State v. Atlantic Richfield Co.

CourtVermont Superior Court
DecidedDecember 5, 2017
Docket340-6-14 Wncv
StatusPublished

This text of State v. Atlantic Richfield Co. (State v. Atlantic Richfield Co.) is published on Counsel Stack Legal Research, covering Vermont Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Atlantic Richfield Co., (Vt. Ct. App. 2017).

Opinion

State v. Atlantic Richfield Co., No. 340-6-14 Wncv (Teachout, J., Dec. 5, 2017). [The text of this Vermont trial court opinion is unofficial. It has been reformatted from the original. The accuracy of the text and the accompanying data included in the Vermont trial court opinion database is not guaranteed.]

STATE OF VERMONT

SUPERIOR COURT CIVIL DIVISION Washington Unit Docket No. 340-6-14 Wncv

STATE OF VERMONT, Plaintiff

v.

ATLANTIC RICHFIELD COMPANY, et al., Defendants

DECISION Defendants’ Motion to Dismiss Amended Complaint

This matter is before the court on a motion to dismiss filed on October 21, 2016 by defendants Exxon Mobil Corporation, ExxonMobil Oil Corporation, and Mobil Corporation (“Exxon”). The remaining co-defendants named in the State’s complaint have joined in the motion. Background The State filed its first Complaint on June 5, 2014, alleging a generalized injury to all State groundwaters caused by methyl tertiary butyl ether (“MTBE”) contamination. The State alleged that all 29 Defendants participated in the promotion, marketing, distribution, and sale of gasoline containing MTBE in Vermont. Exxon, in turn, filed a motion to dismiss for failure to state a claim upon which relief can be granted, arguing that because the State knew of MTBE contamination in Vermont and its harmful environmental effects on State waters by 2007, the State’s complaint was barred by the six-year statute of limitations under 12 V.S.A. § 511. The court granted Exxon’s motion to dismiss with respect to a claim for a generalized injury to the State groundwaters as a whole on the grounds that a claim framed in such a manner was time-barred. However, because the State had alleged discoveries within the preceding six years and could potentially identify claims that were not time-barred, the court could not conclude that there were no facts or circumstances under which the State would be entitled to relief. The court emphasized that the State’s complaint did not sufficiently comply with the requirements of V.R.C.P. 9(f) with respect to specific site claims that were actionable because they were within the statute of limitations period.1 The court granted the motion to dismiss the generalized claim, but gave the State an opportunity to file an amended complaint as to those claims that fell within the statute of limitations period. The Vermont Supreme Court affirmed this decision on May 27, 2016.

1 The pertinent date for statute of limitations purposes is June 5, 2008, which is six years prior to the date this case was filed. On September 7, 2016, the State filed the Amended Complaint now under consideration. In response, Defendants have again moved to dismiss, asserting that “[t]he only substantive changes in the Amended Complaint are the identification of various sites and wells throughout Vermont and an allegation that MTBE is or may be present at those sites and wells.” Supporting Memorandum of Law at 4. Defendants contend that “[w]ith the exception of the five locations for which the State has made specific allegations of discovery within the limitations period, all of the State’s claims are either untimely, alleged with insufficient specificity, or unripe.” Id. Defendants ask the court to dismiss the State’s claims on these grounds. The State has attached to its Amended Complaint Appendices A-G, each one being a list representing a category of sites in which MBTE has at some point been detected or where the State believes it might be detected if testing were undertaken.2 The total number of sites is over 3,000, although there is clearly some duplication, as the categories overlap. There is no question that the lists include sites for which action is barred by the statute of limitations. The State is openly seeking to advance its position that MTBE is pervasive throughout the State and that the court should adopt the continuing tort doctrine and find Defendants responsible for not only known sites but for testing and investigation at potential sites not currently identified. Defendants claim that, based on the prior ruling, it was incumbent on the State to limit the sites in its Amended Complaint to not only those sites where MTBE was first discovered within the limitations period but also, it argues, to identify the date of first discovery to provide assurance that only actionable claims are included.

Standard of Review The purpose of a Rule 12(b)(6) motion is to test the law of the claim, not the facts that might support it. Kane v. Lamothe, 2007 VT 91, ¶ 14, 182 Vt. 241. The court will only grant a motion to dismiss for failure to state a claim “when it is beyond doubt that there exist no facts or circumstances, consistent with the complaint that would entitle the plaintiff to relief.” Bock v. Gold, 2008 VT 81, ¶ 4, 184 Vt. 575. In examining a Rule 12(b)(6) motion, the court assumes that all factual allegations in the complaint are true and must also “accept as true all reasonable inferences that may be derived from plaintiff’s pleading.” Richards v. Town of Norwich, 169 Vt. 44, 48–49 (1999).

“Since averments of time and place are material for testing the sufficiency of a complaint, defenses based on a failure to comply with the applicable statute of limitations are properly raised in a motion to dismiss.” Bethel v. Mount Anthony Union High Sch. Dist., 173 Vt. 633, 634 (2002). Thus, if, accepting as true all factual allegations in the complaint and all reasonable inferences

2 The Appendices may be briefly identified as follows: A: 58 sites owned by the State with MTBE B: 30 sites where MTBE was first discovered after June 5, 2008 C: 550+/- sites in Vermont with known MTBE detection D: 198 gas stations with MTBE possibly present, most of which have not been investigated E: 59 salvage yards with MTBE possibly present, all untested F: 665 public wells where MTBE has been detected since June 5, 2008 G: 1600 +/- public wells in the State, most of which are untested

2 drawn therefrom the complaint does not state a claim that accrued within the limitations period, the motion should be granted, and the complaint dismissed.

Analysis

The court finds it most useful to address the issue using the framework of the categories of sites identified in the State’s Appendices in the Amended Complaint.

1. Claims involving sites where MTBE was first detected on or after June 5, 2008 with specific dates of discovery included; Amended Complaint at ¶ 174. The State alleges that “MTBE was detected for the first time, and on information and belief, was not reasonably discoverable prior to then, in soil and/or groundwater at numerous sites sometime on or after June 5, 2008.” Amended Complaint at 49, ¶ 174. Specifically, the State sets forth the following sites: a. Hinesburg Short Stop (aka Hinesburg Jolley Mobil), 21 Commerce Street, Hinesburg, Vermont, site code 20114243. MTBE was first detected at this site on July 20, 2012. b. North End Deli, 475 North Main Street, Barre, Vermont, site code 20124345. MTBE was first detected at this site on May 30, 2013. c. Citizen’s Bank, 47 Merchants Row, Rutland, Vermont, site code 20124346. MTBE was first detected at this site on June 25, 2013. d. Burlington Free Press, 185-195 College Street, Burlington, Vermont, site code 20134393. MTBE was first detected at this site on September 16, 2013. e. Young Residence, 28 North Williams Street, Burlington, Vermont, site code 20134436. MTBE was first detected at this site on December 23, 2013. Id. The allegations are clear that MTBE was detected at these five sites within the statutory period and Defendants do not challenge the timeliness of claims brought as to these sites. The State’s claims as to these sites are not subject to dismissal. 2. Claims involving sites where MTBE was first discovered or detected after June 5, 2008 with no specific dates of discovery included; Appendix B.

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Bluebook (online)
State v. Atlantic Richfield Co., Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-atlantic-richfield-co-vtsuperct-2017.