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Keywords

lawsuitplaintiffdefendantdamagesnegligenceliabilityappealmotionstrict liabilitymotion to dismiss
plaintiffdefendantdamagesnegligenceliabilityappealmotionstrict liabilitymotion to dismiss

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Benoit v. Saint-Gobain Performance Plastics Corp., 959 F.3d 491, Prod.Liab.Rep. (CCH) P 20,897

Facts

Residents of the Village of Hoosick Falls, New York, filed lawsuits against Saint-Gobain and Honeywell, alleging that the companies' use of PFOA contaminated the local water supply, leading to personal injuries and property damage. The contamination was traced back to a manufacturing facility that had used PFOA since at least 1986, resulting in elevated levels of the chemical in the blood of many residents and significant health risks. The plaintiffs sought damages for personal injuries, property devaluation, and medical monitoring costs.

PFOA is a chemical used in making household and commercial products that resist heat and chemical reactions–such as teflon-coated cookware–and fabrics that repel oil, stains, grease, and water. Since at least as early as 1986, a manufacturing facility in the Village has used PFOA to create such products (the “Facility”). For a decade the Facility was owned by Honeywell; for the last two decades it has been owned by Saint-Gobain.

Issue

Whether the residents sufficiently stated claims for personal injury and property damage due to PFOA contamination, and whether the costs of medical monitoring could be awarded.

Whether the residents sufficiently stated claims for personal injury and property damage due to PFOA contamination, and whether the costs of medical monitoring could be awarded.

Rule

Under New York law, a plaintiff must demonstrate some injury or damage to recover in negligence or strict liability claims, and medical monitoring costs can be claimed as consequential damages if there is a physical injury.

Under New York law, a plaintiff must demonstrate some injury or damage to recover in negligence or strict liability claims, and medical monitoring costs can be claimed as consequential damages if there is a physical injury.

Analysis

The court found that the residents' allegations of elevated PFOA levels in their blood constituted sufficient personal injury under New York law, allowing them to pursue claims for medical monitoring. The court also ruled that property owners could recover damages for the diminished value of their homes and that owners of private wells had standing to pursue claims for private nuisance.

The court found that the residents' allegations of elevated PFOA levels in their blood constituted sufficient personal injury under New York law, allowing them to pursue claims for medical monitoring. The court also ruled that property owners could recover damages for the diminished value of their homes and that owners of private wells had standing to pursue claims for private nuisance.

Conclusion

The court affirmed the district court's decision to deny the defendants' motion to dismiss the claims related to personal injury and property damage, while dismissing the appeal regarding medical monitoring as not ripe for review.

The court affirmed the district court's decision to deny the defendants' motion to dismiss the claims related to personal injury and property damage, while dismissing the appeal regarding medical monitoring as not ripe for review.

Who won?

The residents of the Village prevailed in part, as the court allowed their claims for personal injury and property damage to proceed, rejecting the defendants' arguments that the claims were foreclosed by existing New York law.

The residents of the Village prevailed in part, as the court allowed their claims for personal injury and property damage to proceed, rejecting the defendants' arguments that the claims were foreclosed by existing New York law.

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