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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.

Injuries and Aftermath

Cummings was transported by ambulance to UPMC Mercy Hospital, where she was diagnosed with a dislocated shoulder. She later underwent shoulder surgery in June 2024, but continues to experience diminished range of motion and pain that limit her ability to drive or deliver freight—core functions of her business.

The complaint claims her shoulder and wrist injuries caused lasting impairment and financial loss, as she could no longer perform her regular work duties.

Legal Claims

Cummings accuses Rohrich Automotive Group and its affiliated entities of negligence for failing to maintain a safe workplace and for not warning her of the hazard. She also alleges vicarious liability, arguing the companies are responsible for the negligent actions of their employee.

The lawsuit seeks damages for medical expenses, lost earnings, diminished earning capacity, and pain and suffering.

Representation and Case Information

Cummings is represented by Mark D. Troyan of Robert Peirce & Associates PC.

Counsel information for Rohrich Automotive Group and its affiliates was not immediately available, and representatives for both sides did not respond to requests for comment on Friday.

The case is Cummings v. Rohrich Automotive Group et al., Case No. GD-25-010722, in the Court of Common Pleas for Allegheny County, Pennsylvania.