ARONIMINK GOLF CLUB, INC. v. E.I. DUPONT NEMOURS AND COMPANY
2:16-cv-00283
E.D. Pa.Aug 14, 2017Background
- DuPont manufactured Imprelis herbicide; after reports of damage, EPA suspended sales and DuPont created a Claim Resolution Process and later a class settlement (preliminarily approved Feb 12, 2013; finally approved Oct 17, 2013).
- The Settlement established a self-applicator class covering persons/entities who purchased and applied Imprelis between Aug 31, 2010 and Aug 21, 2011; class members who did not opt out released DuPont from broadly defined Imprelis-related claims.
- Aronimink Golf Club applied Imprelis in May 2011 (within the class period) and again in May 2012 (after the class period); Aronimink did not opt out and is not listed among opt-outs.
- Aronimink filed a warranty claim with DuPont in July 2014 (denied), then sued in state court for 2012 application damages; DuPont removed and moved to dismiss or enjoin based on class release.
- The Court converted the motion to one for summary judgment limited to the class-membership issue, allowed narrow discovery (including spray records), and considered undisputed evidence that Aronimink applied Imprelis in May 2011.
- The Court concluded that because Aronimink is a self-applicator class member who did not opt out, its claims arising from Imprelis (including damages from the 2012 application) are barred by the Settlement and final judgment; summary judgment granted for DuPont.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Aronimink is bound by the Settlement release and barred from suing DuPont | Aronimink contends its 2012 application and resulting damages are independent of any 2011 application and the Settlement only resolved claims tied to class-period (2010–2011) applications | DuPont argues class membership is binary (Aronimink applied in May 2011), Aronimink did not opt out, and the Settlement release covers claims "arising from or relating to Imprelis," not limited to the class-period application | Court held Aronimink is a class member and, having not opted out, its Imprelis claims are released and barred; granted summary judgment for DuPont |
| Whether Settlement notice or agreement ambiguously failed to inform class members they would release post-class-period damages | Aronimink invokes due process precedents, arguing notice confined scope to class-period harms | DuPont contends the Settlement and Notice plainly disclose broad released claims and class membership requirements; no ambiguity supporting Aronimink | Court found Settlement language unambiguous and binding; due-process argument rejected |
| Whether discovery was necessary to oppose summary judgment under Rule 56(d) | Aronimink sought discovery on paid claims outside class period, settlement negotiations, and claim denial reasons | DuPont opposed; Court previously denied broad discovery and limited scope here | Court denied further Rule 56(d) relief and refused to reopen previously denied discovery; summary judgment proceeded |
| Whether an injunction under the All Writs Act is warranted to bar Aronimink's suit | N/A (Aronimink opposes injunction implicitly) | DuPont alternatively sought an injunction to enforce the Settlement and final judgment | Because the Court granted summary judgment on release/res judicata grounds, an injunction was unnecessary; claims dismissed |
Key Cases Cited
- Kaucher v. Cnty. of Bucks, 455 F.3d 418 (3d Cir. 2006) (standard for genuine dispute at summary judgment)
- Anderson v. Liberty Lobby, 477 U.S. 242 (1986) (summary judgment burden and view of evidence for nonmoving party)
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (movant's initial burden and nonmoving party's obligation to show material fact)
- Betts v. New Castle Youth Dev. Ctr., 621 F.3d 249 (3d Cir. 2010) (unsupported assertions cannot defeat summary judgment)
- In re Diet Drugs Prods. Liab. Litig., 369 F.3d 293 (3d Cir. 2004) (due process cautions about binding absent class members on terms not made explicit in notice)