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Steering Committee v. Exxon Mobil Corp.

461 F.3d 598 (2006)

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Steering Committee v. Exxon Mobil Corp.

United States Court of Appeals for the Fifth Circuit
461 F.3d 598 (2006)

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Facts

Residents (residents) (plaintiffs) living near a chemical plant operated by Exxon Mobil Corp. (Exxon) (defendant) sued Exxon after a failed control valve at the plant resulted in an oil leak that ignited and produced a massive smoke plume that passed over the residents’ homes. The residents sought damages from Exxon on a myriad of theories, including personal injury, emotional distress, property damage, and economic losses. The lawsuits were consolidated, and the residents moved for class certification under Federal Rule of Civil Procedure 23(b)(3). The proposed class included individuals and entities in two Louisiana parishes who suffered any legally cognizable damages. On Exxon’s motion, the district court narrowed the issues still in controversy by granting Exxon summary judgment on some of the residents’ claims. The district court also denied certification of the proposed class for failing to satisfy the predominance and superiority requirements of Rule 23(b)(3), as well as the requisite typicality and adequacy of Rule 23(a). The residents appealed the order denying class certification, arguing that the issue of Exxon’s liability with respect to the faulty valve that caused the fire predominated over any individual issues of causation or damages.

Rule of Law

Issue

Holding and Reasoning (Davis, J.)

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