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Paraquat Lawsuit

Paraquat Lawsuit

Farmers and agricultural workers have filed lawsuits in courts around the country alleging Paraquat’s manufacturer, Syngenta Group, failed to warn them about the life-altering neurological effects Paraquat caused them.

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Case Overview

Paraquat is a toxic chemical used as an herbicide. A growing number of scientists have reported finding a link between Paraquat exposure and neurological issues, including Parkinson’s disease. Thousands of U.S. citizens have filed paraquat lawsuits against the manufacturers Syngenta and Chevron and some distributors. Find out if you are eligible for a paraquat lawsuit, too.

Key takeaways

  • Paraquat is a chemical used as an herbicide. A growing number of scientists have reported finding a link between paraquat and serious neurological conditions, including Parkinson’s disease.
  • In lawsuits filed across the country, people exposed to paraquat are setting forth that the manufacturers (Syngenta and Chevron) as well as some distributors were aware of the dangers of the product before it entered the market and have negligently continued to sell it.
  • People who have suffered injuries (or the loved ones of those who have died) because of paraquat exposure may be able to file a lawsuit against the manufacturers and distributors of paraquat.

Recent paraquat lawsuit updates

May 2024: Judge Roberts scheduled four bellwether trial dates in 2025 for paraquat cases pending in the Philadelphia Court of Common Pleas. Motley Rice attorney Fidelma Fitzpatrick serves as co-lead counsel of the Plaintiffs’ Executive Committee for the Philadelphia mass tort. Dan Lapinski serves as Plaintiffs’ Liaison Counsel.

April 2024: A few bellwether cases in the federal paraquat MDL were dismissed. Other MDL cases still remain against Syngenta, Chevron and the other named defendants in the MDL or in the state cases. Federal MDL rulings do not impact the Philadelphia paraquat cases.

April 2024: The California legislature has introduced a new bill that would ban the use of paraquat within the state. If passed, Assembly Bill 1963 would require that the use of paraquat begin phasing out in January 2026. It is estimated that more than a million pounds of paraquat are used annually in the state. The bill comes as the California Department of Pesticide Regulation is currently evaluating the safety of paraquat. The California Department of Pesticide Regulation’s review may impact the use of paraquat within the state.

January 2024: Judge Roberts, presiding over the paraquat litigation — In Re: Paraquat Products Liability Litigation (No. 559) — in the Philadelphia Court of Common Pleas, has issued several rulings in favor of the plaintiffs. First, Judge Roberts has overruled objections to the plaintiffs’ complaint from both Syngenta and Chevron. Second, the judge denied Syngenta’s motion for protective order, which could have prevented disclosure of information. Finally, Judge Roberts lifted any stays on discovery in the consolidated paraquat cases. This means that discovery may now begin. 

Why are people filing paraquat lawsuits?

People who have developed Parkinson’s disease are filing lawsuits against paraquat manufacturers and distributors. These include:

  • Syngenta: Headquartered in Switzerland, Syngenta is the modern face of the original designers of paraquat, Imperial Chemical Industries. It is responsible for selling, promoting and marketing paraquat. It has an agreement with Chevron to help manufacture and sell paraquat in the United States.
  • Chevron: Incorporated in Pennsylvania, Chevron is the successor to the California Chemical Company, Ortho Division. The California Chemical Company was the original business to partner with Syngenta to manufacture and distribute paraquat in the United States.
  • FMC Corporation: Incorporated in Delaware and operating primarily out of Philadelphia, Pennsylvania, FMC is one of the largest distributors of paraquat in the United States.

There are pending state court cases in California, Delaware, Illinois, Florida, Pennsylvania, and Washington. An ongoing multidistrict litigation (MDL) docket consolidates many claims brought in federal court. State courts may also consolidate paraquat cases, as was done in the Court of Common Pleas of Philadelphia. There are hundreds of individual cases pending in Delaware state court.

These lawsuits seek compensation for the victims’ injuries.

Some of the paraquat lawsuits also include claims from victims’ spouses. These lawsuits claim Loss of Consortium. This is a legal term describing the losses a family or spouse may experience because of injuries to the victim.

What is paraquat?

Paraquat dichloride is a toxic chemical used as an herbicide. Paraquat was first sold in the U.S. in 1964 and has been used for decades to control weeds and invasive grasses. Farmers use it on many crops, including corn, soybeans, cotton, and vineyard grapes. It is the key ingredient in many spray herbicides, including Gramoxone, Firestorm, Helmquat and Parazone.

Paraquat is now classified by the U.S. Environmental Protection Agency (EPA) as a restricted use product. It is generally not available to the general public and requires a license to purchase.

How does paraquat work?

Paraquat kills plants by disrupting necessary cellular functions. Once it gets through the plant's skin, paraquat causes a chemical reaction that hinders photosynthesis and damages other components of the plant’s cells. Paraquat is made more effective by adding surfactants, a type of chemical that lets paraquat stick to plants so it can be more easily absorbed. 

Just as paraquat is effective on plant cells, it can have a similar effect on animal cells that absorb it. It disrupts cellular respiration in animal cells, like those found in humans. Plaintiffs allege as early as the 1950s, Syngenta was aware that paraquat could have a toxic effect on the human nervous system and that it could be absorbed through the skin. 

Paraquat bans and safety measures

Dozens of countries have banned paraquat, including the European Union (EU) and China. Kuwait first banned it in 1985. 

Despite many countries having acted already, paraquat is not yet banned in the U.S.

The countries that have banned paraquat and the year they banned it are shown below.

 

Bahrain 2015

Morocco 2021

Brazil 2020

Mozambique 2014

Burkina Faso 2011

Niger 2011

Cabo Verde 2011

Norway 1995

Cambodia 2003

Oman 2014

Chad 2011

Peru 2022

China 2020

Qatar 2015

Côte d’Ivoire 2004

Saudi Arabia 2015

Emirates 2015

Senegal 2011

EU - 27 Countries 2007-2008

Serbia 2009

Fiji 2020

South Korea 2011

Gambia 2011

Sri Lanka 2012

Guinea-bissau 2011

Switzerland 2002

Kuwait 1985

Taiwan 2018

Lao PDR 2011

Thailand 2020

Malawi 2019

Togo 2015

Malaysia 2005-2006, 2020

Turkey 2014

Maldives 2022

UK 2008

Mali 2011

United Arab Emirates 2015

Mauritania 2011

Vietnam 2019

Has the U.S. banned paraquat?

The U.S. has not yet banned paraquat. While the EPA has suggested some restrictions to the use of paraquat, it has yet to implement a full ban despite the evidence of harm.

Proposed EPA safety measures for paraquat

In October 2020, the EPA proposed new safety measures to “reduce risks associated with paraquat in order to better protect human health and the environment.” An interim decision was released in July 2021. Measures outlined by the EPA include, but are not limited to: 

  • Limiting aerial application acreage for all uses and use sites, except cotton desiccation.
  • Requiring enclosed cabs on sprayer vehicles if the area is treated in a 24-hour period and exceeds 80 acres. Areas less than 80 acres should be treated from an enclosed cab or with users wearing PF10 respirators.
  • Requiring a residential area drift buffer.
  • Prohibiting certain applicators, including pressurized handguns and backpack sprayers.

People most at risk for paraquat exposure include agricultural workers, their families and people who live near farms.

Health effects related to paraquat

Paraquat exposure can lead to serious health effects, according to the CDC. Many scientists have found the herbicide is linked to an increased risk of developing Parkinson’s disease. It can also be dangerous if ingested or inhaled or if it contacts the skin.

Paraquat’s high toxicity can cause life-threatening side effects. Paraquat induces oxidative stress, which can lead to a host of health problems. Oxidative stress changes the structure and function of important parts of cells, leading to serious cell damage.

Other health effects of paraquat

Paraquat exposure can lead to many types of health effects. As with Parkinson’s disease, the effects of paraquat poisoning may have serious and potentially life-threatening impacts on people.

Symptoms related to paraquat poisoning include:

  • Health effects: Exposure to paraquat may be linked to the development of Parkinson’s Disease and related neurological issues.
  • Immediate signs of paraquat ingestion: Pain and swelling in mouth and throat, followed by gastrointestinal symptoms like nausea, vomiting, pain and diarrhea. 
  • Health effects from ingesting small to medium amounts of paraquat: Development (within several days to several weeks) of heart failure, kidney failure, liver failure or lung scarring.
  • Health effects from ingesting large amounts of paraquat: Development (within a few hours to few days) of severe health effects, possibly leading to seizures or even death, the EPA notes.

If you or a loved one are showing signs of sickness after being exposed to paraquat, seek immediate medical care.

Paraquat and Parkinson’s disease

Many studies have found strong associations between paraquat use and Parkinson’s disease. These consistent findings suggest that the use of paraquat causes an increased risk of Parkinson’s.

Parkinson’s disease is an irreversible neurological disorder. Symptoms typically become worse over time.

Common Parkinson’s disease symptoms include:

  • Depression
  • Difficulty with swallowing, chewing and speaking
  • Emotional changes
  • Impaired balance and coordination (may lead to falls and other injuries)
  • Muscle stiffness and prolonged contraction
  • Skin problems
  • Slow movement
  • Tremors (commonly in hands, arms, legs, jaw or head)
  • Urinary problems or constipation

If you or a loved one experiences these symptoms, you should see your doctor immediately.

A paraquat lawyer can help explain your paraquat legal options. The options may include filing a personal injury lawsuit of your own. Product liability lawsuits seek to hold the manufacturers and distributors of paraquat accountable. Although there is never a guarantee, lawsuits may result in a settlement or verdict award.

“People who used and were exposed to Paraquat had no idea about the dangers of Paraquat because the manufacturers and distributors failed to warn them. These hard-working farmers, workers and individuals had a right to know so they could have potentially avoided exposure to this highly toxic herbicide. It is an honor to represent these individuals and their families and pursue justice on their behalf,” said Fidelma Fitzpatrick, a trial attorney with Motley Rice LLC who represents hundreds of clients in filed paraquat cases.

Studies on paraquat and Parkinson’s disease

Over the years, the scientific evidence showing association between paraquat exposure and Parkinson’s disease has been mounting.

  • 1997: A study of Taiwanese individuals with and without Parkinson’s disease found a greater prevalence of Parkinson’s in people who had used paraquat than those without exposure. The study found no significant difference between the likelihood of developing Parkinson’s and occupational exposure to chemicals or heavy metals and minerals. 
  • 2002: A study on mice found that exposure to paraquat was linked with selective dopaminergic degeneration in the subjects’ brains. This selective dopaminergic degeneration is a typical sign of Parkinson’s disease. 
  • 2005: A study on mice found that repeated exposure to paraquat could start the process of destroying nigrostriatal dopaminergic neurons, a feature of Parkinson’s disease. The study saw mice begin to show signs of neuron loss following the second dosage of paraquat. 
  • 2011: Using a sample of agricultural workers from the Agricultural Health Study, one study explored the effects of pesticides that increase oxidative stress and inhibit mitochondrial complex I. The study’s analysis found a statistically significant link between Parkinson’s disease and both types of pesticides. Paraquat impacts the human body in the same way as both types of pesticide groups 
  • 2019: A 2019 systematic review of more than a dozen studies found a consistent, statistically significant pattern linking paraquat exposure and Parkinson’s disease.

These studies, along with others, consistently point to the increased risk of developing Parkinson’s disease after paraquat exposure. Studies like this show why so many countries have banned the use of paraquat.

Paraquat plaintiff profiles

People who have developed Parkinson's disease after exposure to paraquat may be eligible to take legal action. Individuals who have filed lawsuits against the manufacturers and distributors of paraquat (Syngenta, Chevron, and FMC Corporation) include:

  • A California man used paraquat on his citrus farms for decades, beginning in the late 1960s. He purchased, mixed, loaded and sprayed paraquat via hand sprayers and tractors each year to control vegetation and protect his crops. He was forced to retire once he began having neurological symptoms. He was diagnosed with Parkinson’s disease at the age of 73. He suffers from tremors, inability to care for himself, delusions/hallucinations, difficulty with moving and walking and loss of balance.
  • A North Carolina man used paraquat from the late 1980s to the late 1990s while working for a utility company. During his work, he sprayed paraquat on powerlines, roads and rights of ways to clear vegetation. He was diagnosed with Parkinson’s disease at the age of 66. He suffers from tremors, drooling, constipation, fatigue, falls, hallucinations, cognitive decline and mobility issues. He is currently in a healthcare facility as he is unable to care for himself.
  • A Pennsylvania man was exposed to paraquat while working on a farm in the 1970s and 1980s. The farm grew many crops including corn, wheat and oats. He was exposed to paraquat while it was mixed, loaded and sprayed on the farm. He was diagnosed with Parkinson’s disease at the age of 43 and has cognitive changes, decreased memory, dizziness, hunched posture, reduced facial expression, tremors, soft speech and urinary incontinence.

These are just a few of the people who have developed Parkinson’s after exposure to paraquat. They represent thousands of people who have had similar experiences.

Contact a paraquat attorney

If you or someone you love was directly exposed to paraquat and later diagnosed with Parkinson’s disease, you may have a claim. For more information on filing a paraquat lawsuit, reach toxic exposure attorney Fidelma Fitzpatrick by email or call 1.800.768.4026.

Current state of paraquat litigation

Thousands of impacted people and their families have filed lawsuits against Syngenta, Chevron, FMC and other parties responsible for manufacturing and distributing paraquat. These lawsuits have been filed in both state and federal courts.

Paraquat state litigation

As of June 2024, over 700 paraquat lawsuits have been filed in Pennsylvania state court, specifically in the Philadelphia Court of Common Pleas. Judge Joshua Roberts is overseeing the lawsuits. The Court has issued an order setting the first group of bellwether trials for March 2025. Motley Rice attorney Fidelma Fitzpatrick is co-lead counsel and a member of the Plaintiffs’ Executive Committee (PEC) for the Pennsylvania mass tort. Daniel Lapinski is liaison counsel for the Pennsylvania mass tort. Several other Motley Rice attorneys also represent plaintiffs, including Philadelphian Mike Daly, the newest member attorney in the firm’s new office at 3 Logan Square.

January 2024 update: Judge Roberts has denied defendants’ multiple preliminary objections arguments to the initial pleadings. Discovery is now underway. An initial group of 20 plaintiffs have been selected to move through case specific discovery. Four cases will be selected to go to trial in 2025 with the first trial beginning in March 2025. 

In addition to the paraquat cases filed in Philadelphia’s Court of Common Pleas’ complex litigation center, hundreds of lawsuits have been filed in Delaware state court and motion practice is underway.

Paraquat federal multidistrict litigation (MDL)

There is one federal multidistrict litigation (MDL) docket related to paraquat. It is located in the Southern District of Illinois Court System. An MDL docket allows federal lawsuits with similar details and defendants to be decided by the same court. MDLs can help expedite the legal process. 

The paraquat MDL, called In Re: Paraquat Products Liability Litigation (MDL-3004), was established in 2021. Motley Rice is not involved in the federal MDL. Motley Rice attorneys have filed cases in Pennsylvania state court. 

Frequently asked questions about paraquat lawsuits

Who qualifies for a paraquat lawsuit?

To qualify for a paraquat lawsuit, you must have been exposed to paraquat and suffered injuries that came from that exposure. If you believe you’ve been harmed by paraquat exposure, seek medical treatment. You can also consider speaking to a lawyer with experience in toxic exposure claims to evaluate your legal options.

How do you prove paraquat exposure?

Proving paraquat exposure will depend on how you may have been exposed. A paraquat attorney can help you gather evidence of paraquat exposure.

How much is the average settlement for a paraquat lawsuit?

Most paraquat Parkinson’s lawsuits are still in early stages and have not yet reached settlements. However, Syngenta’s financial records show some payouts have already happened. The company’s 2022 Financial Report shows a $187.5 million settlement to multiple claimants in 2021.

Syngenta is no stranger to large settlements and paid $1.5 billion to settle claims related to its pesticide Viptera in 2018 and 2019.

Motley Rice was not involved in this settlement or the Viptera settlements.

If you or a loved one was harmed by paraquat, you may also be eligible to file a lawsuit. A successful paraquat lawsuit can help compel Syngenta to pay for medical care costs to provide financial peace of mind. Speak with paraquat attorneys at our law firm to find out if you are eligible.

Types of damages in a paraquat lawsuit

Plaintiffs in paraquat lawsuits are alleging both economic and non-economic damages for the injuries they’ve suffered. As part of their lawsuits, plaintiffs are requesting the following types of relief for the harm they’ve suffered: 

  • Legal costs for pursuing the actions
  • Loss of consortium
  • Medical expenses and other related costs
  • Mental and physical suffering
  • Punitive damages

While the specific claims may vary, the types of damages seen across paraquat litigation include: 

  • Breach of implied warranty of merchantability
  • Negligence
  • Public nuisance
  • Punitive damages
  • Strict liability (Design defect and failure to warn)
  • Violation of consumer fraud and deceptive business practices acts

The damages available to individual plaintiffs depend on the facts of their case. It can be helpful to speak with an attorney who has experience handling toxic exposure claims to understand the legal options available to you.

Our toxic exposure litigation experience

Our attorneys have extensive experience litigating toxic exposure and environmental damage cases for individuals, families, communities, and states. Through our cases we seek justice for our clients and to improve environmental standards and protections. 

An example of our experience includes representing people who developed non-Hodgkin lymphoma after being exposed to Roundup weed killer. The firm also obtained a landmark settlement for 10 cities and counties in California that alleged three lead pigment companies created a public nuisance by exposing residents to toxic lead paint. 

Read more on our toxic exposure experience.

 

Why are people filing paraquat lawsuits?

What is paraquat?

How does paraquat work?

Paraquat bans and safety measures

Has the U.S. banned paraquat?

Proposed EPA safety measures for paraquat

Health effects related to paraquat

Other health effects of paraquat

Paraquat and Parkinson’s disease

Studies on paraquat and Parkinson’s disease

Paraquat plaintiff profiles

Current state of paraquat litigation

Frequently asked questions about paraquat lawsuits

Our toxic exposure litigation experience

Paraquat lawsuit timeline

06.01.24

June 2024

As of June 2024, there are 728 paraquat cases pending in the Pennsylvania state litigation. Defendants continue to try to strike down this group of lawsuits.

02.01.24

February 2024

U.S. District Judge Nancy Rosenstengel has largely denied the motions to dismiss submitted by Syngenta and Chevron in the paraquat MDL. The judge granted a motion to dismiss on plaintiffs’ claims of public nuisance. However, Judge Rosenstengel’s denial of the other motions to dismiss means that thousands of claims against the manufacturers and distributors of paraquat may still go forward in federal court.

02.01.24

February 2024

The BBC investigated claims from Syngenta that there is no link between paraquat and Parkinson’s disease. BBC found that Syngenta’s claims may be misleading. 

The BBC reported that the company’s chief medical officer looked only at the death records of staff and did not include medical records.
Death records may not always include people who had Parkinson’s disease. This led to an underreporting of people potentially impacted by paraquat.
This choice to look only at death records would make it harder to show a link between the pesticide and Parkinson’s disease, which other studies have shown.

02.01.24

February 2024

The Iowa legislature introduced a bill that would reduce the ability of Iowans to sue manufacturers of pesticides for not alerting people to health risks of their products. 

The bill would still allow individuals to bring personal injury claims for health issues they suffered from pesticide exposure. 
The bill would protect manufacturers only from liability for failing to warn people about potential health risks that aren’t added to their warning labels. 
Some in the state have warned that passing the bill would result in fewer people being able to seek justice for the harms they suffer from pesticides like paraquat.  

01.01.24

January 2024

The Environmental Protection Agency (EPA) again failed to ban the use of paraquat. The EPA decided to maintain its 2021 Interim Registration Review Decision to not ban it.

This is in spite of the vast body of scientific research that indicates a link between paraquat exposure and severe neurological conditions like Parkinson’s disease. 
The 2021 decision led to ongoing litigation from environmental and public safety groups. The EPA can still change its position because it has not yet issued a final report. 
It’s expected that the EPA will issue a final report in 2025.

01.01.24

January 2024

Judge Roberts, presiding over the state paraquat litigation in Philadelphia has issued several rulings in favor of the plaintiffs. 

He overruled objections to the plaintiffs’ complaint from both Syngenta and Chevron. 
He denied Syngenta’s motion for protective order, which could have prevented disclosure of information. 
Finally, Judge Roberts lifted any stays on discovery in the consolidated paraquat cases. This means that discovery may now begin.

01.01.24

January 2024

U.S. District Judge Nancy Rosenstengel ordered a limited discovery for 25 plaintiffs in the federal paraquat MDL. 
The MDL now has over 5,000 plaintiffs. 

12.04.23

December 2023

U.S. District Judge Nancy Rosenstengel denied a motion from Syngenta to compel Dr. Earl Ray Dorsey to produce certain documents. 

Syngenta requested documents relating to a 2023 study co-authored by Dr. Dorsey on the relationship between exposure to paraquat and Parkinson’s disease. 
Syngenta alleged that the plaintiff’s lawyer encouraged Dr. Dorsey to write and release the study to be cited in the MDL. 
Dr. Dorsey contested the production of non-public documentation relating to the study. 
Judge Rosenstengel argued that the documents were minimally valuable and that enough scientific debate was already available.

08.24.23

August 2023

U.S. District Judge Nancy Rosenstengel canceled the October 2023 trial date for the paraquat MDL bellwether cases.

07.28.23

July 2023

U.S. District Judge Nancy Rosenstengel ordered a hearing for August 21, 2023, to evaluate the scientific evidence of the plaintiffs’ claims in the paraquat MDL. 

The hearing included testimony from plaintiffs’ expert Dr. Martin Wells. 
The evaluation of the evidence impacted the timeline for potential bellwether trials. 
The parties had until September 8, 2023, to submit closing briefs on the hearing. 

06.02.23

June 2023

An investigation by the Guardian and the New Lede discovered internal documents from Syngenta that indicated it had tried to influence scientific research on paraquat. 

According to the investigation, the documents showed that Syngenta misled regulators about the existence of unfavorable internal research, recruited researchers who published scientific literature without disclosing their link to the paraquat manufacturer and had lawyers edit scientific reports to minimize damaging language.

View Full Timeline

About the Author

Sources

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  2. First Judicial District of Pennsylvania. Caselist.
  3. The Guardian. EPA again OKs use of toxic herbicide linked to Parkinson’s disease.
  4. The Guardian. Revealed: The secret push to bury a weedkiller’s link to Parkinson’s disease.
  5. Iowa Public Radio. Bill to limit lawsuits over pesticide-related illnesses advances in Iowa House.
  6. LA Times. California moves to ban the use of paraquat, a powerful weedkiller.
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  8. McCormack AL, Atienza JG, Johnston LC, Andersen JK, Vu S, Di Monte DA. Role of oxidative stress in paraquat-induced dopaminergic cell degeneration. J Neurochem. 2005 May;93(4):1030-7.
  9. McCormack AL, Thiruchelvam M, Manning-Bog AB, Thiffault C, Langston JW, Cory-Slechta DA, Di Monte DA. Environmental Risk Factors and Parkinson’s Disease: Selective Degeneration of Nigral Dopaminergic Neurons Caused by the Herbicide Paraquat. Neurology of Disease. 2002 July;10(2):119-127.
  10. Reuters. Judge rejects key expert in paraquat lawsuits, tosses first cases set for trial.
  11. Reuters. MDL judge advances most paraquat claims against Syngenta, Chevron.
  12. Stuart AM, Merfield CN, Horgan FG, Willis S, Watts MA, Ramírez-Muñoz F, et al. Agriculture without paraquat is feasible without loss of productivity—lessons learned from phasing out a highly hazardous herbicide. Environ Sci Pollut Res. 2023 Feb 1;30(7):16984–7008.
  13. Syngenta. Financial Report 2023.
  14. Tangamornsuksan W, Lohitnavy O, Sruamsiri R, Chaiyakunapruk N, Norman Scholfield C, Reisfeld B, Lohitnavy M. Paraquat exposure and Parkinson's disease: A systematic review and meta-analysis. Arch Environ Occup Health. 2019;74(5):225-238.
  15. Tanner CM, Kamel F, Ross GW, Hoppin JA, Goldman SM, Korell M, Marras C, Bhudhikanok GS, Kasten M, Chade AR, Comyns K, Richards MB, Meng C, Priestley B, Fernandez HH, Cambi F, Umbach DM, Blair A, Sandler DP, Langston JW. Rotenone, paraquat, and Parkinson's disease. Environ Health Perspect. 2011 Jun;119(6):866-72.
  16. United States District Court for the Southern District of Illinois. In Re: Paraquat Products Liability Litigation. Case Management Order No. 19.
  17. United States District Court for the Southern District of Illinois. In Re: Paraquat Products Liability Litigation. Case Management Order No. 20.
  18. United States District Court for the Southern District of Illinois. In Re: Paraquat Products Liability Litigation. Case No. 3:21-MD-3004-NJR. Memorandum and Order.
  19. United States District Court for the Southern District of Illinois. In Re: Paraquat Products Liability Litigation. Minute Entry 3:21-MD-3004-NJR.
  20. United States District Court for the Southern District of Illinois. Syngenta Crop Protection, LLC v. Dorsey, No. 3:23-pq-03204-NJR.

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