Kirk v. Schaeffler Group USA, Inc., No. 16-3417 (8th Cir. 2018)
Annotate this CaseThis appeal stemmed from litigation establishing that FAG Bearings was solely responsible for the TCE contamination in Silver Creek and Saginaw. Schaeffler Group subsequently acquired the facility. In this case, plaintiffs filed suit against Schaeffler, seeking compensatory and punitive damages for their daughter's autoimmune hepatitis (AIH). Plaintiffs alleged that Schaeffler's negligent release of TCE and failure to warn the community of TCE contamination caused their daughter to develop AIH. A jury found in favor of plaintiffs and the district court then denied Schaeffler's motions for judgments as a matter of law and a new trial. The Eighth Circuit reversed and remanded, holding that the district court abused its discretion in ruling that Schaeffler was judicially estopped to deny successor liability; because plaintiffs failed to prove successor liability, the district court erred in denying summary judgment dismissing Schaeffler as a separate defendant; the post-trial dismissal of Schaeffler because plaintiffs failed to prove successor liability did not affect the jury's finding that FAG Bearings was liable for negligently causing plaintiffs' AIH injury; remand for a partial new trial limited to the issue of FAG Bearings's punitive damages liability was appropriate; plaintiffs proved causation; and the evidence was sufficient to submit the failure to warn claim to the jury.
Court Description: Loken, Author, with Arnold and Shepherd, Circuit Judges] Civil case - Environmental Torts. In action alleging defendant FAG Bearing's negligent release of the chemical tricholorethylene (TCE) resulted in plaintiff developing autoimmune hepatitis, the district court erred in finding defendant Schaeffler's pleadings in actions in the U.S. Court of International Trade and federal district court in Connecticut judicially estopped Schaeffler from denying that it is liable as Fag Bearing's successor for FAG Bearing's pre-acquisition torts; as plaintiff failed to establish successor liability and the district court should have dismissed plaintiff's claims against Schaeffler: with respect to Fag Bearing's appeal, a partial new trial on punitive damages should be awarded as the punitive damage award did not distinguish how much each defendant owed, and plaintiff based her claims for punitive damages, at least in part, on alleged misconduct by Schaeffler; plaintiff submitted sufficient evidence of general causation to submit her claim; plaintiff's expert witnesses' testimony on specific causation was properly admitted; no error in admitting government reports stating the public health regulatory standards for TCE, where the court instructed the jury that exceeding those numbers "does not in and of itself establish causation in this case, though it may be considered by [the jury] in determining causation; the evidence in the case was sufficient to submit plaintiff's failure to warn claim to the jury; remanded to the district court with directions to dismiss the claims against Schaeffler and to conduct further proceedings on the punitive damages claims against Fag Bearing. Judge Shepherd, dissenting.
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