Barron v. Martin-Marietta Corp.
United States District Court for the Northern District of California
868 F. Supp. 1203 (1994)
Morning workers loaded a single Martin-Marietta (MMC) (defendant) missile canister and were exposed to leaking fumes; afternoon workers (plaintiffs, along with the morning workers) loaded six canisters, half from MMC and half from another company, IMI, and were similarly exposed. Both groups sued MMC for negligence, claiming exposure to its canisters caused their injuries, and MMC moved for summary judgment on causation. A Navy investigation suggested toluene exposure and found comparatively low toluene levels in the two MMC canisters loaded in the afternoon.
Whether a plaintiff may satisfy the causation element of a negligence claim merely by showing that the defendant might have caused the plaintiff's injuries.