Thanks for visiting! Welcome to a new way to research case law. You are viewing a free summary from Descrybe.ai. For citation and good law / bad law checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.
In re Methyl Tertiary Butyl Ether ("MTBE") Products Liability Litigation
Citations: 56 F. Supp. 3d 272; 2014 WL 3778176Docket: Master File No. 1:00-1898; MDL No. 1358 (SAS); No. M21-88
Court: District Court, S.D. New York; July 30, 2014; Federal District Court
Consolidated multi-district litigation involves contamination of groundwater due to the use of the gasoline additive methyl tertiary butyl ether (MTBE). The City of New York, along with its water authorities, claims that various defendants, including ExxonMobil Corporation and its affiliates, have contaminated groundwater in New York City through their handling of MTBE. Following an eleven-week jury trial, Exxon was found liable for public nuisance, negligence, trespass, and product liability, resulting in a $104.69 million judgment in favor of the City. Exxon subsequently sought to establish a court-supervised trust for the judgment funds, asserting concerns that the City might not use the money solely for constructing a water treatment facility, as intended. The City opposed Exxon’s motion, arguing it was untimely, violated a tolling agreement, lacked legal support, and that Exxon lacked standing to request the trust. The Court denied Exxon’s motion, stating that Exxon failed to demonstrate standing, as it had already paid the judgment and could not prove any injury from how the City would use the funds. The Court emphasized that, under the "injury in fact" standard, Exxon could not claim a future injury since the funds were no longer under its control. A personal injury plaintiff is not required to refund awarded damages if they decline necessary treatment or pass away before undergoing it, emphasizing that the defendant remains liable for the initial injury. In this context, Exxon lacks standing to request a reversionary trust related to damages awarded to the City, as the traditional remedy for tort claims is a lump-sum payment, and Exxon fails to justify a departure from this principle. Exxon argues that court-supervised trusts are essential in environmental remediation cases, citing cases involving trustees under CERCLA. However, those cases are not applicable here since the City's claims are based on New York common law, not a federal statute, and CERCLA does not necessitate a court-supervised trust. Exxon also references medical monitoring cases where trusts were established due to future costs in the absence of physical injury, contrasting with the City's clear present injury. The City is entitled to its lump-sum damages, already paid by Exxon, and has shown intent to construct a facility to address the contamination. While the City has not claimed to be acting as a trustee for its residents, should it misallocate the awarded funds, residents could potentially sue. Courts typically establish reversionary trusts in unique situations, such as for minors under the Federal Tort Claims Act. The City has indeed suffered an injury from MTBE contamination in the groundwater, despite not yet activating the relevant wells. The motion by Exxon is thus denied, and the court directs closure of this motion. The requested amount for a water treatment facility is specified at $250.45 million, excluding interest.