Wright v. Willamette Industries, Inc.

F.3d 1105 (1996)

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Wright v. Willamette Industries, Inc.

United States Court of Appeals for the Eighth Circuit
F.3d 1105 (1996)

Facts

The Wright family (plaintiffs) lived in Malvern, Arkansas, near a fiberboard-manufacturing facility owned and operated by Willamette Industries, Inc. (Willamette) (defendant). Willamette’s manufacturing process resulted in the emission of particulate matter into the air. Some of the matter had been treated with formaldehyde. The Wrights filed a tort suit against Willamette, alleging that their exposure to the facility’s emissions caused them to suffer headaches, shortness of breath, sore throats, runny noses, and watery eyes. The family sought damages on multiple theories, one of which was negligence. At trial, the Wrights presented evidence proving they had inhaled particles emitted from Willamette’s facility. They also presented expert evidence regarding the levels of exposure to gaseous formaldehyde that were dangerous to human health. The jury found in the Wrights’ favor on the negligence claim and awarded $226,250 in compensatory damages. Willamette moved for judgment as a matter of law, asking the district judge to overrule the jury’s finding and enter judgment in Willamette’s favor on the basis that the Wrights failed to prove the proximate-causation element of negligence. The district judge denied the motion and entered judgment in the Wrights’ favor per the jury’s finding. Willamette appealed.

Rule of Law

Issue

Holding and Reasoning (Arnold, J.)

Dissent (Heaney, J.)

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