Kent Stahle v. CTS Corporation
817 F.3d 96
| 4th Cir. | 2016Background
- Kent Stahle sued CTS alleging childhood exposure to solvents dumped into Dingle Creek caused his chronic myelogenous leukemia; exposure occurred 1959–1968 and suit was filed in 2014.
- Defendant CTS moved to dismiss under N.C. Gen. Stat. § 1‑52(16), which contains a discovery‑rule accrual sentence and a ten‑year statute‑of‑repose sentence.
- The district court dismissed, holding the repose provision barred the claim; Stahle appealed.
- The Fourth Circuit reviewed de novo and framed the question as predicting how the North Carolina Supreme Court would treat § 1‑52(16) for disease claims.
- The panel concluded North Carolina law treats disease claims as legally distinct from latent personal‑injury claims and therefore § 1‑52(16) (the repose sentence) does not apply to disease claims; it reversed and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 1‑52(16) applies to disease claims | Stahle: disease claims are exempt; disease is not a “latent injury,” so repose does not bar the claim | CTS: § 1‑52(16) facially covers “personal injury,” so the 10‑year repose bars the suit | Court: § 1‑52(16) applies to latent injuries; disease is not a latent injury under NC law, so repose does not bar Stahle’s claim; reversed |
| Proper interpretation method for § 1‑52(16) | Read § 1‑52(16) in context with § 1‑52 and NC precedent; don’t isolate the text | Rely on plain text of § 1‑52(16) to apply repose broadly | Court: follow NC rules of statutory construction; read provision in context (incl. § 1‑52(5)) and NC caselaw (Wilder, Misenheimer) |
| Precedential effect of Fourth Circuit decisions (Hyer/Bullard) | Stahle: Hyer/Bullard correctly predict NC Supreme Court’s treatment of disease exception | CTS: Hyer is distinguishable and nonbinding because it treated a different statute | Court: Hyer/Bullard are binding circuit precedent and their reasoning aligns with NC precedent; even absent Hyer, NC caselaw supports the result |
| Whether Waldburger controls | Stahle: Waldburger addressed federal preemption, not scope of the state repose | CTS: Waldburger supports dismissal | Held: Waldburger resolved preemption only and does not decide whether § 1‑52(16) applies to disease claims |
Key Cases Cited
- Wilder v. Amatex Corp., 314 N.C. 550, 336 S.E.2d 66 (N.C. 1985) (North Carolina Supreme Court held the predecessor repose statute did not apply to disease claims and explained disease is legally different from latent injury)
- Hyer v. Pittsburgh Corning Corp., 790 F.2d 30 (4th Cir. 1986) (Fourth Circuit predicted NC Supreme Court would not apply statutes of repose directed at personal injury to disease claims)
- Misenheimer v. Burris, 360 N.C. 620, 637 S.E.2d 173 (N.C. 2006) (NC Supreme Court described § 1‑52(16) as the discovery rule for certain latent injuries and acknowledged ambiguity in “personal injury”)
- Dunn v. Pacific Employers Ins. Co., 332 N.C. 129, 418 S.E.2d 645 (N.C. 1992) (discussed interplay of § 1‑52(16) with wrongful death timing; relevant to analyzing whether § 1‑52(16) applies to disease)
- Bullard v. Dalkon Shield Claimants Trust, 74 F.3d 531 (4th Cir. 1996) (affirmed the distinction between disease claims and latent‑injury statutes of repose under North Carolina law)