PERSONAL INJURY LITIGATION NEWS - ruttergroup.com Injury News sample.pdf · California Practice...

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© 2013 Thomson Reuters

VOLUME 8, ISSUE 7 / SEPTEMBER 2013

PERSONAL INJURY LITIGATION NEWS

California Practice Guide™

™

Product LiabilitySuit over Marine crushed by helicopter fails to state a claim, judge says (S.D. Cal.) ................................... 6

Product LiabilityCalifornia jury rejects design defect claim in bike helmet injury suit (Cal. Super. Ct.) ......................... 7

(See page 3)

(Continued on page 2)

COMMENTARY

The emerging risk of repetitive stress head injury claims (Part 2)Kathryn C. Thomas of Freeborn & Peters discusses how pending suits against the NFL and the NCAA over the alleged failure to warn about the long-term effects of concussions and repetitive head blows may affect coverage defenses in youth concussion lawsuits, which have a potential pool of claimants rising into the millions.

ASBESTOS (CAUSATION)

Union Carbide asks California high court to reverse award in asbestos caseThe California Supreme Court should overturn a $600,000 judgment against Union Carbide in an asbestos exposure suit because a lower court applied too loose a causation standard in affirming the judgment, the company says in a petition for review.

Strickland et al. v. Union Carbide Corp., No. S 212424, petition for review filed (Cal. July 29, 2013).

“This case presents a recurring problem concerning the sufficiency of a plaintiff’s proof of causation in worker asbestos-injury cases,” Union Carbide says.

The company says the 2nd District Court of Appeal wrongly interpreted the causation standard in cases of alleged exposure to multiple companies’ asbestos-containing products set forth by the state Supreme Court in Rutherford v. Owens-Illinois Inc., 16 Cal. 4th 953 (1997).

Under Rutherford, a plaintiff must show exposure and “prove with medical evidence and to a reasonable medical probability that the exposure was a ‘substantial factor’


California Practice Guide: Personal Injury Litigation News2 • SEPTEMBER 2013

The Rutter Group’s “California Practice Guide: Personal Injury Litigation News” Published since March 2006Publisher: Mary Ellen FoxExecutive Editor: Donna Higgins Editor: Melissa Sachs, Esq. [email protected]

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contributing to the worker’s risk of developing his asbestos-related disease,” Union Carbide argues.

In this case, the company says, the lower courts have interpreted the Rutherford test so laxly as to find that the plaintiff’s exposure to its product was the primary cause of his fatal lung cancer without the required medical evidence.

THE LOWER COURT RULINGS

A Los Angeles County Superior Court jury found Union Carbide 46 percent at fault for exposing Glen Strickland to asbestos in Calidria, a joint compound the company sold.

Strickland’s wife, Lind, and their adult children said he used the product in the 1960s while working as a drywall installer, which included applying and sanding the joint compound. He later developed the lung cancer mesothelioma, the family said.

The Superior Court entered final judgment against the company for $598,000.

Union Carbide appealed the ruling to the 2nd District Court of Appeal, arguing that the family overstated Strickland’s exposure to chrysotile, the form of asbestos in Calidria.

The company said Strickland had also been exposed to amphibole asbestos, which it said was found in high concentrations in a stick-on spray he used when working on a movie theater construction job.

Union Carbide had argued in a filing with the appeals court that the plaintiffs’ own expert, Dr. Samuel Hammar, never offered an opinion as to “whether Strickland’s exposure to Calidria in particular made a contribution to his risk of disease that was substantial in light of all his other exposures.”

In affirming the judgment, the appeals court said “there was substantial evidence from which the jury could conclude Strickland’s exposure to Calidria played more than a negligible or theoretical part in his risk of developing peritoneal mesothelioma.” Strickland v. Union Carbide Corp., 2013 WL 2996570 (Cal. Ct. App., 2d Dist. June 18, 2013).

The 2nd District turned town Union Carbide’s request for a rehearing July 11.

THE RUTHERFORD TEST

Now Union Carbide is telling the state Supreme Court the appeals court’s causation standard is too relaxed.

“The Court of Appeal has accepted a standard of proof for causation that amounts to almost automatic liability for the supplier of any of any asbestos-containing product to which the worker was exposed,” the petition says.

(See ASBESTOS on page 7)


SEPTEMBER 2013 • 3California Practice Guide: Personal Injury Litigation News

(In Part 1, the author discussed the developing medical science on head injuries, and the NFL and NCAA lawsuits.)

WHAT ARE REPETITIVE STRESS HEAD INJURY CLAIMS?

Repetitive stress head injury claims most commonly refer to claims that participation in contact sports caused chronic traumatic encephalopathy (“CTE”) or a similar degenerative condition of the brain in participants. CTE was originally identified in boxers and mixed martial arts participants in the 1920s. In 2002, scientists documented the first case of a deceased football player with CTE.

Researchers have opined that CTE develops when an athlete experiences repeated head trauma because the impact of the brain against the inside of the skull causes tau, a naturally occurring protein in the brain, to become dislodged.

In the brain, tau serves the function of holding microtubules, hollow rods that serve as conduits between the brain cells, together. When the tau becomes displaced, the microtubules also become dislodged because the tau is no longer holding them together. The displaced tau eventually becomes insurgent, killing more and more of the brain’s cells. Currently, CTE can only be diagnosed post mortem by autopsying the brain and studying the tau distribution.

THE INSURANCE COVERAGE ISSUES

If the plaintiffs can prove that they are, in fact, damaged and that the NFL, NCAA or other entities sued for repetitive stress head injuries are liable for that damage, insurance companies will likely assert a number of coverage defenses, depending on the facts of each case and the underlying plaintiffs’ allegations. This discussion of possible defenses

is not limited to the issues raised in the pending coverage cases, but is intended to provide a broader overview of possible applicable coverage issues in these types of cases.

Bodily Injury Did Not Take Place During the Policy Period – Typically, coverage provided under liability insurance is triggered by damage or injury occurring during the policy term. Thus, as a threshold issue, insurers must determine when the alleged bodily injury took place. To the extent that a plaintiff does not allege that his/her injuries took place during the applicable policy period, the insurer can challenge coverage under the policy.

Intentional Conduct – As many of the lawsuits assert claims such as misrepresentation, fraud and conspiracy, insurers can disclaim coverage for intentional wrongdoing and for bodily injury that was expected or intended.

Where the underlying plaintiff seeks to demonstrate that the insured knew the plaintiff would suffer additional concussions or sub-concussive blows to the head if he/she continued to play the applicable sport, the insurer can assert a defense to coverage based upon the “expected or intended injury” exclusion.

Where the underlying facts allege that a player who had a concussion was forced to continue playing, the insurer can assert that the resulting injury was not caused by an “occurrence,” which is typically defined in general liability forms as “an accident.”

The following cases are examples of courts applying California, New York and Pennsylvania law in the “expected and intended” and “occurrence” insurance language context.

• California: There is no “accident” if all of the insured’s acts are intentional, whether or not the resulting injuries were “expected or intended.” Allstate Ins. Co. v. Salahutdin, 815 F.Supp. 1309, 1311 (N.D. Cal. 1992). Although there is a general statutory presumption that a person intends the ordinary consequences of his deliberate acts, California courts have refused to extend this principle to insurance disputes. Meyer v. PEIC, 233 Cal. App. 2d 321, 327 (Cal. Ct. App., 2d Dist. 1965). Moreover, Section 533 of the California Insurance Code provides

COMMENTARY

The emerging risk of repetitive stress head injury claims (Part 2)By Kathryn C. Thomas, Esq. Freeborn & Peters

Kathryn C. Thomas is a partner in the litigation practice group at Freeborn & Peters in Chicago. Her areas of focus include complex disputes, e-discovery, insurance coverage and regulation, intellectual property litigation, and product liability. She chairs the firm’s diversity and inclusion committee and is a founder of its women’s leadership council.



that “an insurer is not liable for a loss caused by a willful act of the insured...” California courts provide broader meaning for “expected” than “intended.” See Montrose Chem. Corp. v. Canadian Universal Ins. Co., 861 P.2d 1153, 1164 (Cal. 1993) (pollution would be “expected” if the insured knew or believed that “its conduct was substantially certain or highly likely to result in that kind of damage”).

• New York: Under New York law, an insurer has no obligation to defend a suit that alleges injuries that were either intended or expected. Federal Ins. Co. v. Cablevision Sys. Dev. Co., 637 F. Supp. 1568, 1576 (E.D.N.Y. 1986). However, “the courts have distinguished between damages which flow directly and immediately from an intended act, thereby precluding coverage, and damages which accidently arise out of a chain of unintended though expected or foreseeable events that occurred after an intentional act.” Id. See also County of Broome v. Aetna Cas. & Surety Co., 540 N.Y.S.2d 620, 622-23 (N.Y. App. Div., 3d Dept. 1989) (insurers not required to defend county for dumping pollutants because county’s actions were neither expected nor intended under policy).

• Pennsylvania: The standard for determining whether an event was expected or intended by the insured is whether the insured “acted even though he was substantially certain that an injury generally similar to the harm which occurred would result.” USAA v. Elitzky, 517 A.2d 982, 991 (Pa. Super. 1986). In Gene’s Restaurant v. Nationwide Ins. Co., the Pennsylvania Supreme Court ruled that an intentional, willful assault was not an “occurrence.” 548 A.2d 246, 248 (Pa. 1988). To establish an occurrence, the resulting injury must not have been of the “same general type” that was expected or intended by the insured. State Farm Fire & Cas. Co. v. Levine, 566 A.2d 318, 320 (Pa. Super. 1989). Intent may be inferred as a matter of law where the insured’s conduct is inherently injurious, as in cases of sexual assault and molestation. Aetna Cas. & Sur. Co. v. Roe, 650 A.2d 94, 102 (Pa. Super. 1994). Intent, at least in the sexual assault realm, may not be inferred if the plaintiff was of a sufficient age to be able to form an intent to consent. Teti v. Huron Ins. Co., 914 F. Supp. 1132, 1137 (E.D. Pa. 1996). Under Pennsylvania law, the exclusionary rule applies “when the insured intends to cause a harm.” United Servs. Auto. Ass’n v. Elitzky, 517 A.2d 982, 987 (Pa. Super. 1986). This rule provides that insurance coverage is not excluded because

the insured’s actions are intentional unless he also intended the resulting damage. Id.

Number of Occurrences – A court’s determination regarding how many occurrences have taken place will likely impact which insurance policies are triggered, the applicable policy limits, the applicable deductible amounts and other insurer’s obligations under the insurance policies. With regard to repetitive stress head injury cases, the range of possible occurrences is broad. Depending on the applicable law, the number of occurrences may be determined to be many, few or some number in between. For example, the alleged failure of the NFL, NCAA or other team or governing body to warn and protect its players could be determined to be a single occurrence. On the other end of the spectrum, each game could be deemed a separate occurrence. Or the number of occurrences may be determined by the injuries to the players. For example, courts may determine, on one end of the spectrum that each practice and each game per player is an occurrence or, on the other end of the spectrum, that an administration’s supervision of all student athletes during a policy period constitutes an occurrence.

Courts have not been consistent when determining the number of occurrences; at the present time, California, New York, and Pennsylvania law seems most relevant to the pending actions and those three states are not consistent.

• California: California has adopted the “causation” approach for determining the number of occurrences. See, e.g., State Farm Fire and Cas. Co. v. Kohl, 131 Cal. App.3d 1031, 1034-35 (Cal. Ct. App., 3d Div. 1982). “[A] single uninterrupted course of conduct which gives rise to a number of injuries or incidents of property damage is one ‘accident’ or ‘occurrence.’ On the other hand, if the original cause is interrupted or replaced by another cause, then there is more than one ‘accident’ or ‘occurrence.’” Id. Where a continuing loss arising out of a single ‘occurrence’ triggers multiple policy limits, an insured is entitled to “stack” the separate occurrence limits in the subject policies, thereby effectively obtaining “more coverage” than is listed in the policy. Employers Insurance of Wausau v. Granite State Insurance Company, 330 F.3d 1214, 1220-21 (9th Cir. 2003). The court found that the policy should be limited to “per occurrence per year.” Id.

• New York: Although New York state law provides a haphazard application of “number of occurrences,” most New York courts have found that the number of occurrences is governed not by the number



of persons injured, nor by the number of acts of negligence committed by the insured, but by the nature of the “unfortunate event.” “In determining the number of occurrences for deductible purposes, New York inquires whether multiple claims result from ‘an event of an unfortunate character that takes place without one’s foresight or expectation.’” Stonewall Ins. Co. v. Asbestos Claims Mgmt. Corp., 73 F.3d 1178, 1213 (2d Cir. 1995) (quoting Arthur A. Johnson Corp. v. Indemnity Ins. Co. of North America, 7 N.Y.2d 222, 228 (N.Y. 1959)). In assessing whether multiple claims all arise out of a single event, New York courts apply the average person’s view of whether the underlying circumstances giving rise to diverse claims are all part of a single “unfortunate event.” Arthur A. Johnson Corp., 7 N.Y.2d at 229. Some subsequent cases add that the cause of injury must be “continuous and not interrupted by other independent causes.” See, e.g., Allied Grand Doll Mfg. Co., Inc. v. Globe Indem. Co., 15 A.D.2d 901, 901 (N.Y. App. Div., 1st Dep’t 1962).

Reckless behavior or a calculated risk is an “occurrence” unless the insured intended the resulting harm. Continental Cas. Co. v. Rapid-American Corp., 609 N.E.2d 506, 510 (N.Y. 1993). “Resulting damage can be unintended even though the act leading to the damage was intentional.” Id.; see also McGroarty v. Great Am. Ins. Co., 36 N.Y. 2d 358, 364 (N.Y. 1975). However, where the insured not only took a calculated risk but acted with near certainty that a loss would occur, courts have refused to require coverage. Continental Grain Co. v. Fireman’s Fund Ins. Co., No. 95 Civ. 3871, 1997 WL 86392 (S.D.N.Y. Feb. 27, 1997). I n Stonewall Ins. Co. v. Asbestos Claims Mgmt. Corp., the 2nd Circuit found that each building installation including asbestos-containing products was a separate occurrence. 73 F.3d at 1215. Determining the single “unfortunate event” can be difficult, and often weighs against a finding of multiple occurrences. In Endicott Johnson Corp. v. Liberty Mut. Ins. Co., for instance, the U.S. District Court for the Northern District of New York found that the process of repeatedly dumping waste improperly was a single occurrence at each site where waste products were present. 928 F.Supp. 176, 181 (N.D.N.Y. 1996). See also Consolidated Edison Co. of New York, Inc. v. Employers Ins. of Wausau, 1997 WL 727486 (S.D.N.Y. Nov. 21, 1997).

• Pennsylvania: Pennsylvania has applied the “cause theory,” which holds that damage from a single cause is a single occurrence. Appalachian Ins. Co. v. Liberty Mutual Ins. Co., 676 F.2d 56, 61 (3d Cir. 1982). This has been applied in the sex

discrimination context. Id. at 62-63. It has also been applied in the context of asbestos litigation. In Centennial Ins. Co. v. Lumbermens Mutual Cas. Co., the insured’s asbestos claim was deemed to have arisen from a single occurrence based on a cause analysis. 677 F.Supp. 342, 347-348 (E.D. Pa. 1987). However, in Pittsburgh Corning Corp. v. Travelers Ind. Co., the court subsequently found that each separate asbestos claim at each site was a new “occurrence.” 1988 WL 5301 (E.D. Pa. Jan. 20, 1988). Claims for breach of contract are not covered because they are not an “accident or occurrence contemplated or covered by the provisions of a general liability insurance policy.” Redevelopment Auth. of Cambria County v. Int’l Ins. Co., 685 A.2d 581, 589 (Pa. Super 1996).

Medical Monitoring – Insurers can challenge coverage for medical monitoring claim costs as such costs would not qualify as “damages” as that term is used in insurance policies. Additionally, because medical monitoring costs are incurred for the purpose of determining whether an individual will develop a disease or sickness in the future, insurers can assert that such costs do not qualify for coverage as costs incurred “because of bodily injury during the policy period.”

Scope of Coverage – Some insurance policies contain Participant Liability Sports endorsements, which provide coverage for “those sums which you become legally obligated to pay because of actions brought against you for ‘bodily injury or property damage’ by a participant while practicing or participating in any contest or exhibition of an athletic or sports nature sponsored by you.” “Participant” is defined to include players. Insurers may want to disclaim coverage to the extent that the insured did not sponsor an event at which the player allegedly sustained bodily injury.

Some policies may contain exclusions applicable to “athletic or sports participants,” “sports contests” or “athletic activities.” These exclusions serve to limit coverage.

Athletic exclusions may also be included in the medical payments coverage. Some policies exclude “expenses for bodily injury to a person injured in athletics” or “expenses for bodily injury while the person is practicing, instructing, or participating in any physical exercise or games, sports, or athletic contests.”

Some of the policies at issue may also contain endorsements that limit coverage to specified events or particular games. These endorsements also serve to limit coverage.



Known Risk, Known Loss and Assumption of the Risk – Common law known risk, known loss and assumption of the risk defenses to coverage may apply. To the extent that the facts show that the athletes knew of the risk of concussions and repetitive head trauma from participating in high-impact sports and assumed the risk by choosing to participate in such activities, such defenses should be raised.

To read updates on the cases mentioned in this article and other sports-related head injury cases, visit http://www.freeborn.com/industry/insurance-and-reinsurance.

See Haning, Flahavan & Kelly, CAL. PRAC. GUIDE: PERSONAL INJURY (The Rutter Group 2012):

• “Special relationship” liability; sports facility operators and athletes - 2:1993

• Assumption of the risk; “occupational” - 3:239.16; 3:241-241.1

• Insurance; subrogation rights of carrier - 1:55; 3:53-53.1; 4:350; 4:469; 4:543.4; 5:206-209

• Medical monitoring damages - 3:60-65.17

PRODUCT LIABILITY

Suit over Marine crushed by helicopter fails to state a claim, judge saysThe mother and young son of a Marine who died in 2011 when the military helicopter he was repairing collapsed on him cannot proceed with a lawsuit against the aircraft’s manufacturers without alleging more specific claims, a San Diego federal judge has decided.

Fontalvo v. Sikorsky Aircraft Corp. et al., No. 3:13-cv-00331, 2013 WL 4401437 (S.D. Cal. Aug. 15, 2013).

U.S. District Judge Gonzalo P. Curiel of the Southern District of California dismissed Norma and Dominic Fontalvo’s wrongful-death suit Aug. 15, finding that the plaintiffs dressed up legal conclusions as factual allegations without including enough detail to support their claims against GE Aviation Systems and Sikorsky Aircraft Corp.

“If plaintiff intends to allege a manufacturing defect, [he] must state with some particularity how the defendants’ product either deviated from GE’s intended result or design or how the product deviated from other identical products,” Judge Curiel wrote, adding that “threadbare recitals” of a tort’s elements do not suffice to state a cause of action.

“Plaintiff simply alleges that GE and other defendants manufactured a defective product, the product was used by [Staff] Sgt. [Alexis] Fontalvo and Sgt. Fontalvo suffered fatal injuries as a result,” the judge noted.

The Fontalvos may amend their complaint, which alleges strict product liability, negligence and breach of warranty against the manufacturers of the Sikorsky CH-53E Super Stallion that crushed Alexis Fontalvo to death as he was troubleshooting it at Marine Corps Air Station Miramar in San Diego, the judge held. He gave the plaintiffs 20 days to refile.

The decision is the second major ruling against the Fontalvos. In June Judge Curiel rejected their motion to remand the suit to the San Diego County Superior Court, finding after months of sparring that the case belongs in the District Court under federal officer jurisdiction because the Defense Department at least arguably directed the Super Stallion’s design and manufacture.

To proceed further, the Fontalvos will now have to recast their claims to satisfy the federal pleading standard, which the U.S. Supreme Court has refined twice since 2007, in Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), and Ashcroft v. Iqbal, 556 U.S. 662 (2009).

Under Twombly and Iqbal, a plaintiff must allege facts sufficient, if true, to support their cause of action and detailed enough to put the defendant on notice about the specific allegations it will have to dispute. The Fontalvos have not done that, Judge Curiel said.

“Plaintiff’s complaint fails to sufficiently state what particular component or product was allegedly defective, much less allege how those components deviated from an intended result,” he wrote.

See Haning, Flahavan & Kelly, CAL. PRAC. GUIDE: PERSON-AL INJURY (The Rutter Group 2012):

• Product liability claims; causation - 2:1785; 2:2432-2435

• Pleadings; “fact pleading” requirement - 5:424; 5:438



PRODUCT LIABILITY

California jury rejects design defect claim in bike helmet injury suitA Los Angeles jury has decided that Easton-Bell Sports’ Giro Pneumo model bicycle helmet is not defective, rejecting a cyclist’s claim that its design was ineffective and allowed him to suffer severe brain damage in a 2009 accident.

Sohn v. Easton-Bell Sports Inc., No. LC095289, verdict returned (Cal. Super. Ct., L.A. County Aug. 14, 2013).

The jury in the Los Angeles County Superior Court rendered its verdict for the sports equipment maker following five hours of deliberation that capped a three-week trial, defense attorney James J. Yukevich said in a media statement.

Jurors found that the Giro Pneumo helmet’s design was “not a substantial factor” in causing plaintiff Jeffrey Sohn’s injuries. The incident occurred as Sohn was nearing the end of an 85-mile bike ride near Sunol, Calif., according to Yukevich.

Sohn sued Easton-Bell, claiming the helmet was defectively designed because of its internal “RocLoc” system that caused the helmet to rotate.

The rotation allowed the helmet to leave the left side of his head unprotected as it hit the pavement during the crash, Sohn claimed. He said the traumatic brain injury he suffered left him unable to enjoy a normal life and prevented him from enjoying cycling, one of his favorite activities.

At trial, attorneys for Easton-Bell argued that Sohn’s “helmet rotation” theory was impossible and said scratch patterns on his helmet contradicted the testimony offered by his expert witnesses. The company also maintained that Sohn improperly wore the helmet too high at the time of the accident, contrary to instructions.

“Our hearts certainly go out to Mr. Sohn and his family,” Yukevich said in the media release. “But cases like this are of exceptional significance because they demonstrate that, given a safe product and a coherent defense, most juries will exercise basic common sense despite their sympathies for the plaintiffs.”


• Product liability claims; causation - 2:1785; 2:2432-2435

• Investigation of - 2:230-231

• Design changes - 2:286-300

• History of product - 2:280-285; 2:301

• Industry standards - 2:340-343

• Obtaining product - 2:232-273

• Similar claims by others - 2:310-315; 6:19

• Similar products - 2:350

• Use instructions - 2:320-326

• Warnings - 2:320-326

The appeals court’s ruling was a “dumbing down” of Rutherford’s causation test, because the panel could not explain how the jury could reach its decision in the absence of medical evidence to guide it, Union Carbide says. The company wants the state high court to grant review to clarify how courts should apply Rutherford’s test for causation in asbestos litigation.


• Rutherford v. Owens-Illinois Inc. - 2:1799; 2:2407; 2:2409

• Asbestos-related injury or death; causation - 2:1823; 2:2405; 2:2409; 5:180.2

• Appeals; order denying motion to vacate and enter different judgment - 10:143

(ASBESTOS continued from page 2)

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