Anderson v. Cryovac

Anderson v. Cryovac was a landmark federal case concerning toxic contamination in Woburn, Massachusetts. The book A Civil Action documents the case and surrounding issues. The book was made into a film in 1998, starring John Travolta as Jan Schlichtmann, was loosely based on the case and related events.

Residents brought action against operator of tannery to recover for personal injuries allegedly sustained through contamination of municipal water wells by toxic solvents. The United States District Court for the District of Massachusetts, Walter Jay Skinner, J., denied residents' motion for relief from judgment in favor of tannery operator, and residents appealed. The Court of Appeals, 862 F.2d 910, remanded with directions. On remand, the District Court, 127 F.R.D. 1, found that rebuttable presumption existed that tannery operator's nondisclosure of report substantially impaired trial preparation. Subsequently, the District Court, 129 F.R.D. 394, recommended that its earlier denial of motion for relief from judgment be sustained. The Court of Appeals, Selya, Circuit Judge, held that: (1) district court did not abuse its discretion by determining that operator's failure to disclose report during pretrial discovery did not warrant relief from judgment; (2) district court did not abuse its discretion in determining that operator's nondisclosure of report was roughly equivalent to residents' improper continuation of prosecution of their claim, and thus that monetary sanctions should not be imposed upon either party; and (3) operator's nondisclosure of report did not constitute “fraud on the court” which would trigger entry of default.

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