Anderson v. Cryovac, Inc.

Summary

The court denied W.R. Grace & Co.’s motion under Federal Rule of Civil Procedure 11 to strike the complaint and amended complaint and dismiss the action. The court held that plaintiffs’ investigation and supporting information provided a sufficient good-faith basis for alleging that Grace contributed to groundwater contamination and that trichloroethylene contributed to plaintiffs’ illnesses.

Holdings

1. The pleadings were supported by a good-faith basis sufficient to satisfy Rule 11 because plaintiffs had conducted factual research, relied on an environmental report, consulted an environmental engineer, and possessed information supporting their allegations against Grace.
2. The absence of conclusive evidence that trichloroethylene causes leukemia did not establish a Rule 11 violation where plaintiffs had evidence that TCE caused other health problems and statistical evidence concerning leukemia in Woburn, together with expert support for the allegations.

Questions Presented

1. Whether plaintiffs' complaint and amended complaint were supported by sufficient factual and scientific information to satisfy Federal Rule of Civil Procedure 11.
2. Whether the court should strike the pleadings or dismiss the action under Rule 11 based on plaintiffs' alleged lack of conclusive evidence linking Grace's chemicals to leukemia.

Disposition

other