Patrick Short, et al. v. Civ. Amerada Hess Corp. et al.

2019 DNH 062
CourtDistrict Court, D. New Hampshire
DecidedMarch 29, 2019
Docket16-cv-204-JL
StatusPublished

This text of 2019 DNH 062 (Patrick Short, et al. v. Civ. Amerada Hess Corp. et al.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Patrick Short, et al. v. Civ. Amerada Hess Corp. et al., 2019 DNH 062 (D.N.H. 2019).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

Patrick Short, et al.

v. Civ. No. 16-cv-204-JL Opinion No. 2019 DNH 062 Amerada Hess Corp. et al.

MEMORANDUM ORDER

Whether the plaintiffs in this environmental-contamination

action may take it past the summary judgment stage depends on

whether (1) they have demonstrated standing to sue, see U.S.

Const. art. III, § 2, and (2) they filed this action within

New Hampshire’s three-year statute of limitations, accounting

for the discovery rule, see N.H. Rev. Stat. Ann. § 508:4.

Nineteen individual plaintiffs commenced this action in

2016, alleging that an underground gasoline leak discovered in

1990 in Swanzey, New Hampshire, injured their persons and

property.1 The gasoline contained methyl-tertiary butyl ether

(“MTBE”), an additive that New Hampshire has banned since 2007.

The defendants are gasoline manufacturers and suppliers and the

current and former owners of the gas station from which the leak

1 Four of those plaintiffs have dismissed their claims and the plaintiffs do not oppose the defendants’ motion to dismiss plaintiff Robert LaClair’s claims (doc. no. 48), which the court accordingly grants. emanated. The court’s subject matter jurisdiction over this

removed case is based on diversity, 28 U.S.C. §§ 1332(a), 1446,

and the Energy Policy Act of 2005, see 42 U.S.C. § 7545 note

(Claims Filed After August 8, 2005), Pub. L. 109-58, Title XV,

§ 1503, Aug. 8, 2005 (“[c]laims and legal actions filed after

[August 8, 2005] related to allegations involving actual or

threatened contamination of [MTBE] may be removed to the

appropriate United States district court.”).

The 14 plaintiffs remaining in this action assert products-

liability and negligence claims arising from alleged injuries to

their persons.2 Ten plaintiffs also assert nuisance and trespass

claims, arguing that the value of their real property has been

diminished by the presence of MTBE.3 And all plaintiffs assert a

claim under New Hampshire’s Consumer Protection Act, N.H. Rev.

Stat. Ann. § 358-A, contending that the defendants engaged in

unfair and deceptive business practices. The defendants move

for summary judgment, see Fed. R. Civ. P. 56, arguing that all

2 Specifically, plaintiffs Joseph Arsenault, David Bashaw, Jr., Darren Bashaw, Armond Bedard, Marion Bedard, Julie Bedard, Teresa Chandler, Nicole Cote (for the benefit of Stephanie Cote), Tammy Demond, Christine House, Connie Merrill, Gale Shelley, Patrick Short, and Robert Symonds. 3 Specifically, plaintiffs Joseph Arsenault, David Bashaw, Jr., Armond Bedard, Marion Bedard, Teresa Chandler, Tammy Demond, Christine House, Gale Shelley, Patrick Short, and Robert Symonds.

2 of the plaintiffs’ claims except one4 are barred either for lack

of standing or by the applicable statute of limitations.5

Having reviewed the parties’ filings and exhibits,

including supplemental filings after oral argument, the court

grants the defendant’s motion in large part and denies it in

part. Specifically, all plaintiffs’ claims under the New

Hampshire Consumer Protection Act are barred by its statute of

limitations. And all plaintiffs except Teresa Chandler have

failed to carry their burdens of demonstrating standing or that

the discovery rule prevents the statute of limitations from

barring their tort claims. Accordingly, the court grants the

defendants’ motions as to all plaintiffs’ claims except

Chandler’s tort claims.

Applicable legal standard

“The court shall grant summary judgment if the movant shows

that there is no genuine dispute as to any material fact and the

movant is entitled to judgment as a matter of law.” Fed. R.

4 The defendants “do not seek summary judgment on Chandler’s property damage claim” through this motion. Defendants’ Supp. Mem. (doc. no. 72) at 46. 5 The court previously denied without prejudice the defendants’ motion to dismiss plaintiffs’ claims. See Endorsed Order, (Sept. 27, 2017). That motion asserted several grounds for dismissal, including the statute of limitations and plaintiffs’ standing to sue. The parties subsequently agreed to address those issues through summary judgment after a period of limited discovery. See Stipulations (doc. nos. 32, 33).

3 Civ. P. 56(a). The moving party must “assert the absence of a

genuine issue of material fact and then support that assertion

by affidavits, admissions, or other materials of evidentiary

quality.” Mulvihill v. Top-Flite Golf Co., 335 F.3d 15, 19 (1st

Cir. 2003). “A genuine issue is one that could be resolved in

favor of either party, and a material fact is one that has the

potential of affecting the outcome of the case.” Vera v.

McHugh, 622 F.3d 17, 26 (1st Cir. 2010) (internal quotation

omitted).

Where, as here, the plaintiffs bear the ultimate burden of

proof, once the movant has made the requisite showing, they can

no longer “rely on an absence of competent evidence, but must

affirmatively point to specific facts that demonstrate the

existence of an authentic dispute.” Torres–Martínez v. P.R.

Dep’t of Corr., 485 F.3d 19, 22 (1st Cir.2007). That is, the

plaintiffs “‘may not rest upon the mere allegations or denials

of [the] pleading, but must set forth specific facts showing

that there is a genuine issue’ of material fact as to each issue

upon which [they] would bear the ultimate burden of proof at

trial.” Santiago-Ramos v. Centennial P.R. Wireless Corp., 217

F.3d 46, 52–53 (1st Cir. 2000) (quoting Anderson v. Liberty

Lobby, Inc., 477 U.S. 242, 256 (1986)).

As it is obligated to do in the summary judgment context,

the court “rehearse[s] the facts in the light most favorable to

4 the nonmoving party (here, the plaintiff[s]), consistent with

record support,” and gives them “the benefit of all reasonable

inferences that those facts will bear.” Noviello v. City of

Boston, 398 F.3d 76, 82 (1st Cir. 2005) (internal citation

The following background takes this approach, drawing on

the parties’ recitations of undisputed, accepted facts except

where noted. Before moving on to that recitation, the court

observes that it was hampered in this endeavor by the

plaintiffs’ failure to comply with Local Rule 56.1, which

requires that “[a] memorandum in opposition to a summary

judgment motion shall incorporate a short and concise statement

of material facts, supported by appropriate record citations, as

to which the adverse party contends a genuine dispute exists so

as to require a trial.” LR 56.1(b). Failure to comply with

this requirement and properly oppose a motion for summary

judgment, as the plaintiffs have failed to, may result in “[a]ll

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Bluebook (online)
2019 DNH 062, Counsel Stack Legal Research, https://law.counselstack.com/opinion/patrick-short-et-al-v-civ-amerada-hess-corp-et-al-nhd-2019.