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The Pennsylvania Superior Court has reversed summary judgment granted in favor of Travelers Insurance Co., upending a ruling that a woman seeking benefits from the company failed to show that her post-traumatic stress disorder was the result of physical injuries she suffered in a car accident.

A three-judge panel consisting of Judges Jack Panella, Deborah Kunselman and Correale Stevens ruled in favor of plaintiff Carol Evans, remanding the case back to the Wayne County trial court.

While driving on I-476 on Dec. 14, 2017, the side of Evans' vehicle was struck by a tractor trailer attempting to change lanes, according to Stevens' precedential Dec. 4 opinion. The impact damaged the passenger side of her vehicle and forced her into the median.

After the accident, Evans experienced pain and dizziness that persisted for a week. She was diagnosed with a "'concussion, closed head injury, post-concussion syndrome, vertigo, post-traumatic vascular headac[h]es, post-traumatic vestibuloneuronitis, and/or post-traumatic stress disorder (PTSD),'" which could be permanent, according to Stevens.

Travelers paid coverage to Evans for her injuries sustained in the accident, but denied her claim for future coverage. The company maintained that PTSD did not constitute a bodily injury under Evans' policy.

Evans sued, but the trial court granted summary judgment in favor of Travelers, reasoning that she failed to show that her mental injuries stemmed from her physical injuries.

On appeal, Evans argued that her PTSD qualified as a bodily injury under her policy.

"While this court is bound by precedent in [Zerr v. Erie Insurance Exchange] which provides that physical manifestations of emotional distress cannot constitute 'bodily harm' as defined by the policy language at issue and the MVFRL, Zerr is distinguishable as Zerr's claim for coverage was based solely on emotional injury without any accompanying physical injury whereas it is undisputed that Evans suffered both physical injuries and emotional distress (including PTSD) in her accident," Stevens said.

"When reviewing the record in the light most favorable to Evans and resolving all doubts as to the existence of a genuine issue of material fact against Travelers, we reject the trial court's conclusion that summary judgment was warranted based on its finding that Evans 'failed to produce any evidence that her mental injuries resulted from her physical injuries,'" he added. "Evans has presented evidence to support her claim that her PTSD resulted from not only from experiencing the traumatic collision but also from her physical injuries which caused Evans continuous physical pain, affected her physical and emotional well-being, and required extensive medical testing, treatment, and rehabilitation over a period of several years. Evans asserted that she still was experiencing continuous neck pain on the day of her deposition, over three years after the accident."

Evans is represented by Thomas Foley Jr. of Foley Law in Scranton and Travelers is represented by Brooks Foland of Marshall Dennehey Warner Coleman & Goggin. Neither responded to requests for comment.