Henley v. FMC Corporation

20 F. App'x 108
CourtCourt of Appeals for the Fourth Circuit
DecidedJune 29, 2001
Docket00-1605
StatusUnpublished
Cited by6 cases

This text of 20 F. App'x 108 (Henley v. FMC Corporation) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Henley v. FMC Corporation, 20 F. App'x 108 (4th Cir. 2001).

Opinion

OPINION

PER CURIAM.

Debra Lynn Henley, individually and on behalf of her minor child, is a named representative in a class action in which the named class members filed suit in the United States District Court for the Southern District of West Virginia against FMC Corporation, alleging that they were injured by a cloud of phosporous trichloride that escaped an FMC chemical plant because of a gas leak. There were a total of *111 forty named representatives, 1 but after the class was divided into sub-classes, only fourteen were chosen as initial “trial plaintiffs” (the trial plaintiffs are collectively referred to as the Appellants). 2 After the jury awarded the Appellants compensatory and punitive damages, the district court granted a new trial based upon newly discovered evidence in the form of affidavits submitted by a witness who had been unavailable at trial. The Appellants now appeal the jury’s unfavorable verdict at the second trial, arguing that the district court erred in granting a new trial based upon the new affidavits, that the district court erred in concluding that the jury’s findings at the second trial are binding on the entire class, and that the district court erred in refusing to grant the Appellants a new trial following the second jury verdict. We conclude that the district court did not abuse its discretion in granting the second trial based upon newly discovered evidence. However, because at the second trial, the district court erred in fading to instruct the jury as to the bifurcation of the class-wide issue of causation from the individual issues of causation and damages, we conclude that yet another trial is necessary. We therefore affirm in part, reverse in part, and remand for further proceedings consistent with this opinion.

I.

On December 5, 1995, FMC’s chloride unit ruptured at its Nitro, West Virginia plant and released a hazardous cloud. The rupture was caused, at least in part, by failures in FMC’s monitoring devices and safety valves. After the release of the cloud, hundreds of people alleged that they had suffered injuries as a result of cloud exposure. On December 11, 1995, the Appellants sued FMC in the United States District Court for the Southern District of West Virginia. The Appellants sought class certification, with a proposed class consisting of “all persons or other entities, who or which sustained damage as a result of the leak of toxic gas from the Nitro, West Virginia facility of [Defendant] on December 5, 1995.” (J.A. at 226 (alteration in original).) On January 22, 1997, the district court issued a memorandum opinion and order granting a conditional certification of the class pursuant to Federal Rules of Civil Procedure 23(b)(3) and (c)(4)(A). 3

On March 5, 1998, the district court issued a case management order certifying six subclasses. 4 On March 13, 1998, the parties agreed to a joint plan under which each side would select an equal number of named representatives to serve as “trial plaintiffs .” (J.A. at 322.) On September *112 18, 1998, the first trial began with these fourteen representatives. The case was to be tried in two phases. In the first phase of the trial, the jury was to decide the class-wide issues of negligence and strict liability, as well as compensatory damages for the Appellants. The same jury would decide whether FMC’s conduct warranted punitive damages, which would be awarded in a single lump sum and then allocated, after adjudication or settlement of the individual claims, to all class members successfully proving actual damages stemming from the cloud. 5 The second phase of trial, “if necessary, would involve the disposition of individual claims of class members,” under which “[rjesolution [could] occur either by a series of mini-trials or disposition by a special master or mediator.” (Case Management Order of Sept. 4, 1998.) “If mini-trials [were to be used], the juries would be instructed as to the findings on common issues of the original jury.” (Id.)

At trial, FMC offered the testimony of its expert, Dr. Tony Eggleston, to show that the wind direction had carried the cloud across a largely uninhabited portion of the state. Eggleston based his opinion partially upon data gathered from a wind monitoring station run by the West Virginia Division of Environmental Protection (DEP). Charles Spann worked at that DEP station and Eggleston spoke with Spann before trial to confirm the accuracy of the data and the equipment used to gather that data." Spann was listed as a potential witness by both parties, but Spann was unavailable to testify because he was out of the country. 6

After Eggleston was excused by the district court and left town, the Appellants offered Steve Drake as a rebuttal witness to undermine Eggleston’s testimony. Drake was an employee of the DEP who was supervised by Spann. The Appellants had not previously disclosed Drake as a witness to either the district court or to FMC, and Drake had not been a subject of discovery. Although counsel for the Appellants represented that Drake had been discovered as a witness only on the previous day, the district court found that counsel actually had become aware of Drake before Eggleston left town. Nevertheless, Appellants’ counsel did not disclose Drake as a witness until after Eggleston was no longer available. The Appellants offered Drake’s testimony to show that the equipment upon which Eggleston relied was defective and therefore that Eggleston’s expert opinion was flawed.

The district court was concerned about the surprise nature of Drake’s testimony, as well as the questionable manner in which the Appellants had proceeded in offering the testimony:

[Y]ou had access to this type of information as early as Wednesday. You went ahead and crossed the witness Eggle-ston with a view toward coming up with refuting type of information, and then you disclosed to counsel, once Dr. Eg-gleston left the stand and left the jurisdiction, that you had a witness who would significantly attack or erode the effect of Mr. or Dr. Eggleston’s testimony. So we get back to that point, which is one that the Court remains concerned about, and that is, as everyone here concedes, trials like this are not to be *113 conducted by way of ambush but rather following the rules of discovery.

(J.A. at 2247.) After hearing Drake’s testimony outside of the presence of the jury, the district court noted the “immense probative value” of the evidence and its “possible real significance as to the validity of the testimony of some of the witnesses.” (J.A. at 2281.) The district court also continued to express reservations as to whether to admit the evidence:

[T]he evidence comes about and comes before this Court and a jury ... under highly questionable circumstances....

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Bluebook (online)
20 F. App'x 108, Counsel Stack Legal Research, https://law.counselstack.com/opinion/henley-v-fmc-corporation-ca4-2001.