Satterfield v. Breeding Insulation Co.

From 1973 to 1975, and again from 1978 to 1984, Doug Satterfield (plaintiff) was employed at an aluminum-manufacturing plant operated by Alcoa, Inc. (defendant). Satterfield’s duties at Alcoa brought him into daily contact with asbestos dust and fibers. Since the 1960s, Alcoa was aware that asbestos posed health dangers not only to employees, but also to the families of employees who were exposed to asbestos through the work clothing that employees wore home. In 1972, the Occupational Safety and Health Administration (OSHA) issued guidelines restricting employees with asbestos exposure from laundering their work clothes at home. Despite OSHA’s regulations and Alcoa’s knowledge that work clothes spread asbestos to family members, Alcoa did not educate Satterfield regarding the risks of asbestos. Alcoa did not provide protective coveralls, did not launder its employees’ clothing, and discouraged its employees from using on-site bathing facilities. Satterfield’s adult daughter, Amanda, developed mesothelioma, allegedly from her exposure to asbestos borne home on her father’s clothing. Amanda sued Alcoa for negligently failing to take reasonable care to protect her from the foreseeable risk of harm she faced from Satterfield’s asbestos exposure. Amanda died at age 25, shortly after filing suit. As the personal representative of Amanda’s estate, Satterfield stepped into his daughter’s shoes as plaintiff. Alcoa argued that it did not owe a duty of care to Amanda, because it had no special relationship with her and was under no affirmative obligations to act. Alcoa moved to dismiss Satterfield’s complaint, and the trial court granted Alcoa’s motion. The appellate court reversed and remanded the case. Alcoa applied to take an interlocutory appeal, which the supreme court granted.