Plaintiffs’ Leadership File Master Complaint in Camp Lejeune Litigation

Plaintiffs’ Leadership File Master Complaint in Camp Lejeune Litigation

The Camp Lejeune litigation centered in North Carolina has recently experienced a significant development after the court-appointed Plaintiffs’ Leadership submitted a Master Complaint in federal court. Master Complaint establishes a framework for the efficient and streamlined submission of Short Form Complaints and will likely prompt a considerable uptick in Camp Lejeune lawsuits in the coming months. 

With the discovery process well underway and the presiding judges signaling their intentions to host bellwether trials in 2024, the Camp Lejeune toxic water exposure litigation is rapidly entering a more advanced stage as the August 2024 deadline for filing suit approaches. 

Camp Lejeune Master Complaint Establishes Short Form Complaint Option

The Camp Lejeune Master Complaint enables current and prospective plaintiffs to submit Short Form Complaints, which are abbreviated claims that rely upon the allegations and factual record in the Master Complaint. By promulgating the Master Complaint, current and prospective plaintiffs can more easily and efficiently file a Camp Lejeune lawsuit

Although Camp Lejeune lawsuit Master Complaints streamline the admission of new claims in active litigation, they are by their nature generalized and not as specific. Consequently, the allegations and injuries that they outline may not be universally applicable. To account for this fact, the Camp Lejeune lawsuit Master Complaint contains a caveat enabling individual plaintiffs to amend their Short Form Complaint to address unique circumstances, injuries, or claims. 

The sweeping factual record of the Master Complaint levels a series of allegations against the United States government for its decades’ long disregard, obfuscation, and negligence over water contamination at Camp Lejeune. In the Case Management Order which required the Plaintiffs’ Leadership to submit a Master Complaint, the court’s judges also mandated that the Defense file a Responsive Pleading within 45 days of the submission of the Master Complaint. 

Case Management Order Aims for 2024 Camp Lejeune Bellwether Trials

The Camp Lejeune Case Management Order which requested the submission of a Master Complaint also contains a thorough outline for tentative bellwether trials. In consolidated litigation of the sort currently before the United States District Court for the Eastern District of North Carolina, bellwether trials serve as a litmus test for the probable trajectories of pretrial litigation. They can inform parties of the receptiveness of juries to the proposed allegations and requested damages, and therefore serve a crucial role in directing pretrial settlement negotiations. 

Relying upon common illnesses among the current plaintiffs, the Case Management Order establishes a category which it defines as “Track 1 Plaintiffs” from which the bellwether cases are to be selected. The medical conditions from Camp Lejeune toxic chemical exposure which constitute Track 1 litigants include:

  • Bladder cancer
  • Kidney cancer
  • Leukemia
  • Non-Hodgkin’s Lymphoma 
  • Parkinson’s Disease

With the exception of the lattermost diagnosis, the illnesses are all classified as “Tier 1” conditions in the recently introduced Elective Option, which the DOJ and Department of the Navy (DON) introduced for quickly processing backlogged administrative claims (ACs). 

The Court also signaled that it aims to initiate bellwether trials at some point in 2024. It did not, however, resolve the scheduling dispute between the Justice Department and Plaintiffs’ Leadership which occurred in late August. The DOJ likely desires to delay any bellwether or proper trials until the final two quarters of 2024, at which point the effective statute of limitations for filing a Camp Lejeune lawsuit expires. In the interest of concluding proceedings as expeditiously as possible, the Plaintiffs’ Leadership requested trials in the first quarter of 2024.

Toxic Contaminants Found in Camp Lejeune Water Distribution Systems

At the center of the ongoing Camp Lejeune litigation is the carnage wrought by toxic chemical exposure on the Marine Corps Base (MCB) in Onslow County, North Carolina. Officially operational in 1941, Camp Lejeune served as the temporary and long-term residence for hundreds of thousands of military service members, civilian personnel, and their families. 

However, at least as early as 1953, the private water supply at Camp Lejeune became contaminated with highly toxic substances known as volatile organic compounds (VOCs), including: 

The primary water distribution systems at Camp Lejeune’s were provided by Hadnot Point, Tarawa Terrace, Camp Johnson, and Holcomb Boulevard, whose supplies were routinely susceptible to the irresponsible disposal of industrial chemicals. When the Environmental Protection Agency (EPA) unveiled new VOC exposure limits, the management at Camp Lejeune conducted a thorough series of tests and discovered that the water supplies exceeded by hundreds of times the federally mandated standards. 

By the time that the military began to decontaminate the water in the mid- to late 1980s, the damage had been done. Tens of thousands of residents and their families had sustained life-altering and life-threatening doses of VOCs. 

Camp Lejeune Justice Act of 2022 Enables Veterans to Seek Compensation 

For years, the victims of toxic chemical exposure at Camp Lejeune sought access to compensation for the injuries they and their descendants sustained. Unfortunately, the doctrine of sovereign immunity by and large prohibited any litigation against the United States government, and the most significant recourse they possessed came in the form of disability benefits through the Department of Veterans Affairs (VA).

After veterans of Camp Lejeune and various military operations undertook concerted and protracted lobbying to expand VA benefits and accessibility, the Congress ratified the PACT Act of 2022, which contained a provision entitled The Camp Lejeune Justice Act (CLJA). Signed into law in August 2022, the CLJA established a comprehensive framework for providing compensation and legal recourse to the victims of Camp Lejeune. 

The procedural framework enumerated in the CLJA required claimants to resort initially to the DON for an out-of-court settlement. A refusal to accept the DON-offered figure or a failure of the Department to assess a claim within a period of 6 months rendered an individual eligible to file a lawsuit against the government. 

Department of the Navy Failed to Process Camp Lejeune Administrative Claims 

Despite commonly cited statistics about the potential number of eligible claimants, the Department of the Navy failed to address any of the ACs it received from August 2022 to August 2023. The nearly 100,000 unresolved claims subsequently translated into active Camp Lejeune lawsuits, which numbered over 1,000 before the DON and Justice Department unveiled the Elective Option in early September 2023. 

Pursuant to the requirements of the Camp Lejeune Justice Act, active litigation is currently advancing before the United States District Court for the Eastern District of North Carolina. With the promulgation of the recent Master Complaint, the number of Camp Lejeune lawsuits is likely to grow exponentially and quickly on account of the streamlined filing of Short Form Complaints. 

Common Injuries in Camp Lejeune Lawsuits

The recently filed Master Complaint outlines ubiquitous injuries and corollary damages in pending Camp Lejeune lawsuits. Although the MC states that the list of injuries caused by toxic chemical exposure at Camp Lejeune is “long and grave”, common illnesses include: 

Common Damages in Camp Lejeune Lawsuits

Camp Lejeune victims who suffer from any of the preceding or additional conditions must also contend with the mounting costs associated with their treatment. Despite extensive VA disability benefits and healthcare coverage, in the words of one prominent Camp Lejeune advocate, “Cancer is not a poor man’s disease”. 

Moreover, living with severe chronic and potentially lethal illnesses can cause unquantifiable emotional and mental stress. The economic and non-economic costs of toxic chemical exposure at Camp Lejeune eventually take their toll. In the context of the ongoing litigation, claimants in pursuit of due compensation often request awards in damages such as:

  • Medical expenses – past, present, and future
  • Transportation costs
  • Lost income and wages
  • Mental anguish
  • Emotional distress
  • Decreased quality of life

Seek the Assistance of a Qualified Camp Lejeune Lawyer Today

If you were stationed at Camp Lejeune for a minimum period of 30 days between August 1, 1953 and December 31, 1987 and subsequently developed any of the conditions associated with toxic chemical exposure, consider contacting us today. In a free consultation for prospective clients, our team of qualified Camp Lejeune lawyers can talk you through the eligibility of your claims, assist you in filing a Camp Lejeune Short Form Complaint, and advise you on how best to proceed. 

At LLN, we believe that the victims of toxic chemical exposure at Camp Lejeune deserve compensation and peace of mind. That is why we are committed to protecting your rights as you tend to your health. Given the two-year deadline for filing a Camp Lejeune lawsuit, the sooner you speak with a qualified Camp Lejeune attorney the more time you’ll have to strategize, recuperate, and rest assured that you are one step closer to accessing the compensation you deserve for injuries you did not. 


Matthew Dolman

Personal Injury Lawyer

This article was written and reviewed by Matthew Dolman. Matt has been a practicing civil trial, personal injury, products liability, and mass tort lawyer since 2004. He has represented over 11,000 injury victims and has served as lead counsel in over 1000 lawsuits. Matt is a lifetime member of the Million Dollar Advocates Forum and Multi-Million Dollar Advocates Forum for resolving individual cases in excess of $1 million and $2 million, respectively. He has also been selected by his colleagues as a Florida Superlawyer and as a member of Florida’s Legal Elite on multiple occasions. Further, Matt has been quoted in the media numerous times and is a sought-after speaker on a variety of legal issues and topics.

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