A delivery driver has filed a negligence lawsuit against Rohrich Automotive Group and its affiliates, claiming she suffered severe shoulder injuries after a warehouse employee allegedly moved a loading dock plate without warning, causing her to fall into a gap during a delivery in Pittsburgh last year.
According to the complaint, filed Wednesday in the Allegheny County Court of Common Pleas and made public Thursday, Shaun Cummings—owner of Ohio-based Kultured Beauty LLC, a moving and freight delivery company—was unloading auto parts at the Rohrich Parts Center on November 17, 2023, when the accident occurred.
Incident Details
Cummings alleges she had properly positioned a dock plate to bridge the space between her delivery truck and the warehouse loading dock before entering her truck to begin unloading. While her back was turned, a Rohrich Automotive Group employee allegedly removed the dock plate without notifying her.
“Plaintiff alleges, upon information and belief, that the Rohrich employee failed to warn her that the dock plate had been removed and that a gap had been created,” the complaint states. “Plaintiff believes that video surveillance of the incident shows that an employee of Rohrich removed the dock plate.”
Unaware of the change, Cummings turned around to exit her truck, stepping into the now-exposed gap. She fell, attempting to catch herself by grabbing the dock with her right arm, but fell to the ground, dislocating her shoulder.
The lawsuit asserts that moving the dock plate without warning violates Occupational Safety and Health Administration (OSHA) safety standards, which require that dock plates be secured and that no employee or visitor is placed in harm’s way during loading or unloading operations.
