The Pennsylvania Supreme Court has held that the exclusive remedy provision of the Pennsylvania Workmen's Compensation Act does not bar an employee of a medical services provider from bringing a common law tort action against his employer when the employee is injured while obtaining treatment in the employer's facility.
Tatrai v. Presbyterian University Hospital, 497 Pa. 247, 439 A.2d 1162 (1982).
Gretchen L. Kelly,
Pennsylvania Workmen's Compensation Act - Exclusivity Provision - Permissibility of Common Law Action Against Employer,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol21/iss2/18