Hospitalized Student Sues Dartmouth After Consuming Entire Wall Of Russell Sage Lead Paint

Following revelations that the Russell Sage Hall dormitory contains peeling lead paint, Braydon Bloggs ’25 has filed a lawsuit against the College. In it, he seeks compensation for having developed lead poisoning after eating an entire wall of Russell Sage’s lead-laced paint. 

Though COSO did not approve our request for funding for a PACER subscription, the   Jack-O-Lantern has exclusively obtained the first three pages of the lawsuit. You can read them for yourself below. 

Case 4:20-cv-12345-NH2           Document 1           Filed 10/2/22           Page 1 of 69

IN THE UNITED STATES DISTRICT COURT FOR 

THE DISTRICT OF NEW HAMPSHIRE

BRAYDON BLOGGS

249 Central Street

Hoboken, NJ 07030

Plaintiff

 

CIVIL ACTION

NO. 4:20-cv-12345-NH2 

COMPLAINT

JURY TRIAL DEMANDED

DARTMOUTH COLLEGE

Parkhurst Hall

14 N Main Street

Hanover, NH 03755

PHILIP J. HANLON

14 Webster Ave

Hanover, NH 03755

Defendants

____________________________________

Case 4:20-cv-12345-NH2           Document 1           Filed 10/2/22           Page 2 of 69

COMPLAINT PRELIMINARY STATEMENT

1. Plaintiff BRAYDON BLOGGS (“Plaintiff” or “Bloggs”) files this Original Complaint against Defendants DARTMOUTH COLLEGE (“Defendant 1” or “the College” or “Dartmouth”) and PHILIP J. HANLON (“Defendant 2” or “Hanlon”), and respectfully shows the Court the following:

2. Colleges and Universities have a responsibility to provide their students with adequate and safe housing so that they take classes, earn their degrees, and eat their daily recommended values of paint unencumbered. Dartmouth and Hanlon have manifestly failed to create those conditions. 

3. After returning to Dartmouth as an eager sophomore, Plaintiff moved into a two-room triple in the dilapidated Russell Sage Hall, located at or near 7 Tuck Drive, Hanover, NH 03755. There, through no fault of his own, he was exposed to and ate an entire wall’s worth of paint — paint that has since been shown to contain lead, a deadly substance. 

4. Plaintiff has, upon information and belief, consumed paint from Dartmouth walls in the past and suffered no ill effects. Having been housed in the more recently constructed McLaughlin dormitory cluster freshman year, he was able to enjoy his favored wall paint to his heart’s content, with no fear of ill health effects. 

5. On Wednesday, Sept. 14, 2022, Plaintiff was hospitalized with serious kidney problems and headaches. These are classic signs of lead poisoning, a condition Plaintiff would not have developed had the entire wall’s worth of paint he consumed not contained lead. It is clear, then, that these critical health issues stem from one place: Russell Sage’s walls. 

Case 4:20-cv-12345-NH2           Document 1           Filed 10/2/22           Page 3 of 69

6. It is unacceptable that lead paint continues to be present on Dartmouth’s campus. Additionally, upon information and belief, the average Dartmouth student’s propensity to eat large quantities — even entire walls’ worth — of paint means that this was an injury waiting to happen. Dartmouth’s negligence in this incident is truly condemnable. 

7. Students at Dartmouth should know that their housing, as well as their right to consume truly enormous amounts of paint, will not be threatened by well-known health hazards like lead. Put another way, measures must be taken to ensure wall paint does not contain lead so that, when students eat wall paint, it does not injure them as it did Plaintiff. 

8. Plaintiff seeks compensatory damages in accordance with the damage being done to his body by the gargantuan mass of paint he devoured: Sixty-two thousand dollars ($62,000) for his medical expenses, three hundred thousand dollars ($300,000) so that plaintiff can safely buy lead-free paint for eating in the future, and one trillion dollars ($1,000,000,000,000) for emotional distress. Plaintiff additionally seeks a court order requiring Dartmouth to replace all dormitory paint with yummy paint verified as edible by the Food and Drug Administration. 

9. We urge the Court to expeditiously grant Plaintiff his justly deserved relief, and we lay out the case for doing so below. To fulfill this request would not only be entirely reasonable under established landlord-tenant law — including but not limited to Paint Eaters International Association v. Blish Gainesville Apartments, Ltd. (1987) — it would also send an important signal to all paint-eaters everywhere: Secure in the knowledge that your God-given paint is lead-free, you can live around, work with, and gobble up truly incredible amounts of paint in peace. 

—KM ’22