Sawyer v. Union Carbide Corporation (2018)

Our plain-English summary of Sawyer v. Union Carbide Corporation (U.S. District Court, District of Maryland, January 10, 2018).

The estate, widow and children of Joseph Morris sued Foster Wheeler and many other companies in Baltimore City Circuit Court. They said Morris died of mesothelioma, diagnosed in December 2014, after asbestos exposure while working as a riveter heater and boilermaker in the boiler shop at the Sparrows Point shipyard from 1948 into the 1970s. Foster Wheeler removed the case to federal court under the federal officer removal statute, saying it made boilers for Navy ships under Navy contracts. The district court first sent the case back to state court. The Fourth Circuit reversed and told the district court to decide whether removal was timely. The question was when the 30-day removal period began. The court held it began with a co-worker's December 11, 2015 deposition, which said he and Morris built Navy ships in the boiler shop. Earlier discovery, including a list of ships built at the yard, did not show that Morris worked on Navy ships. Removal on January 11, 2016 was timely, and the motion to remand was denied.

We wrote this summary from the court's opinion with the help of AI. It is not the court's wording, and it is not legal advice. The full opinion is below.

The decision

• Court: U.S. District Court, District of Maryland
• Decided: January 10, 2018
• Stage: Jurisdiction, venue or removal
• State: Maryland

Outcome. The district court denied the plaintiffs' renewed motion to remand, holding that Foster Wheeler's federal officer removal was timely, so the case stays in federal court.

What the court held. Under 28 U.S.C. § 1446(b)(3), the 30-day removal clock starts when a paper first shows within its four corners the nexus among the decedent, the defendant and Navy work, without inquiry into the defendant's subjective knowledge.

Issues decided: Government Contractor Defense and Removal, Venue, Removal and Transfer.

The people and their exposure

• Joseph W. Morris: mesothelioma; died

Who	Work	Where	When	Products
Joseph W. Morris	riveter heater and boiler maker in the boiler shop (shipyards and maritime work)	Bethlehem Steel Sparrows Point Shipyard, Maryland	1948 through the 1970s	Foster Wheeler boilers

The defendants

• Foster Wheeler, LLC (manufacturer)
• Union Carbide Corporation (manufacturer)

Other decisions in this case

Other rulings from the same court in the same case, in our library:

• Sawyer v. Union Carbide Corporation (April 20, 2016). The court granted the plaintiffs' motion to remand the case to Baltimore City state court, finding Foster Wheeler failed to establish a colorable federal contractor defense or a causal nexus needed for federal officer removal.
• Sawyer v. Union Carbide Corporation (April 29, 2019). The court granted the plaintiffs' motion for partial summary judgment, barring Foster Wheeler's sophisticated user and superseding cause defenses; Foster Wheeler lost on both.

Decisions this opinion cites

Earlier decisions in our library that the court cited:

• Sawyer v. Foster Wheeler LLC (U.S. Court of Appeals, Fourth Circuit, 2017). The Fourth Circuit reversed the district court's remand order, holding Foster Wheeler met the federal officer removal requirements of § 1442(a)(1), and remanded for the district court to decide whether the removal notice was timely.
• Citrano v. John Crane-Houdaille, Inc. (U.S. District Court, District of Maryland, 2014). The district court denied the plaintiffs' motion to remand the case to state court, or to sever and remand the claims against the non-removing defendants, so General Electric kept its federal forum.

The court's opinion

The text below is Google Scholar's copy of the court's opinion, a public record. Numbers in brackets, such as [*921], mark where each page of the printed reporter begins.

JAYNA SAWYER, etal.,

v.

UNION CARBIDE CORPORATION, etal.

Civil No. CCB-16-118.

January 10, 2018.

United States District Court, D. Maryland.

Janya Sawyer, Representative of the Estate of Joseph W. Morris, Garnette Morris, Individually and as Surviving Spouse of Joseph W. Morris, Nancy Pike, Surviving Child of Joseph W. Morris, Edward Morris, Surviving Child of Joseph W. Morris, Wayne Morris, Surviving Child of Joseph W. Morris & Joanne Traynor, Surviving Child of Joseph W. Morris, Plaintiffs, represented by William G. Minkin, Law Offices of Peter G. Angelos & James Steven Zavakos, Law Offices of Peter G. Angelos.

John Crane-Houdaille, Inc., formerly known as Crane Packing Company & Selby, Battersby & Company, Defendants, represented by Laura A. Cellucci, Miles and Stockbridge PC, Scott Jeffrey Richman, Miles and Stockbridge PC & Timothy McDevitt Hurley, Miles and Stockbridge PC.

Owens-Illinois Glass Co., formerly known as Owens-Illinois, Inc., Defendant, represented by Randolph L. Burns, The Burns Law Firm PC.

Foster Wheeler Corporation, Cooper Industries, Inc., Individually and as Successors in Interest to other Crouse Hinds Co. & Pfizer, Inc., Defendants, represented by John C. Ruff, DeHay and Elliston LLP & Patrick C. Smith, Dehay and Elliston LLP. Hopeman Brothers, Inc., Wayne Manufacturing Corporation & Lofton Corporation, as Successor-in-Interest to other Wayne Manufacturing Corporation other Hopeman Manufacturing Corporation, Defendants, represented by David W. Allen, Goodell DeVries Leech and Dann LLP, Malcolm Sean Brisker, Goodell DeVries Leech and Dann LLP & Terri Lynn Goldberg, Goodell DeVries Leech and Dann LLP.

Universal Refractories Company & Koppers Company, Inc., Defendants, represented by Jason Sean Garber, Moore & Jackson LLC.

CBS Corporation, a Delaware Corporation formerly known as Viacom, Inc. other CBS Corporation, a Pennsylvania Corp. formerly known as Westinghouse Electric Corp. & International Paper Company, Individually and as Successor in Interest to other Champion International Corporation other U.S. Plywood Corp., Defendants, represented by Philip A. Kulinski, Evert Weathersby Houff & Clare Marie Maisano, Evert Weathersby Houff.

J.H. France Refractories Co. & Paramount Packing & Rubber, Inc., Defendants, represented by Geoffrey S. Gavett, Gavett Datt and Barish PC & Laura D. Abenes, Gavett, Datt Barish PC.

The Goodyear Tire & Rubber Co, Wallace & Gale Asbestos Settlement Trust, Successor to the other Wallace & Gale Company & Crown, Cork & Seal Co., Inc., Defendants, represented by Theodore F. Roberts, Venable LLP & Scott Mason Richmond, Venable LLP.

MCIC, Inc., and its Remaining Director of Trustees, Robert I. McCormick, Elizabeth McCormick and Patricia Shunk, Defendant, represented by Louis E. Grenzer, Jr., Bodie, Dolina, Hobbs, Friddell & Grenzer, PC.

Metropolitan Life Insurance Co., Defendant, represented by Cheri V. Koerner, Steptoe & Johnson LLP, Stephen Anthony Fennell, Steptoe and Johnson LLP & Jamie Michelle Hertz, Steptoe & Johnson LLP.

General Electric Company, Defendant, represented by Donald S. Meringer, Meringer Zois and Quigg LLC. Ferro Engineering Division of On Marine Services Company, Defendant, represented by Jennifer M. Alexander, Brassel Alexander & Rice LLC & Jon W. Brassel, Brassel Alexander & Rice.

Foseco, Inc. & Georgia-Pacific, LLC, Ind/Successor to other BestWall Gypsum Co., Defendants, represented by Laura A. Cellucci, Miles and Stockbridge PC & Scott Jeffrey Richman, Miles and Stockbridge PC.

Schneider Electric USA, Inc., formerly known as Square D Company, Defendant, represented by Neil Joseph MacDonald, MacDonald Law Group, LLC & Rachelle A. Schofield, MacDonald Law Group, LLC.

Greene, Tweed & Co., Individually and as Successor in Interest to other Palmetto, Inc., Defendant, represented by Andrew William Gaudreau, Goldberg Segalla & Thomas Peter Bernier, Goldberg Segalla.

Phelps Packing & Rubber Co., other Phelps Industrial, Defendant, represented by William Carlos Parler, Jr., Parler and Wobber LLP.

Lloyd E. Mitchell, Inc., Defendant, represented by Helyna M. Haussler, Wilson Elser Moskowitz Edelman and Dicker LLP & Jason Richard Waters, Wilson Elser Moskowitz Edelman and Dicker.

Pecora Corporation, Individually and as Successor in Interest to other Pecora, Inc. other New Pecora Corp., Defendant, represented by Michael Thomas Hamilton, Marks ONeill OBrien Doherty and Kelly PC & Sebastian Goldstein, Marks, O Neill, O Brien, Doherty & Kelly, P.C.

MCIC, Inc., ThirdParty Plaintiff, represented by Louis E. Grenzer, Jr., Bodie, Dolina, Hobbs, Friddell & Grenzer, PC. A.W. Chesterton Company, ThirdParty Defendant, represented by Benjamin D. Whetzel, Segal McCambridge Singer and Mahoney Ltd. & Thomas Peter Bernier, Goldberg Segalla.

SB Decking Inc., formerly known as Selby, Battersby & Co., Inc., ThirdParty Defendant, represented by Joshua Franklin Kahn, Miles and Stockbridge PC.

John Crane-Houdaille, Inc., Cross Claimant, represented by Laura A. Cellucci, Miles and Stockbridge PC, Scott Jeffrey Richman, Miles and Stockbridge PC & Timothy McDevitt Hurley, Miles and Stockbridge PC.

Bayer Cropscience, Inc., Individually and as Successor In Interest to & Union Carbide Corporation, Cross Defendants, represented by Danielle Grilli Marcus, Whiteford Taylor and Preston LLP, Peter Woodward Sheehan, Whiteford Taylor and Preston LLP & Thurman W. Zollicoffer, Jr., Whiteford Taylor and Preston LLP.

CBS Corporation, a Delaware Corporation & International Paper Company, Individually and as Successor in Interest to, Cross Defendants, represented by Philip A. Kulinski, Evert Weathersby Houff & Clare Marie Maisano, Evert Weathersby Houff.

Cooper Industries, Inc., Individually and as Successors in Interest to, Foster Wheeler Corporation & Pfizer, Inc., Cross Defendants, represented by John C. Ruff, DeHay and Elliston LLP & Patrick C. Smith, Dehay and Elliston LLP. Crown, Cork & Seal Co., Inc., The Goodyear Tire & Rubber Co & Wallace & Gale Asbestos Settlement Trust, Successor to the, Cross Defendants, represented by Theodore F. Roberts, Venable LLP.

Ferro Engineering Division of On Marine Services Company, Cross Defendant, represented by Jennifer M. Alexander, Brassel Alexander & Rice LLC, Jon W. Brassel, Brassel Alexander & Rice & Kelly Sullivan Kylis, Brassel Alexander & Rice, LLC.

Foseco, Inc. & Georgia-Pacific, LLC, Ind/Successor to, Cross Defendants, represented by Laura A. Cellucci, Miles and Stockbridge PC & Scott Jeffrey Richman, Miles and Stockbridge PC.

General Electric Company, Cross Defendant, represented by Donald S. Meringer, Meringer Zois and Quigg LLC. Greene, Tweed & Co., Individually and as Successor in Interest to, Cross Defendant, represented by Andrew William Gaudreau, Goldberg Segalla & Thomas Peter Bernier, Goldberg Segalla.

Hopeman Brothers, Inc., Lofton Corporation, as Successor-in-Interest to & Wayne Manufacturing Corporation, Cross Defendants, represented by David W. Allen, Goodell DeVries Leech and Dann LLP, Malcolm Sean Brisker, Goodell DeVries Leech and Dann LLP & Terri Lynn Goldberg, Goodell DeVries Leech and Dann LLP.

J.H. France Refractories Co. & Paramount Packing & Rubber, Inc., Cross Defendants, represented by Geoffrey S. Gavett, Gavett Datt and Barish PC & Laura D. Abenes, Gavett, Datt Barish PC.

Koppers Company, Inc. & Universal Refractories Company, Cross Defendants, represented by Jason Sean Garber, Moore & Jackson LLC.

Lloyd E. Mitchell, Inc., Cross Defendant, represented by Helyna M. Haussler, Wilson Elser Moskowitz Edelman and Dicker LLP & Jason Richard Waters, Wilson Elser Moskowitz Edelman and Dicker.

MCIC, Inc., and its Remaining Director of Trustees, Robert I. McCormick, Elizabeth McCormick and Patricia Shunk, Cross Defendant, represented by Louis E. Grenzer, Jr., Bodie, Dolina, Hobbs, Friddell & Grenzer, PC.

Metropolitan Life Insurance Co., Cross Defendant, represented by Cheri V. Koerner, Steptoe & Johnson LLP & Stephen Anthony Fennell, Steptoe and Johnson LLP.

Owens-Illinois Glass Co., Cross Defendant, represented by Randolph L. Burns, The Burns Law Firm PC. Pecora Corporation, Individually and as Successor in Interest to, Cross Defendant, represented by Michael Thomas Hamilton, Marks ONeill OBrien Doherty and Kelly PC & Sebastian Goldstein, Marks, O Neill, O Brien, Doherty & Kelly, P.C. Phelps Packing & Rubber Co., Cross Defendant, represented by William Carlos Parler, Jr., Parler and Wobber LLP. Schneider Electric USA, Inc., Cross Defendant, represented by Neil Joseph MacDonald, MacDonald Law Group, LLC. Selby, Battersby & Company & John Crane-Houdaille, Inc., Cross Defendants, represented by Laura A. Cellucci, Miles and Stockbridge PC, Scott Jeffrey Richman, Miles and Stockbridge PC & Timothy McDevitt Hurley, Miles and Stockbridge PC. Phelps Packing & Rubber Co., Cross Claimant, represented by William Carlos Parler, Jr., Parler and Wobber LLP. J.H. France Refractories Co. & Paramount Packing & Rubber, Inc., Cross Claimants, represented by Geoffrey S. Gavett, Gavett Datt and Barish PC & Laura D. Abenes, Gavett, Datt Barish PC.

Cooper Industries, Inc., Individually and as Successors in Interest to, Pfizer, Inc. & Foster Wheeler Corporation, Cross Claimants, represented by John C. Ruff, DeHay and Elliston LLP & Patrick C. Smith, Dehay and Elliston LLP. Greene, Tweed & Co., Individually and as Successor in Interest to, Cross Claimant, represented by Andrew William Gaudreau, Goldberg Segalla & Thomas Peter Bernier, Goldberg Segalla.

Foseco, Inc. & Georgia-Pacific, LLC, Ind/Successor to, Cross Claimants, represented by Laura A. Cellucci, Miles and Stockbridge PC & Scott Jeffrey Richman, Miles and Stockbridge PC.

Selby, Battersby & Company, Cross Claimant, represented by Laura A. Cellucci, Miles and Stockbridge PC, Scott Jeffrey Richman, Miles and Stockbridge PC & Timothy McDevitt Hurley, Miles and Stockbridge PC.

MCIC, Inc., and its Remaining Director of Trustees, Robert I. McCormick, Elizabeth McCormick and Patricia Shunk, Cross Claimant, represented by Louis E. Grenzer, Jr., Bodie, Dolina, Hobbs, Friddell & Grenzer, PC.

Union Carbide Corporation & Bayer Cropscience, Inc., Individually and as Successor In Interest to, Cross Claimants, represented by Danielle Grilli Marcus, Whiteford Taylor and Preston LLP, Peter Woodward Sheehan, Whiteford Taylor and Preston LLP & Thurman W. Zollicoffer, Jr., Whiteford Taylor and Preston LLP.

SB Decking Inc., Cross Defendant, represented by Joshua Franklin Kahn, Miles and Stockbridge PC.

International Paper Company, Individually and as Successor in Interest to & CBS Corporation, a Delaware Corporation, Cross Claimants, represented by Philip A. Kulinski, Evert Weathersby Houff & Clare Marie Maisano, Evert Weathersby Houff.

Lloyd E. Mitchell, Inc., Cross Claimant, represented by Helyna M. Haussler, Wilson Elser Moskowitz Edelman and Dicker LLP & Jason Richard Waters, Wilson Elser Moskowitz Edelman and Dicker.

Pecora Corporation, Individually and as Successor in Interest to, Cross Claimant, represented by Michael Thomas Hamilton, Marks ONeill OBrien Doherty and Kelly PC & Sebastian Goldstein, Marks, O Neill, O Brien, Doherty & Kelly, P.C.. MEMORANDUM

CATHERINE C. BLAKE, District Judge.

The estate of Joseph Morris, his surviving spouse, and his surviving children sued Foster Wheeler, LLC ("Foster Wheeler") in the Circuit Court for Baltimore City. Morris died from mesothelioma, and the plaintiffs claim under various state law theories that the defendants were responsible for exposing him to the asbestos that caused his disease. Foster Wheeler removed Morris's action to this court under the federal officer removal statute, 28 U.S.C. § 1442(a)(1). This court initially remanded the case to state court. On appeal, the Fourth Circuit reversed that order, and remanded the case to this court for further proceedings. Now pending again is the plaintiffs' renewed motion to remand the case to state court. The issues have been fully briefed, and no hearing is necessary. See Local R. 105.6 (D. Md. 2016). For the reasons stated below, the court will deny the plaintiffs' motion to remand.

BACKGROUND

The plaintiffs claim that Morris was diagnosed with asbestos-related mesothelioma on December 1, 2014, and died as a result of this disease on March 1, 2015. (Compl. 12-13, ECF No. 2.) Allegedly he was exposed to asbestos at Bethlehem Steel Sparrows Point Shipyard (the "shipyard"), where he worked as a "riveter heater and boiler maker in the `boiler shop'" from 1948 through the 1970s. (Compl. 12; Pls.' Mot. Remand 3, ECF No. 138-1.) The plaintiffs filed their complaint in the Circuit Court for Baltimore City on June 5, 2015, alleging theories of strict liability, breach of warranty, negligence, fraud, conspiracy, market share liability, loss of consortium, and wrongful death. (Compl. 10.) Foster Wheeler filed its notice of removal on January 11, 2016. Foster Wheeler claims it "manufactured marine boilers and auxiliary equipment for use on Navy ships pursuant to contracts and specifications executed by the Navy." (Notice of Removal ¶ 6, ECF No. 1.) The defendant's basis for removal is that Foster Wheeler was acting under an officer or agency of the United States within the meaning of 28 U.S.C. § 1442(a)(1) in the manufacture and sale of boilers for the Navy.

The plaintiffs moved to remand to state court on February 9, 2016, and this court granted that motion on the grounds that Foster Wheeler had not established a colorable federal defense, nor a causal nexus between the plaintiffs' claims and actions taken by Foster Wheeler under color of federal law. The plaintiffs appealed, and the Fourth Circuit reversed. Sawyer v. Foster Wheeler LLC, 860 F.3d 249, 259 (4th Cir. 2017). The Fourth Circuit remanded the case for further consideration regarding the timeliness of removal. Id.

ANALYSIS

To remove a case, the defendant ordinarily must file a notice of removal in the district court within 30 days after receiving the initial pleading. 28 U.S.C. § 1446(b)(1). Where, as here, the complaint does not provide sufficient details of the plaintiffs' claims to demonstrate that the claims are removable, the defendant may remove within 30 days of receiving "an amended pleading, motion, order or other paper from which it may first be ascertained that the case is one which is or has become removable." 28 U.S.C. § 1446(b)(3). The "other paper" requirement "is broad enough to include any information received by the defendant, whether communicated in a formal or informal manner." Yarnevic v. Brink's, Inc., 102 F.3d 753, 755 (4th Cir. 1996) (internal quotation marks omitted). The grounds for removal must be "apparent within the four corners of the initial pleading or subsequent paper." Citrano v. John-Crane-Houdaille, Inc., 1 F.Supp.3d 459, 465 (D.Md. 2014) (quoting Lovern v. General Motors Corp., 121 F.3d 160, 162 (1997)). The court is not required "to inquire into the subjective knowledge of the defendant." Id; see also Houser v. Ammco Tools, a/k/a Hennessy Industries, Inc., 2013 WL 3364377, [*3]-[*4] (D.Md. July 2, 2013) (holding identification "of the exact U.S. Navy ships on which the plaintiff was allegedly exposed to the defendant's asbestos products gave the defendants adequate notice to trigger the thirty-day removal limitation"); Covington v. Owens Illinois Glass Co., 2012 WL 4764883, [*2] (D.Md. Oct. 5, 2012) (stating "[Defendant] does not bear the burden of conducting outside research in order to ascertain whether the Complaint is removable."); Bing v. Alltite Gaskets, 2012 WL 4764774, [*2] (D.Md. Oct. 5, 2012); Hurley v. Alltite Gaskets, 2012 WL 4764901, [*2] (D.Md. Oct. 5, 2012).[1]

The unreported Covington, Bing, Hurley, and Houser decisions are particularly instructive to this case. Those cases also involved asbestos exposure during shipyard work. In each case, removal was proper only once "the triangular nexus between Decedent, [the defendant], and the U.S. Navy Vessel allegedly a part of the asbestos exposure" was identified through identification of the specific Navy ships upon which the decedent allegedly worked and was exposed to the defendant's product.

Foster Wheeler argues that its January 11, 2016, notice of removal was timely because it was filed within 30 days of David Williams's deposition on December 11, 2015. (Notice of Removal ¶¶ 2-3.) In his deposition, Williams said he worked in the boiler shop of the shipyard, and Morris was "[t]he helper most of the time" when Williams worked there. (Williams Dep. 11, 13, Notice of Removal Ex. B, ECF No. 1-1.) Foster Wheeler claims it was first ascertainable that the case was removable when Williams responded to the question, "Do you know the names of any of the ships that you were building boilers for?" (Williams Dep. 68.) Williams testified, "No. When I went there, I knew Vietnam War and we were building Navy ships for that, but as far as the names and things like that, no." (Id.)

The plaintiffs claim that Foster Wheeler was aware of the information contained in Williams's testimony no later than November 30, 2015, when the plaintiffs filed interrogatories and document requests directed to Foster Wheeler, which provided Foster Wheeler with a list of ships constructed at the shipyard from 1948 through 1979. (Interrog. No. 11, Mot. Remand Ex. 9, ECF No. 138-12.) Some of those ships were designated as "USS," or "United States Ship," in the interrogatory, and the plaintiffs asked Foster Wheeler to provide all documents and information relating to the construction of boilers for use on these ships. (Id.) The plaintiffs had previously provided an answer to an interrogatory indicating that Morris was exposed to asbestos from Foster Wheeler boilers in his work as a boilermaker at the shipyard from 1948 through the 1970s. (Pls.' Suppl. Answers to Interrogs. 4, Mot. Remand Ex. 8, ECF No. 138-11.) Together, these two pieces of information alerted Foster Wheeler that some Navy ships were built at the shipyard during the time period that Morris was allegedly exposed to asbestos while constructing Foster Wheeler boilers.

As noted above, the Fourth Circuit has cautioned against inquiring into defendant's subjective knowledge. Whether Morris actually worked on any of the Naval ships mentioned in the list of ships constructed from 1948 to 1979 is not apparent from within the four corners of the combined discovery materials provided by plaintiffs. The Covington, Bing, Hurley, and Houser cases each required identification of the specific ship(s) connected with asbestos exposure. A list of ships constructed in the shipyard while Morris was employed there, only some of which were Naval, falls short of this standard of specificity. Therefore, Williams's testimony is the first "paper" that establishes within its four corners the "triangular nexus" between Morris, Foster Wheeler, and work undertaken for the U.S. Navy. Even though the testimony does not identify the specific U.S. Naval ships involved, Williams did clearly state that he worked with Morris while constructing U.S. Navy ships for the Vietnam War.

The plaintiffs also claim that their designation of Foster Wheeler corporate designee Mr. Christenson on their witness list of September 8, 2015, triggered the removal clock. They claim the Fourth Circuit relied on U.S. Naval contracts that were referred to in Christenson's deposition, and not in Williams's deposition. This claim is based on the Fourth Circuit's statement, "the record shows that during Morris' tenure as an employee at Sparrows Point Shipyard, Foster Wheeler manufactured boilers under contracts with the U.S. Navy for use on its vessels." Sawyer v. Foster Wheeler LLC, 860 F.3d at 255.

Yet, the Fourth Circuit's statement is merely a summation of the same facts discussed above: that U.S. Navy ships were constructed in the shipyard while Morris was allegedly exposed to asbestos through his work there. The Fourth Circuit's statement does not demonstrate that Christenson's deposition identified the clear nexus within its four corners as needed to trigger the removal clock. Merely listing Christenson and expecting defendants to obtain and review the 1994 transcript, which in any event contained no reference to Morris, is again attempting to place an investigative burden on the defendant not warranted under case law.

The required nexus was first identified by Williams's testimony on December 11, 2015. Removal on January 11, 2016, was within 30 days of that testimony and is timely. The plaintiffs' motion to remand will be denied.

A separate order follows.

[1] Unpublished opinions are cited not as precedent, but for the soundness of their reasoning.

Sources

• The opinion on Google Scholar
• Maryland asbestos laws
• Maryland asbestos exposure sites