## Facts

- Willamette Industries operated a fiberboard manufacturing plant near Malvern, Arkansas, using a urea–formaldehyde resin in its process.
- The plant emitted particulate matter into the air, including particles treated with formaldehyde.
- The Wright family lived near the plant and reported symptoms including headaches, sore throats, watery eyes, runny noses, dizziness, and shortness of breath.
- The Wrights presented evidence that wood-fiber particles containing formaldehyde were found in their homes and in urine samples.
- The Wrights sued in federal court under diversity jurisdiction, asserting negligence and other theories based on alleged toxic exposure.
- A jury found for the Wrights on negligence and awarded $226,250 in compensatory damages for five plaintiffs.
- Willamette moved for judgment as a matter of law under Rule 50(b), arguing insufficient evidence of proximate cause; the district court denied the motion.

## Issues

1. Whether the evidence was sufficient to submit the Wrights’ negligence claim to the jury, particularly on proximate causation.
2. Whether, in a toxic-exposure negligence case, plaintiffs must prove hazardous exposure levels generally and the plaintiffs’ actual exposure levels to establish causation.

## Decision

- The Eighth Circuit reversed the judgment for the Wrights.
- The court held the Wrights failed to present legally sufficient evidence of proximate cause because they did not prove exposure to a hazardous level of the relevant substance.
- The court directed entry of judgment as a matter of law for Willamette on the negligence claim.

## Legal Principles

- On Rule 50(b) review, judgment as a matter of law is improper unless the evidence permits no reasonable inference supporting the nonmovant.
- In toxic-tort negligence actions, plaintiffs must prove both (a) the levels of exposure hazardous to humans generally (general causation) and (b) the plaintiffs’ actual level of exposure to the defendant’s substance (specific causation).
- Proof that a contaminant is present in a plaintiff’s environment, without proof of dose and a basis to infer probable causation of the complained-of injuries, is insufficient as a matter of law.
- Exact quantification is not always required, but the record must allow a reasonable factfinder to conclude the exposure level probably caused the alleged injuries.

## Conclusion

The court set aside the plaintiffs’ negligence verdict because the evidence showed exposure to formaldehyde-containing particulates but did not establish that the plaintiffs’ exposure reached hazardous levels or that it probably caused their symptoms, requiring judgment for the defendant.


Wright v. Willamette Indus., Inc., 91 F.3d 1105 (8th Cir. 1996)