Pennsylvania Civil Caselaw Update Motion to Stay In Geronimo v. Commonwealth Env’t Sys., 2026 LX 183031 (Pa. Super. 2026), the court quashed an appeal and found denial of motion to stay proceedings was not a collateral order. D sought to stay proceedings in a tort case while the issue of whether D was a statutory employer for WC purposes was pending. The public policy prong of collateral order analysis was not met where D would be immune from tort liability as statutory employer. Tort immunity’s fundamental objective was not cost containment but rather for employers to pay injured employees; therefore, D’s litigation costs did not implicate an important public policy Forum Non Conveniens In Garcia v. Foley , 2026 LX 114896 (Pa. Super. 2026), the court reversed dismissal based on forum non conveniens , finding defendant did not provide specifics of how maintaining action in Philadelphia would inconvenience D. The injury occurred in NJ, Plaintiff was a resident of NJ and worked for a company based in NJ, the incident was investigated by the NJ Osha Office, and D Foley’s principal place of business was in NJ. Both Defendants were incorporated in DE. D Foley had opened a mailbox in Philadelphia to receive payments. D’s general manager supplied an affidavit generally asserting it would be burdensome for employee witnesses to travel to PA. To establish forum non conveniens D must provide the identity of witnesses and some notion of their testimony Additionally, P provided affidavits from witnesses averring it would not be an issue to travel to PA for travel. We hope this information has been helpful. Let us know if you have any questions, or would like to discuss further by contacting ALevy@LevyandLevyLaw.com, or calling (813) 259-5389 Do you like this caselaw update? Follow us! Levy & Levy, LLC Editor: Adam Levy, Esq. Writers: Daniel Baquerizo, Esq. & Zachary Williams, Esq. Unsubscribe