ABC Textiles, Inc. has a textile production facility located in Palm City,

ABC Textiles, Inc. has a textile production facility located in Palm City, FL. It lies along a river that is used for drinking water for the surrounding town and is therefore tested regularly for chemical contaminants according to EPA standards. There is also a recreational beachfront with swimming and boating located ½ mile downstream of the plant. Over the last ten years, the incidence of a skin reaction called allergic dermatitis has increased dramatically for swimmers at the recreational beachfront.

 

Due to public concern, the local water utility began checking for elevated levels of several pollutants that cause skin reactions. Over the course of a year, they collected 45 water samples from a location adjacent to the output of the industrial plant. These samples were tested and elevated levels of chromium were identified. The EPA’s Maximum Contaminant Level (MCL) for chromium is 0.1 mg/L. With the knowledge that chromium pollution can result from fabric dyeing within textile factories, a group of concerned citizens has brought a class-action lawsuit against ABC Textiles, Inc. The class claims that the company’s textile mill has contributed to elevated chromium levels in the river, causing skin reactions at the local beach.

 

Due to the significance of this litigation, the Judge involved with the case, The Honorable Orlana Leia, has brought you in as an expert witness, independent of either side of the litigation, to give your expert opinion on the chromium exceedance. At your request, she is providing you with data from the 45 samples the water utility collected. She has requested that you analyze whether the chromium levels in the river exceed the EPA standard. Because there are no other outputs to the river within 5 miles, it can be presumed that the textile plant is the most likely source of elevated chromium levels, if they are present in the river. The area between the output of the industrial plant and the beachfront is populated with residential housing, and the prosecution and defense have agreed that illegal dumping or another source of contamination in this area is highly unlikely.

 

She is requiring that you complete your work with a high level of confidence, therefore you have suggested using a significance level of .01 (i.e., 99% confidence). You are to provide the jury with which side of the litigation you would support and why in a written document that makes the determination clear and believable to them.  The document you are to provide is to follow the court’s template and their Legal memorandum guide. You will also copy the document to John Coltrane, Clerk of the Courts, Mitchell Bilano, Plaintiffs’ Counsel, and Jill Gailow, Defendant’s Counsel. Remember that you are only an expert on statistical analysis of the exceedance of chromium in the river, not on whether elevated chromium can cause allergic dermatitis. Be careful not to overstate your findings – don’t make any assumptions that aren’t very clearly suggested by the data. (Data File  Download Data File)  

Sample Date

Sample Number

Chromium Level (mg/L)

1-Aug

1

0.094

7-Aug

2

0.08

20-Aug

3

0.077

28-Aug

4

0.081

5-Sep

5

0.086

13-Sep

6

0.078

20-Sep

7

0.117

29-Sep

8

0.084

3-Oct

9

0.113

10-Oct

10

0.094

27-Oct

11

0.088

5-Nov

12

0.093

12-Nov

13

0.115

26-Nov

14

0.121

1-Dec

15

0.112

8-Dec

16

0.119

15-Dec

17

0.11

21-Dec

18

0.101

29-Dec

19

0.082

4-Jan

20

0.088

11-Jan

21

0.084

19-Jan

22

0.094

25-Jan

23

0.118

31-Jan

24

0.127

7-Feb

25

0.123

14-Feb

26

0.096

22-Feb

27

0.093

1-Mar

28

0.112

8-Mar

29

0.071

18-Mar

30

0.081

31-Mar

31

0.082

5-Apr

32

0.092

10-Apr

33

0.088

19-Apr

34

0.081

25-Apr

35

0.076

1-May

36

0.079

9-May

37

0.08

18-May

38

0.91

25-May

39

0.082

1-Jun

40

0.072

12-Jun

41

0.071

25-Jun

42

0.075

2-Jul

43

0.092

16-Jul

44

0.102

24-Jul

45

0.106