Skip to main content
DRAFT FOR ATTORNEY REVIEW — NOT FINAL

section 908

Citation
section 908
Parent Document
Patrick Blanks v. Fluor Corporation (2014)
Jurisdiction
Missouri (state)
Effective Date
2014-06-17

Other Sections in This Document (3438)

Full Text

1,198 chars
The verdict directors submitting the claims for punitive damages against Massey and DRIH are the same,
save for the company name and applicable date. They read:
                    If you find in favor of plaintiff (---) and against defendant A.T. Massey [DRIH]
          under Instruction Number ___ [partner compensatory verdict director for the particular
          child], and if you believe that:
                    First, the Doe Run Company Partnership allowed plaintiff (---), a resident of
          Herculaneum, to be exposed to unsafe levels of lead which originated from the smelter
          operations before April 5, 1989 [March 26, 1994], and
                    Second, before April 5, 1989, the Doe Run Company Partnership knew or had
          information from which it, in the exercise of ordinary care, should have known that such
          conduct created a high degree of probability of injury, and
                    Third, the Doe Run Company Partnership thereby showed complete indifference
          to or conscious disregard for the safety of others,
          then in Verdict _, you may find that defendant A.T. Massey [DRIH] is liable for punitive
          damages.