Tuck v. Air & Liquid Sys., Corp.

CourtSuperior Court of Maine
DecidedNovember 26, 2013
DocketCUMcv-11-29
StatusUnpublished

This text of Tuck v. Air & Liquid Sys., Corp. (Tuck v. Air & Liquid Sys., Corp.) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tuck v. Air & Liquid Sys., Corp., (Me. Super. Ct. 2013).

Opinion

STATE OF MAINE BUSINESS AND CONSUMER COURT CUMBERLAND, ss Location: Portland Docket No.: BCD-CV-ll/29 : 1/ ,'-'.:__,A) - Cu.}fl-· It/~,? 1 ~oB I• ,I .

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JUDITH TUCK, Personal Representative of ) the ESTATE OF DOUGLAS 0. TUCK, ) ) Plaintiff, ) ) ) ) v. ) DECISION AND ORDER ) (Motion for Summary Judgment) ) AIR & LIQUID SYSTEMS CORP., et al., ) ) Defendants ) ) ) )

This matter is before the Court on the Motion for Summary Judgment of Defendant

Crane Co. (Crane). In this action, Plaintiff seeks to recover damages allegedly resulting from the

death of Douglas Tuck (the Decedent) due to his exposure to asbestos during the course of his

employment at Bath Iron Works. Plaintiff seeks to recover under theories of negligence (Count

1), strict products liability (Count II), and loss of consortium (Count III). Crane argues that

Plaintiff has failed to establish that the Decedent was exposed to asbestos from any Crane

product that contributed to his illness and death. Crane, therefore, requests summary judgment

in its favor.

I. FACTUALBACKGROUND

The following facts are undisputed, except where noted. See Fore, LLC v. Benoit, 2012

ME 1, ~ 2, 34 A.3d 1125. The Decedent was employed by Bath Iron Works (BIW) as an outside machinist from July 1, 1976, until March 1, 2002. (S.S.M.F. 1 1; O.S.M.F. 1 1.) The Decedent

worked primal'ily on overhauling ships, rather than new construction. (A.S.M.F. 1 12; R.S.M.F.

1 12.) Plaintiff alleges that the Decedent was exposed to asbestos from inhalation and ingestion of asbestos dust and fibers that settled on his clothing and person, which ultimately caused his

mesothelioma. (S.S.M.F., 2; O.S.M.F. 1 2.)

The Decedent was not deposed in the course of the present litigation because he passed

away before his deposition could be taken. (O.S.M.F. 1 5.) Instead, the parties rely in part on a

deposition of the Decedent from his federal workers compensation case. (O.S.M.F. 1 5.) At that

deposition, the Decedent did not identify any Crane product on which he worked not· did he

testify regarding that he worked near Crane products while employed at BIW. 1 (S.S.M.F. , 5;

O.S.M.F. , 5; see also S.S.M.F. , 4.) Nevertheless, in interrogatories that the Decedent

answered before his death, he recalled seeing Crane valves at his worksite, and the parties do not

dispute the presence of Crane products at BIW. (S.S.M.F., 4; O.S.M.F. 1 4; Pl.'s Exh. Bat 11.)

II. DISCUSSION

A. Standard of Review

Pursuant to M.R. Civ. P. 56(c), a moving pat1y is entitled to summary judgment "if the

pleadings, depositions, answers to interrogatories, and admissions on file, together with the

affidavits, if any, ... show that there is no genuine issue as to any material fact set forth in those

statements and that Ithe I party is entitled to a judgment as a matter of law." A party wishing to

avoid summary judgment must present a prima facie case for each element of a claim or defense

that is asserted. See Reliance Nat'l!ndem. v. Knowles Indus. Svcs., 2005 ME 29, ~ 9, 868 A.2d

1 Plaintiff "qualifies" this statement essentially to note that product and company identification were not relevant to the workers compensation proceeding. (O.S.M.F. ~ 5.) The qualification is more in the nature of legal argument than a factual qualification, 11s it includes no record citation, a point which Crane asserts is in violation of M.R. Civ. P. 56(h)(4). (Pl.'s Obj. to O.S.M.F. ~ 5.)

2 220. At this stage, the facts in the summary judgment record are reviewed "in the light most

favorable to the nonmoving party." Lightfoot v. Sch. Admin. Dist. No. 35,2003 ME 24, ~ 6, 816

A .2d 63. A material fact is a fact that has "the potential to affect the outcome of the suit."

Burdzel v. Sobus, 2000 ME 84, ~ 6, 750 A.2d 573. "If material facts are disputed, the dispute

must be resolved through fact-finding." Curtis v. Porter, 2001 ME 158, ~ 7, 784 A.2d 18.

A factual issue is genuine when there is sufficient supporting evidence for the claimed

fact that would require a fact-finder to choose between competing versions of the facts at trial.

See lnkel v. Livingston, 2005 ME 42, ~ 4, 869 A.2d 745. "Neither party may rely on conclusory

allegations or unsubstantiated denials, but must identify specific facts derived from the

pleadings, depositions, answers to interrogatories, admissions and affidavits to demonstrate

either the existence or absence of an issue of fact." Kenny v. Dep't of Human Svcs., 1999 ME

158, ~ 3, 740 A.2d 560 (quoting Vinick v. Comm'r, 110 F.3d 168, 171 (1st Cir. 1997)).

B. Applicable Law

Plaintiff's primary causes of action against Crane are in negligence and strict liability.

"The essential elements of a claim for negligence are duty, breach, proximate causation, and

harm." Baker v. Farrand, 2011 ME 91, ~ 11,26 A .3d 806. A plaintiff must demonstrate that "a

violation of the duty to use the appropriate level of care towards another, is the legal cause of

harm to" the plaintiff and that the defendant's "conduct lwasJ a substantial factor in bringing

about the harm." Spickler v. York, 566 A.2d 1385, 1390 (Me. 1993) (internal citations omitted);

see also Bonin v. Crepeau, 2005 ME 59, ~ 10, 873 A.2d 346 (outlining negligence cause of

action for supplying a product without adequate warnings to the user); REsTATEMENT (SECOND)

OF TORTS§ 388 (1965). "Maine's strict liability statute, 114 M.R.S. § 221 (2011)1, imposes

liability on manufacturers and suppliers who market defective, unreasonably dangerous

3 products," including liability for defects based on the failure to warn of the product's dangers?

See Bernier v. Raymark Indus., Inc., 516 A.2d 534,537 (Me. 1986).

As the asbestos litigation has evolved both nationally and within Maine, the level of

proof necessary to establish the requisite relationship between a plaintiffs injuries and a

defendant's product has been subject of much debate. A majol'ity of jurisdictions have adopted

the standard at1iculated by the court in Lohrmann v. Pittsburg Corning Corp., 782 F.2d 1156 (4 1h

Cir. 1986), where the court construed the "substantial factor" test of the Restatement (Second) of

Torts. 3 In Lohrmann, the court mmounced and applied the "frequency-regularity-proximity test",

which requires a plaintiff to "prove more than a casual or minimum contact with the product"

that contains asbestos. Lohrmann, 782 F.2d at 1162. Rather, under Lohrmann, a plaintiff must

present "evidence of exposure to a specific product on a regular basis over some extended period

of time in proximity to where the plaintiff actually worked." Id. at 1162-63. Lohrmann suggests

that the Court engage a quantitative analysis of a party's exposure to asbestos in order to

detetmine whether, as a matter of law, the pat1y can prevail.

Although the Maine Law Com1 has not addressed the issue, at least one Justice of the

Maine Superior Com1 has expressly rejected the Lohrmann standard. Justice Ellen Gorman4

rejected the Lohrmann standard "because it is entirely the jury's function to determine if the

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Related

Vinick v. Commissioner
110 F.3d 168 (First Circuit, 1997)
Pottle v. Up-Right, Inc.
628 A.2d 672 (Supreme Judicial Court of Maine, 1993)
Burdzel v. Sobus
2000 ME 84 (Supreme Judicial Court of Maine, 2000)
Inkel v. Livingston
2005 ME 42 (Supreme Judicial Court of Maine, 2005)
Spickler v. York
566 A.2d 1385 (Supreme Judicial Court of Maine, 1989)
Bernier v. Raymark Industries, Inc.
516 A.2d 534 (Supreme Judicial Court of Maine, 1986)
Baker v. Farrand
2011 ME 91 (Supreme Judicial Court of Maine, 2011)
Curtis v. Porter
2001 ME 158 (Supreme Judicial Court of Maine, 2001)
Lightfoot v. School Administrative District No. 35
2003 ME 24 (Supreme Judicial Court of Maine, 2003)
Schappell v. Motorists Mutual Insurance
868 A.2d 1 (Superior Court of Pennsylvania, 2004)
Reliance National Indemnity v. Knowles Industrial Services, Corp.
2005 ME 29 (Supreme Judicial Court of Maine, 2005)
Kenny v. Department of Human Services
1999 ME 158 (Supreme Judicial Court of Maine, 1999)
Bonin v. Crepeau
2005 ME 59 (Supreme Judicial Court of Maine, 2005)
Addy v. Jenkins, Inc.
2009 ME 46 (Supreme Judicial Court of Maine, 2009)
Fore, LLC v. Benoit
2012 ME 1 (Supreme Judicial Court of Maine, 2012)

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