Satterfield v. J.M. Huber Corp.

888 F. Supp. 1567 (1995)

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Satterfield v. J.M. Huber Corp.

United States District Court for the Northern District of Georgia
888 F. Supp. 1567 (1995)

  • Written by Liz Nakamura, JD

Facts

Elaine Satterfield (plaintiff) owned property located approximately one mile away from J.M. Huber Corporation’s (Huber) (defendant) oriented-strand board (OSB) plant. OSB is a type of engineered wood similar to particle board. Satterfield raised toxic-tort claims against Huber sounding in negligence, trespass, and nuisance, arguing that the chemicals released by Huber’s plant had caused both personal injuries to Satterfield and damage to her real and personal property. Specifically, as to the trespass claim, Satterfield alleged that she had seen smoke from Huber’s plant invade her property and that the invading smoke had diminished her property value. There were numerous potential sources of smoke surrounding Satterfield’s property other than Huber’s plant, and Satterfield admitted she was unable to see Huber’s plant from her property. Satterfield did not introduce any scientific evidence or expert testimony to support her claims against Huber. Huber moved for summary judgment, arguing that Satterfield had failed to meet her burden of proof to establish that the personal injuries and property damages alleged had been caused by Huber’s chemical emissions.

Rule of Law

Issue

Holding and Reasoning (O’Kelley, J.)

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