Robinson v. Mine Safety Appliances Co., No. 14-2961 (8th Cir. 2015)
Annotate this CaseRobinson worked as a sandblaster for decades. Sand sometimes breaks down into silica dust, which, if inhaled, can cause the incurable lung disease silicosis. By 1997, Robinson knew that sandblasting could cause silicosis. In 1998, he saw Dr. Ragland, after coughing up white mucus. In 2002, he went to Ragland for bronchitis. In 2007, Robinson went to an emergency room for chest pain. The report listed three possibilities: tuberculosis, sarcoidosis, or a pneumonoconiosis disease (e.g., silicosis) caused by inhaling dusts. Medical notes reflect an “impression” of “silicosis related to sandblasting.” Robinson saw a respiratory specialist, to “follow up his silicosis.” Ridgeway’s notes, shared with Ragland, list an “impression” of silicosis. In 2011 Ridgeway biopsied Robinson’s lung. According to Robinson, Ridgeway then first told him he had silicosis. In 2012, Robinson sued entities that “sold, designed, manufactured, or marketed . . . silica related products.” The Eighth Circuit affirmed that the suit was time-barred. Arkansas’s three-year limitations period for product-liability actions applied, subject to a discovery rule: the period “does not commence running until the plaintiff knew or, by the exercise of reasonable diligence, should have discovered the causal connection between the product and the injuries suffered.” Robinson should have known in 2007 that silica-related products had damaged his lungs.
Court Description: Gruender, Author, with Wollman, Circuit Judge, and Gritzner, District Judge] Civil case - Products liability. Plaintiff's 2012 suit against defendants who manufactured or sold silica-related products was barred by Arkansas's three-year statute of limitations for products liability actions, as given his work history, knowledge of silicosis and physical symptoms, appellant reasonably should have known in 2007 that silica-related products had damaged his lungs.
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