The state Superior Court has reversed a Lancaster County trial judge's grant of summary judgment in favor of Mutual Benefit Insurance Co. and against two property owners, reasoning that the judge erred in relying on the state Supreme Court's 1967 ruling in Pennsylvania Manufacturers' Association Insurance v. Aetna Casualty and Surety Insurance, rather than on the plain language of the policy at issue.

The court in PMA found that a company that qualified as an insured under an omnibus clause in another company's automobile insurance policy was an employer for coverage purposes and was therefore precluded from coverage under the employers' liability exclusion.