Barron v. Martin-Marietta Corp.

Brief Fact Summary.

Plaintiffs worked for Defendant corporation when they suffered severe harm after loading missile canisters, manufactured by Defendant, into a magazine storage at a weapons station. Plaintiffs complained that fumes from the canisters caused their injuries. An investigation suggested that Defendant’s canisters may have caused Plaintiffs injuries. Plaintiffs brought suit against Defendant.

Synopsis of Rule of Law.

In a negligence claim, a plaintiff does not meet the necessary element of causation by showing that a defendant might have caused the harm suffered by the plaintiff.

Facts.

Plaintiffs, morning and afternoon workers (Workers) at Martin-Marietta Corporation (MMC) (Defendant), loaded missile canisters into magazine storage at a weapons station in California. Half of the missiles were manufactured by MMC and the other half by another company, IMI. The Workers complained of smelling fumes leaking from the canisters and alleged that they suffered from physical and psychological harm because of loading the canisters. An investigation by the U.S. Navy advised that the Workers were likely exposed to toluene, which was a chemical present in the canisters. The Navy’ s investigation also found that the canisters that MMC manufactured had low levels of the chemical toluene. Workers brought a negligence suit against MMC alleging that the canisters manufactured by MMC caused their injuries because they exposed to the toluene. MMC, in its motion of summary judgment, argued that the Workers failed to show that MMC was the cause of the injuries they suffered.

Issue.

Whether a plaintiff meets the causation requirement of a negligence claim when he or she makes a showing that a defendant might have caused plaintiff’s harm.

Held.

No. A plaintiff does not meet the causation requirement of a negligence claim by making a showing that a defendant might have caused the harm. A plaintiff must show that a defendant’s negligence actually caused the plaintiff’s harm. On the other hand, when the plaintiff does not know of the defendant’s identity, the burden shifts to the defendant. In this case, the morning Workers at MMC provided sufficient evidence that showed that MMC was the cause of their injuries. This is because the morning workers were exposed to MMC canister, only, and one could reasonably infer that MMC canister caused the morning Workers injuries. Contrarily, the afternoon Workers were exposed to six different canisters three of which were owned by another company, IMI. Hence, the afternoon Workers were only able to show that MMC canisters might have been the cause of their injuries. The afternoon Workers were only able to show that MMC canisters had a low-level of toluene. Additionally, the afternoon Workers offered no expert testimony to show that exposure of toluene from the MMC canisters would have caused their injuries versus the canisters manufactured by IMI. Therefore, the morning Workers demonstrated the causation by MMC and the afternoon Workers did not. Motion of summary judgement against the afternoon Workers was granted.

Discussion.

To make a successful negligence claim, plaintiff must make a sufficient showing of the causation element.