Law School Case Brief
Singleton v. Chevron United States, Inc. - 835 F. Supp. 2d 144 (E.D. La. 2011)
To survive a Rule 12(b)(6) motion to dismiss, the plaintiff must plead enough facts to state a claim to relief that is plausible on its face.
Plaintiff William Singleton worked at Evans Cooperage in Harvey, Louisiana in the 1950s, where he filled drums from barges with benzene, naphtha, and liquid asphalt. In 2009, Mr. Singleton was diagnosed with multiple myeloma. In April 2011, he learned that his illness could have been caused by his exposure to benzene-containing products. His exposure to benzene and benzene-containing products allegedly occurred daily over the course of his 42 years of work at various locations for various, unknown employers, while he labored as a painter, mechanic, construction worker, and drum filler. In May 2011, he filed a complaint in federal district court against defendants Chevron United States, Inc., Valspar Corporation ("Valspar") several other manufacturers of products containing benzene. The complaint alleged causes of action for negligence, strict liability, and Louisiana Products Liability Act ("LPLA") claims for damages associated with Mr. Singleton's contraction of myeloma. The complaint also alleged that Valspar failed to warn Mr. Singleton of the dangers of its benzene-containing products. Defendant Valspar filed a motion to dismiss the complaint for failure to meet the pleading requirements.
Did the complaint allege sufficient facts to avoid dismissal as to Valspar?
Valspar's motion to dismiss was denied. The court held that the Federal Rules allowed a plaintiff to plead legal theories of recovery in the alternative. Fed. R. Civ. P. 8(d)(2). Thus, Mr. Singleton's complaint could be read as stating two theories in the alternative: (1) strict liability and negligence claims if substantial benzene exposure occurred prior to the LPLA's enactment; and (2) LPLA claims if such exposure occurred after the LPLA's enactment. Drawing all well-pleaded facts as true, and drawing all reasonable inferences in favor of Mr. Singleton, the court held that the complaint overcame the Rule 8 pleading hurdle and stated a claim upon which relief can be granted.
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