Richard v. Hoechst Celanese Chemical Group, Inc.
Plaintiff Richard filed a class action lawsuit against Hoechst Celanese Chemical Group, Inc., Shell Oil Co., and E.I. DuPont de Nemours & Co., alleging damages from defective polybutylene plumbing systems and asserting RICO and Due Process claims. The court asserted subject matter jurisdiction over the RICO claim but dismissed the Due Process claim based on the Rooker-Feldman doctrine. The plaintiff's motion for preliminary class certification was denied, citing Fifth Circuit precedent on the difficulty of certifying RICO class actions due to the individual reliance requirement. Ultimately, the court granted the defendants' motions to dismiss for failure to state a claim, concluding that the plaintiff failed to establish direct reliance on alleged misrepresentations as mandated by controlling Fifth Circuit precedent, Summit Properties v. Hoechst Celanese Corp. The court also rejected arguments for equitable relief under RICO as a way to avoid the reliance requirement.