Stella Johnson, et al. v. Marathon Petroleum Corporation, et al.

Summary

The United States District Court for the Eastern District of Louisiana granted Marathon Petroleum Company LP’s motion to dismiss an amended class action complaint arising from the August 2023 fire at the Garyville Refinery. The court held that the expanded class definition did not relate back under Federal Rule of Civil Procedure 15(c), that contra non valentem did not toll prescription on a class-wide basis, and that equitable considerations did not alter those conclusions.

Holdings

1. The amended class definition did not relate back to the original complaint because, although both pleadings arose from the same refinery fire, the original complaint did not give Defendant adequate notice that Plaintiffs sought to represent persons outside the two-mile mandatory evacuation zone, and permitting the expansion would prejudice Defendant.
2. The third category of contra non valentem did not suspend prescription because Plaintiffs sought class-wide relief without showing, through individualized facts, that every proposed class member reasonably failed to act.
3. The fourth category of contra non valentem did not suspend prescription on a class-wide basis because the reasonableness of each purported class member's knowledge, action, or inaction could not be determined without individualized facts.
4. Equitable considerations did not permit Plaintiffs to avoid prescription or expand the class after the prescriptive period expired where Defendant lacked notice of the substantially broader proposed class and would be prejudiced.

Questions Presented

1. Whether the amended class action complaint, which expanded the geographic scope and potential membership of the proposed class, related back to the original complaint under Federal Rule of Civil Procedure 15(c).
2. Whether Louisiana's doctrine of contra non valentem suspended prescription for the expanded class under the third or fourth categories of the doctrine.
3. Whether equitable considerations justified allowing the amended complaint despite prescription and the absence of relation back.

Disposition

dismissed