Anderson v. W.R. Grace & Co.

Plaintiffs exposed to water contaminated with tetrachloroethylene, but who hadn't developed leukemia like some co-plaintiffs, sued chemical manufacturers (defendants) for bodily injury, emotional distress, and increased risk of future illness; the defendants moved for summary judgment on the emotional-distress claims, arguing physical injury (beyond unmanifested subcellular harm) was required, and to dismiss the future-illness claims as not yet accrued.