Scoggins v. ViacomCBS CA1/4

CourtCalifornia Court of Appeal
DecidedAugust 28, 2025
DocketA170859
StatusUnpublished

This text of Scoggins v. ViacomCBS CA1/4 (Scoggins v. ViacomCBS CA1/4) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Scoggins v. ViacomCBS CA1/4, (Cal. Ct. App. 2025).

Opinion

Filed 8/28/25 Scoggins v. ViacomCBS CA1/4 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION FOUR

ALYCE M. SCOGGINS et al., Plaintiffs and Appellants, A170859 v. VIACOMCBS, INC., (Alameda County Super. Defendant and Respondent. Ct. No. RG21104466)

David Scoggins was diagnosed with mesothelioma, a cancer caused by his exposure to asbestos. Scoggins filed a personal injury action against ViacomCBS, formerly known as Westinghouse Electric Corporation (Westinghouse), among other defendants, alleging that he inhaled asbestos while working with and around Westinghouse products and contractors at worksites of his former employer, Pacific Gas & Electric Company (PG&E). After his death, Scoggins’s surviving relatives (collectively, plaintiffs) pursued his claims along with their survivorship claims. Plaintiffs argue that the trial court erred in excluding the declaration of their expert witness, Jerome Spear, on the ground that he was untimely designated, and without considering whether any untimeliness was unreasonable within the meaning of Code of Civil Procedure section

1 2034.300.1 The exclusion, they claim, left uncontroverted Westinghouse’s expert evidence that its products could not be shown to have caused Scoggins’s mesothelioma, and resulted in the termination of the case against Westinghouse by grant of summary judgment. In response, Westinghouse adheres to its view that the designation was untimely and that plaintiffs’ conduct was unreasonable. It further argues that, even if the designation was timely served, plaintiffs were not prejudiced both because they failed to show error in the court’s conclusion that they did not produce sufficient evidence of Scoggins’s threshold exposure to asbestos- containing dust from Westinghouse products, and because Spear’s declaration was subject to exclusion on the additional ground that it lacked foundation. As discussed below, we conclude that Westinghouse’s objection that plaintiffs did not timely designate Spear as an expert was not well taken. Moreover, because at this stage of the case we are required to view the evidence in the light most favorable to plaintiffs, we find that they were prejudiced by the erroneous exclusion of his declaration. We therefore reverse. BACKGROUND I. The complaint alleges that Scoggins “was employed as a mechanic with [PG&E] from approximately 1968 to 2009. During and throughout these years, [Scoggins] worked in various PG&E sites where he was exposed to asbestos. [He] worked as a mechanic and had other job titles and was exposed to asbestos in numerous ways, including . . . working on and/or

1 Unless otherwise stated, all further statutory references are to this

code.

2 around turbines, boilers, pumps and valves at various PG&E power plant locations . . . . [Scoggins] was further exposed through his work around other trades, including boilermakers, pipefitters, welders, mechanics, carpenters, iron workers, insulators, and electricians. [Scoggins] worked closely to a variety of trades that were working on asbestos-containing insulation, generators, boilers, and often worked near tradesmen working on asbestos- containing pipe insulation, valves, steam traps, pumps, furnaces, and other equipment. All of these activities exposed [Scoggins] to asbestos.” To establish that his exposure to asbestos for which Westinghouse had responsibility caused his mesothelioma, plaintiffs provided Scoggins’s own deposition testimony, the declaration and deposition testimony of Thomas Tellez, deposition testimony from Raymond Friend, and Spear’s expert declaration. The evidence from Scoggins, Friend, and Tellez established that Scoggins worked around some Westinghouse equipment in various power plants; that some of this equipment contained asbestos; and that when work was done on this equipment—often by outside contractors, including Westinghouse contractors—the work generated dust that became airborne and that Scoggins and his coworkers breathed. Scoggins also cleaned up around the work that others performed; his sweeping caused the dust to become airborne and he would breathe it. Westinghouse’s corporative representative, Douglas M. Ware, testified that Westinghouse had equipment at the PG&E locations where Scoggins worked roughly in the time period that he worked there, and that various components of that equipment contained asbestos and/or were designed to work with asbestos-containing parts. Westinghouse argued, however, that plaintiffs’ evidence was insufficient to show that Scoggins’s work exposed him to asbestos from Westinghouse equipment. Moreover, Westinghouse’s expert,

3 Dennis C. Ertel, declared that whatever exposure Scoggins had would not be a substantial factor in causing his mesothelioma to a reasonable scientific certainty. He also opined that the Westinghouse electrical products that Scoggins had worked around, even assuming they contained asbestos, would not have resulted in “significant emissions of asbestos” from the work Scoggins described doing. In his expert declaration, Spear opined, based on his review of the scientific literature, that “gaskets and packing used in equipment (such as pumps and valves) for high temperature and/or high pressure applications installed prior to the late 1980s was likely asbestos-containing,” that the same was true for “thermal system insulation . . . installed prior to the mid- 1970s,” and that “asbestos-reinforced plastics (e.g., Bakelite) was commonly used in electrical panels and switchgear until the early 1980s,” and even though such plastics were considered encapsulated, the asbestos fibers within them could be released under certain circumstances or could protrude from the surface. Spear further opined that “within a reasonable degree of scientific certainty . . . Scoggins’ presence around others working with asbestos-containing gaskets on Westinghouse turbines and pumps, the work of Westinghouse contractors around Mr. Scoggins, Mr. Scoggins [sic] work during overhauls, and Mr. Scoggins’ work with Westinghouse motor control centers, caused him to breathe asbestos dust well above background levels” and as a result, “within a reasonable degree of scientific certainty . . . such exposure significantly increased Mr. Scoggins [sic] risk of developing the mesothelioma that eventually took his life.” II. Trial was set for February 13, 2024, with expert discovery set to close January 29. On December 1, 2023, plaintiffs served Westinghouse with a

4 demand for expert disclosures pursuant to section 2034.210, specifying December 20, 2023, as the date for the exchange. On December 19, plaintiffs served their designation, listing five experts. On December 22, plaintiffs filed an amended designation adding Spear as an expert witness. On December 28, Westinghouse served plaintiffs with an objection to the amendment as untimely and not compliant with the procedures for augmenting their disclosures. The objection explained: “Under California Code of Civil Procedure 2034.230(b), the date for the exchange of expert witness information based on the date of Plaintiffs’ Demand for Exchange of Expert Witness Information was December 21, 2023.” It also stated that plaintiffs had “timely submitted” their (original) designation of expert witnesses “on December 21, 2023,”2 and that Westinghouse itself had “made complete and timely expert designation,” referencing the electronic service transaction number but without mentioning the date of it. III.

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Scoggins v. ViacomCBS CA1/4, Counsel Stack Legal Research, https://law.counselstack.com/opinion/scoggins-v-viacomcbs-ca14-calctapp-2025.