In a meatpacking facility just outside of Philadelphia, the routine hum of production was shattered by a single slip of the hand. Amidst the clatter of machinery and the swift movement of workers, a knife, dulled by use and neglected by oversight, slid from a co-worker's grasp. It arced through the air, ricocheting off the assembly line table. The blade struck a 33-year-old husband and father at the base of his neck. He bled to death on the factory floor.
Workers at the factory had previously filed reports about the dull knife and requested a replacement. However, management deferred those requests and assured the workers that it would be addressed later. The blade pierced the worker's left subclavian vein and slightly cut the artery, ultimately penetrating the left pleural space. Over half of his blood volume flooded his left lung and chest cavity, causing slow and painful asphyxiation. While the meatpacking facility provided personal protective equipment (PPE) — including hair nets, goggles, and masks — they proved inadequate to protect the worker’s critical areas.
The worker’s family sought counsel. However, as the case entered discovery, they sought out Aidan Carickhoff of Saltz Mongeluzzi Bendesky P.C. to help put together expert reports, enhance the theory of the case for trial, and get the case ready for trial or settlement. They identified two Defendants: the meatpacking facility’s parent company and the company that supplied the facility with PPE for its workers. Alongside co-counsel, Aidan delved deep into the case, determined to bring some justice to the decedent’s wife and young daughter.
The meatpacking facility’s parent company claimed workers’ compensation immunity as a shield, attempting to assign all fault to the facility. In addition, they denied awareness of any requests for additional PPE. However, their argument weakened during discovery when evidence of multiple knife-related injuries surfaced.
Next, the two Defendants questioned how it could have been foreseeable that a knife would slip from a worker’s hand, travel across the workspace, and injure the worker in the neck. In response, Aidan assembled a team of liability experts. He consulted with a workplace safety and OSHA expert to affirm the standards for safe working environments, as well as a human factors expert to explain how the accident was indeed foreseeable. The experts established that had the Defendants provided a simple metal mesh neck guard, the worker would still be alive.
Aidan also brought on an economist and a pathologist to discuss damages. The pathologist described what the final minutes of the worker’s life felt like, emphasizing his conscious pain and suffering leading to his death.
Despite the strong testimonies from his experts, Aidan knew he needed more to refute the Defendants’ claims that the worker’s death resulted from a freak accident. He enlisted the help of DK Global to visually demonstrate the preventability of the accident. Collaborating with Aidan and his experts, DK Global crafted an animated reconstruction of the events leading to the worker’s injury and the extent of his suffering.
The animation commenced with a view of the meatpacking facility, the decedent and his co-worker on either side of an assembly row with a conveyor belt in between. The knife was shown as it flew from the co-worker’s hand and struck the decedent in the neck. The narrative slowed at critical points to detail the environment, including a realistic depiction of the decedent at his workstation. The animation explained how he was wearing the PPE that the factory had given him but that his neck was unprotected. Next, the presentation paused at the moment the knife made contact, indicating the wound’s proximity to the brain and heart. An internal view showed the damage to the worker’s subclavian artery and pleural space, along with a visualization of 2.5 liters of blood — akin to five and a quarter water bottles — filling his left lung. The animation continued with an explanation of the worker’s final minutes, suffering from asphyxia and hypoxia, leading to hypotension, hemorrhagic shock, and, ultimately, death. Before concluding, a what-if scenario showcased how the knife would have deflected off the chain plate had the worker received proper protection.
The Defense attempted to file motions for summary judgment, but they were denied. They knew that Aidan and his team were ready to take the case to trial. After producing the Plaintiff’s expert liability and damage reports alongside the DK Global animation, the Defense quickly agreed to mediate. After a days of negotiations, both parties agreed to resolve the matter for $12,000,000.
Aidan Carickhoff of Saltz Mongeluzzi Bendesky P.C. specializes in advocating for catastrophically injured clients, securing millions in damages, notably a $15.5 million verdict in 2022 for a burn case. His practice focuses on trucking, medical malpractice, and workplace accidents. Aidan's legal journey began as a law clerk at SMB. It continued through impactful roles, including an intern at the United States Attorney's Office, where he won a federal case as a judicial extern for Judge Daniel J. Anders. A Temple University and Drexel University's Kline School of Law graduate, Aidan has been honored with awards for his trial advocacy, including induction into the Order of the Barristers and being named to the 2023 Pennsylvania Super Lawyers Rising Stars List. He also maintains an active pro bono practice.
