANTED in part and DENIED in part. With respect to Counts I and II, Defendants’ Motion for
Summary Judgment is DENIED without prejudice. With respect to Count III, Defendants’ Motion
for Summary Judgment is GRANTED. 	Defendants are directed to file an answer to Plaintiff’s
Amended Complaint within fourteen (14) days of the entry of this Order.
Date: November 25, 2025 	/s/
J. Mark Coulson
United States Magistrate Judge
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