In QBE Ins. Corp. v. M & S Landis Corp, 2007 WL 60995 (Pa.Super., 2007), the administrator of a nightclub patron's estate brought a wrongful-death and survival action against the owner of the nightclub and eight bouncers. The administrator contended that the bouncers wrestled the patron down the stairs in a choke hold, and then threw him face down on the ground at the direction of the nightclub's management. They then laid on top of him, restricting his ability to breathe and causing his death.