Watt v. BP Prods. N. Am. Inc.

2025 NY Slip Op 31332(U)
CourtNew York Supreme Court, New York County
DecidedApril 18, 2025
DocketIndex No. 151554/2024
StatusUnpublished

This text of 2025 NY Slip Op 31332(U) (Watt v. BP Prods. N. Am. Inc.) is published on Counsel Stack Legal Research, covering New York Supreme Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Watt v. BP Prods. N. Am. Inc., 2025 NY Slip Op 31332(U) (N.Y. Super. Ct. 2025).

Opinion

Watt v BP Prods. N. Am. Inc. 2025 NY Slip Op 31332(U) April 18, 2025 Supreme Court, New York County Docket Number: Index No. 151554/2024 Judge: Mary V. Rosado Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. INDEX NO. 151554/2024 NYSCEF DOC. NO. 141 RECEIVED NYSCEF: 04/18/2025

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. MARY V. ROSADO PART 33M

_________________________________________________________ ,___ Justice --------X INDEX NO. 151554/2024 HARRINGTON WATT, GRACE WATT, MOTION DATE 07/12/2024 Plaintiffs, MOTION SEQ. NO. 007 -v- BP PRODUCTS NORTH AMERICA INC.,CARBO INDUSTRIES, INC.,CHEVRON U.S.A. INC. F/K/A GULF OIL CORPORATION, INDIVIDUALLY AND AS SUCCESSOR- IN-INTEREST TO HESS CORPORATION, ENERGY TRANSFER (R&M), LLC F/K/A SUNOCO, LLC (R&M) F/K/A SUNOCO, INC. (R&M) F/K/A SUN COMPANY, INC. AND F/K/A SUN OIL COMPANY, INC.,EXXON MOBIL CORPORATION, HESS CORPORATION, MARATHON PETROLEUM CORPORATION, INDIVIDUALLY AND AS DECISION + ORDER ON SUCCESSOR-IN-INTEREST TO MARATHON PETROLEUM COMPANY LLC F/K/A MARATHON MOTION ASHLAND PETROLEUM LLC,NORTHVILLE INDUSTRIES CORP., SHELL USA, INC. F/K/A SHELL OIL COMPANY, SPRAGUE OPERATING RESOURCES LLC,INDIVIDUALL Y, AND AS SUCCESSOR-IN-INTEREST TO CARBO INDUSTRIES INC.,TEXACO INC.,INDIVIDUALLY AND AS SUCCESSOR-IN-INTEREST TO TEXACO REFINING AND MARKETING, INC.,

Defendants. ---------------------------------------------------------------------------------X

EXXON MOBIL CORPORATION Third-Party Index No. 595247/2025 Plaintiff,

-against-

ISLAND TRANSPORT CORPORATION

Defendant. --------------------------------------------------------------------------------X

The following e-filed documents, listed by NYSCEF document number (Motion 007) 92, 93, 94, 95, 97, 101, 102 were read on this motion to/for DISMISSAL

Upon the foregoing documents, and after a final submission date of April 1, 2025,

Defendant Northville Industries Corp.' s ("Northville") motion to dismiss Plaintiffs Harrington 151554/2024 WATT, HARRINGTON ET AL vs. BP PRODUCTS NORTH AMERICA INC. ET AL Page 1 of6 Motion No. 007

[* 1] 1 of 6 INDEX NO. 151554/2024 NYSCEF DOC. NO. 141 RECEIVED NYSCEF: 04/18/2025

Watt ("Harrington") and Grace Watt's (collectively "Plaintiffs") Complaint pursuant to CPLR

321 l(a)(5) and (a)(7) is granted in part and denied in part.

I. Background

This action arises from Harrington's alleged benzene exposure as a driver transporting

gasoline, diesel fuel, aviation fuel, kerosene, and heating oil products to numerous fueling stations

and petroleum supply and distribution centers (NYSCEF Doc. 1 at ,i 21 ). Harrington was employed

in this line of work from 1985 through 2022 (id). Plaintiffs allege that because of this work

Harrington contracted multiple myeloma on January 21, 2022 (id at ,i 25). Plaintiffs allege

numerous causes of action, including (1) negligence and gross negligence; (2) strict products

liability; (3) fraudulent misrepresentation; (4) breach of warranty, and (5) loss of consortium. Now,

Northville moves to dismiss Plaintiffs' fraud claims, breach of warranty claims, and asks this Court

to strike Plaintiffs' demand for punitive damages. Plaintiffs oppose.

II. Discussion

A. Standard

When reviewing a pre-answer motion to dismiss for failure to state a claim, the Court must

give the Plaintiff the benefit of all favorable inferences which may be drawn from the pleadings

and determines only whether the alleged facts fit within any cognizable legal theory (Sassi v

Mobile Life Support Services, Inc., 37 NY3d 236, 239 [2021]). All factual allegations must be

accepted as true (Allianz Underwriters Ins. Co. v Landmark Ins. Co., 13 AD3d 172, 174 [1st Dept

2004]). Conclusory allegations or claims consisting of bare legal conclusions with no factual

specificity are insufficient to survive a motion to dismiss (Godfrey v Spano, 13 NY3d 358, 373

[2009]; Barnes v Hodge, 118 AD3d 633, 633-634 [1st Dept 2014]). A motion to dismiss for failure

151554/2024 WATT, HARRINGTON ET AL vs. BP PRODUCTS NORTH AMERICA INC. ET AL Page 2 of 6 Motion No. 007

[* 2] 2 of 6 INDEX NO. 151554/2024 NYSCEF DOC. NO. 141 RECEIVED NYSCEF: 04/18/2025

to state a claim will be granted if the factual allegations do not allow for an enforceable right of

recovery (Connaughton v Chipotle Mexican Grill, Inc., 29 NY3d 137, 142 [2017]).

Nonetheless, the sole criterion for a Court to determine on a motion to dismiss for failure

to state a claim is whether the pleadings, from its four corners, taken together as a whole, manifests

any cause of action cognizable at law (African Diaspora Maritime Corp. v Golden Gate Yacht

Club, 109 AD3d 204 [1st Dept 2013]). Whether a Plaintiff can ultimately establish its allegations

is not taken into consideration in deciding a motion to dismiss (id.).

B. Fraudulent Misrepresentation

Northville's motion to dismiss Plaintiffs' fraudulent misrepresentation claim is denied. To

sufficiently allege fraudulent misrepresentation, a plaintiff must allege that (1) defendant made a

materially false representation; (2) defendant intended to defraud plaintiffs; (3) plaintiffs

reasonably relied upon the misrepresentation, and (4) plaintiffs suffered damages as a result (JA. 0.

Acquisition Corp. v Stavitsky, 18 AD3d 3 89 [1st Dept 2005]). While Northville is correct that

CPLR 3016(b) imposes a heightened pleading standard for fraud, that requirement is not meant to

prevent an otherwise valid cause of action in situations where it may be 'impossible to detail the

circumstances constituting a fraud"' (Pludeman v Northern Leasing Systems, Inc. 10 NY3d 486,

491 [2008] citing Lanzi v Brooks, 43 NY2d 778, 780 [1977] quoting Jered Contr. Corp. v New

York City Tr. Auth., 22 NY2d 187, 194 [1968]).

Here, Plaintiffs have alleged that the Defendants, including Northville, had specific

knowledge that benzene exposure led to a high risk of injury or death and had obtained this

knowledge through their own testing and research or through participation in industry and trade

organizations. Plaintiffs allege that nonetheless, Defendants concealed the dangers of benzene

containing products. Plaintiff alleges that Northville specifically knew about the dangers of

151554/2024 WATT, HARRINGTON ET AL vs. BP PRODUCTS NORTH AMERICA INC. ET AL Page 3 of 6 Motion No. 007

[* 3] 3 of 6 INDEX NO. 151554/2024 NYSCEF DOC. NO. 141 RECEIVED NYSCEF: 04/18/2025

benzene no later than 1948 yet distributed benzene containing products without any warning of its

potential dangers. This is sufficient, for purposes of a pre-answer motion to dismiss, to state a

claim for fraudulent misrepresentation.

C. Express and Implied Warranty

Northville's motion to dismiss Plaintiffs' causes of action alleging breaches of express and

implied warranties is granted in part and denied in part. Plaintiffs have agreed to withdraw, without

prejudice, their claims for breach of express warranty. Thus, to the extent the Complaint contained

allegations related to breach of express warranty, those claims are dismissed without prejudice.

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Related

Denny v. Ford Motor Co.
662 N.E.2d 730 (New York Court of Appeals, 1995)
Pludeman v. NORTHERN LEASING
890 N.E.2d 184 (New York Court of Appeals, 2008)
Godfrey v. Spano
920 N.E.2d 328 (New York Court of Appeals, 2009)
Lanzi v. Brooks
373 N.E.2d 278 (New York Court of Appeals, 1977)
Connaughton v. Chipotle Mexican Grill, Inc.
75 N.E.3d 1159 (New York Court of Appeals, 2017)
Matter of Ruiz
2020 NY Slip Op 3121 (Appellate Division of the Supreme Court of New York, 2020)
Allianz Underwriters Insurance v. Landmark Insurance
13 A.D.3d 172 (Appellate Division of the Supreme Court of New York, 2004)
Heilbut v. Heilbut
18 A.D.3d 1 (Appellate Division of the Supreme Court of New York, 2005)
African Diaspora Maritime Corp. v. Golden Gate Yacht Club
109 A.D.3d 204 (Appellate Division of the Supreme Court of New York, 2013)
Barnes v. Hodge
118 A.D.3d 633 (Appellate Division of the Supreme Court of New York, 2014)
Jered Contracting Corp. v. New York City Transit Authority
239 N.E.2d 197 (New York Court of Appeals, 1968)

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2025 NY Slip Op 31332(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/watt-v-bp-prods-n-am-inc-nysupctnewyork-2025.