Pennfield Corporation v. Meadow Valley Electric, Inc.
Superior Court of Pennsylvania
604 A.2d 1082 (1992)
Meadow Valley Electric (MVE) (defendant) maintained the electrical ventilation system for Pennfield Corporation's (plaintiff's) pig enclosure, which malfunctioned and asphyxiated 1,537 pigs; Pennfield sued MVE for negligence, and MVE sought to join electrical cable suppliers York Electrical Supply and Tri-State Electrical Supply, alleging the ventilation failure was caused by defective cable supplied by one or the other (the cables from each supplier being indistinguishable), without alleging both suppliers' conduct was tortious. York objected that MVE could not maintain a negligence claim without identifying which specific supplier actually caused the defect, and the trial court dismissed MVE's complaint against York; MVE appealed.
Whether the alternative-liability doctrine, shifting the burden of disproving causation onto multiple defendants, applies when the plaintiff (or third-party plaintiff) alleges only one of two possible suppliers' conduct was actually tortious, rather than alleging both engaged in wrongful conduct.