In re: East Palestine Train Derailment

CourtDistrict Court, N.D. Ohio
DecidedMay 1, 2026
Docket4:23-cv-00242
StatusUnknown

This text of In re: East Palestine Train Derailment (In re: East Palestine Train Derailment) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re: East Palestine Train Derailment, (N.D. Ohio 2026).

Opinion

PEARSON, J. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

IN RE: EAST PALESTINE TRAIN ) DERAILMENT ) CASE NO. 4:23CV0242 ) ) JUDGE BENITA Y. PEARSON ) ) MEMORANDUM OF OPINION ) AND ORDER ) [Resolving ECF Nos. 993 and 994]

On September 25, 2025, Attorney Jedidiah I. Bressman, on behalf of 144 class members,' filed a Motion for Relief From Judgment Pursuant to Fed. R. Civ. P. 60(b)(3), (b)(6), and (d)(3) (ECF No. 993). Four (4) days later, Attorney Bressman, on behalf of 52 class members,’ filed a second Motion for Relief From Judgment Pursuant to Fed. R. Civ. P. 60(b)(3), (b)(6), and □□□□ (ECF No. 994). The two motions make similar substantive arguments. These class members move the Court for relief from the Order (ECF No. 557) granting Plaintiffs’ Motion for Final Approval of Settlement, entered on September 27, 2024. ECF No. 557 approved the Class

' A four-page list of these class members whom opted in for the “Voluntary Exposure Supplement” or “Personal Injury Payment” is attached as Exhibit 1 (ECF No. 993-2). The list provides names with no other identifying information. One of the class members, Tamara Lynn Freeze, is one of the five objectors that appealed in Jn Re East Palestine Train Derailment, 158 F 4th 704 (6th Cir. 2025) (ECF No. 1019), cert. denied, No. 25-929, 2026 WL 568332 (March 2, 2026) (Mem) (ECF No. 1049). > A two-page list of these class members whom also opted in for the voluntary exposure personal injury supplement is attached as Exhibit 1 (ECF No. 994-2). This list also provides names with no other identifying information.

(4:23CV0242) Action Settlement Agreement (ECF No. 452-2). That Order, in relevant part, allowed for class members to voluntarily participate in a fund designed to compensate those class members presumptively exposed to toxins as a result of the February 2023 train derailment. The “Voluntary Exposure Supplement” or “Personal Injury Payment” is the only category of payment Movants raise an issue with in the within motions, as they now seek to be released from the voluntary contract they signed in exchange for such payment. They ask the Court to “[p]rohibit enforcement of Personal Injury opt-ins and releases signed by movants.” ECF No. 993-1 at PagelD #: 68936.’ Thirteen (13) of the Movants seek a rescission of the personal injury releases that they voluntarily and individually signed in exchange for compensation. For the reasons that follow, the Court finds that the Movants have not established a basis for relief from judgment under Rule 60(b)(3), (b)(6) or (d)(3). 1. Class Counsel reviewed over a million documents in discovery, including information about environmental contamination and cleanup. See Declaration of M. Elizabeth Graham (ECF No. 518-2) at PageID #: 10949, § 27; Declaration of Seth A. Katz (ECF No. 518-3) at PageID #: 11060, □ 27. They facilitated a comprehensive environmental sampling and testing program designed to collect data, on which Plaintiffs’ experts relied in determining chemical exposure. See Transcript of Fairness Hearing (ECF No. 553) at PageID #: 14487. Class Counsel also consulted with and retained numerous experts on topics including chemistry, toxicology, epidemiology, medical monitoring, pulmonology, and oncology, to advise them about

° For conciseness, the Court has cited only to the memorandum in support of the first motion (ECF No. 993-1) when similar arguments appear in both memoranda.

(4:23CV0242) information learned from discovery and the environmental sampling program. See ECF No. 518- 2 at PageID #: 10954, {47 (providing a longer non-exhaustive list of expert types). Class Counsel and Defendants Norfolk Southern Corporation and Norfolk Southern Railway Company (“Norfolk Southern’) retained the services of U.S. District Judge Layn R. Phillips (retired) to mediate the claims of Plaintiffs against Norfolk Southern. See ECF No. 518-2 at PageID #: 10955-56, 9] 53-56. Judge Phillips, confidentially informed by facts derived in part from the work of Plaintiffs’ experts, presented a mediator’s recommendation to Class Counsel and Norfolk Southern on March 6, 2024. See ECF No. 518-2 at PageID #: 10957, □□□ After months of negotiation, on April 9, 2024, Plaintiffs and Norfolk Southern announced a settlement in principle. See Notice and Motion to Stay Deadlines (ECF No. 445); ECF No. 518- 2 at PageID #: 10957, | 60. Notably, the Settlement was reached before expert reports were finalized and due to be exchanged. See Order (ECF No. 432) at PageID #: 5686 (“On or before April 15, 2024, the party that has the burden of proof on an issue(s) shall identify its retained expert witness(es) and provide opposing counsel with a written expert report(s).”). The Class Action Settlement Agreement (ECF No. 452-2) was executed on April 26, 2024. The Settlement creates a non-reversionary fund of $600 million, to be allocated among the Settlement Class Members. The Settlement distribution includes three categories of payment: Direct Payments to individuals on a per-Household basis (“Direct Payments”); payments to businesses for Business Loss claims (“Business Loss Payments”); and optional payments to Settlement Class Members within 10 miles of the derailment who voluntarily agree to release any personal injury claims they might have in connection with the derailment by executing a release of personal injury claims (“Voluntary Exposure Supplement” or “Personal Injury Payment”). See

(4:23CV0242) ECF No. 452-2 at PageID #: 6023-26. The Order (ECF No. 557) granting Plaintiffs’ Motion for Final Approval of Settlement did not compel any class member to sign the personal injury release they entered into with Norfolk Southern. In fact, class members were informed the personal injury releases would not impact direct payments to them. During the notice period, Class Counsel communicated with class members about the Settlement and their options. Class Counsel arranged several virtual conferences or “town hall”

meetings with class members. One such town hall led by community member and Village Manager Chad Edwards was held on August 1, 2024. It was recorded and the video was provided to class members. See EP Settlement Attorney PR Zoom meeting. 8/1/24 (“Town Hall Recording”), https://www.youtube.com/watch?v=VTZpstUPR9I (last visited May 1, 2026). This town hall included a pre-recorded presentation by Dr. Chip Carson, a physician and Ph.D. environmental toxicologist. Class Counsel arranged for Dr. Carson to speak to the class members. Dr. Carson, however, was not compensated in any way by Class Counsel for his

opinions or for his time. See ECF No. 553 at PageID #: 14477. As explained to class members at the town hall, Dr. Carson was “not involved in the litigation [and is] a completely independent third party.” Town Hall Recording at 12:48-52 (brackets added). In response to the question “[w]hat are the health impacts associated with the chemicals released by the derailment?” he explained, in part: Based on my best judgment, there will not be any long-term health impact of chemical exposure from the derailment to community members of East Palestine. As far as people just living in East Palestine or working there or in nearby neighboring communities, we don’t expect there to be any long-term health effects associated with chemical exposure resulting from the derailment. 4 (4:23CV0242) Town Hall Recording at 13:32-14:06. Furthermore, he explained that measurable health effects depend on the toxins and characteristics of the exposure, but:

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In re: East Palestine Train Derailment, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-east-palestine-train-derailment-ohnd-2026.