Louisiana Court Distinguishes Insurer Policy-Trigger Burden from Manufacturer Liability in Asbestos Take-Home Exposure Case

The dispute centers on Joseph Raymond Steib, Sr., who worked at Avondale Shipyards from 1968 to 2011 as a tack welder, pipefitter, and foreman. Steib alleged that he was exposed to asbestos fibers at the shipyard and subsequently brought them home on his work clothes, causing his wife, Elaine Weber Steib, to develop mesothelioma. Steib died in January 2026, and his heir, Janai Steib, was substituted as plaintiff.

Steib’s estate sued Huntington Ingalls Incorporated (formerly Avondale Shipyards) and Eagle, Inc., a supplier of asbestos-containing products. Avondale removed the case to federal court and filed crossclaims against Eagle, seeking contribution under Louisiana law. Avondale also brought direct-action claims against Eagle’s alleged insurer, Berkshire Hathaway Specialty Insurance Company.

Berkshire moved for summary judgment, arguing that Avondale failed to prove Steib was exposed to Eagle products during Berkshire’s specific policy periods in the mid-1970s. The insurer contended that Avondale’s evidence was too general and did not place Steib in proximity to Eagle products during the relevant windows.

Avondale opposed, relying on historical deposition testimony from former workers and expert opinions. It argued that Steib performed weekend overtime work cleaning engine rooms aboard cargo ships, where Eagle half-round insulation was used. Avondale maintained this circumstantial evidence created a genuine dispute of material fact regarding exposure during Berkshire’s policy periods.

U.S. District Judge Greg Gerard Guidry rejected Berkshire’s argument that Steib’s transfer to the shipfitting department narrowed the exposure window to six weeks. The court held that Steib’s own testimony and expert reports confirmed he continued weekend overtime work around insulation activities after the transfer, meaning the full policy periods remained at issue.

However, Guidry granted Berkshire’s motion because Avondale failed to connect Steib specifically to Eagle products during the policy periods. The court noted that while historical witnesses identified Eagle products at Avondale, none knew Steib or placed him in proximity to those specific products during the relevant years. The court emphasized that general evidence of Eagle products’ presence at Avondale was insufficient to trigger Berkshire’s specific policy periods under Louisiana law.

The court distinguished this case from Prive v. Eagle, Inc., where summary judgment was granted because the plaintiff could not identify the defendant’s product and no evidence placed it in his work environment. Here, multiple witnesses testified that Eagle products were regularly present in the specific shipboard environments where Steib performed his work.

Guidry denied Eagle’s motion, concluding that the record permitted a reasonable factfinder to infer Steib encountered asbestos from Eagle products during his shipboard work. The court held that the question of whether this exposure contributed to Mrs. Steib’s mesothelioma must be reserved for a jury.

Avondale’s claims against Berkshire Hathaway Specialty Insurance Company were dismissed with prejudice. Eagle remains a defendant in the case, though the original plaintiff had previously settled its claims against Eagle.