Union Carbide Corporation v. Daisey E. Synatzske and Grace Annette Webb, Individually and as Representatives and Co-Executrixes of the Estate of Joseph Emmite, Sr., Joseph Emmite, Jr., Dorothy A. Day, Vera J. Gialmalva and James R. Emmite
Joseph Emmite Sr. was exposed to asbestos while working for Union Carbide, leading to his death from asbestosis. His family, the Emmites, filed a wrongful death claim. Union Carbide moved to dismiss the claims, arguing that the Emmites failed to timely serve a compliant physician report as required by Chapter 90 of the Texas Civil Practice and Remedies Code. The MDL pretrial court denied Union Carbide's motions. On appeal, the Court of Appeals affirmed the MDL pretrial court's order, finding that while the submitted physician reports did not satisfy the specific pulmonary function testing requirement of Chapter 90, applying that requirement retroactively to the Emmites' case, where the deceased could not undergo such testing, would be unconstitutional under the Texas Constitution's prohibition against retroactive laws.