The record
Later dated third-party and internal detections recounted by the Ingham court: 1984 MSHA air-filter testing at a defendant mine found 5.8% anthophyllite; a 1998 internal letter recorded Dr. Alice Blount's report of trace asbestos in Vermont talc; in 2003 supplier Luzenac America reported tremolite in a talc sample; in 2004 Hayward Laboratory reported asbestos in a Johnson's Baby Powder sample.
Claim scope
That corporate knowledge, as recounted, extends past the 1970s measurement dispute into 1984-2004, including one federal agency measurement (MSHA 1984) with a numeric result.
What this source does not establish
The MSHA 1984 result is a MINE AIR FILTER measurement, not a finished-product measurement — do not present it as a product contamination figure. The Blount 1998 letter quote is itself qualified: 'well below those specified by OSHA'. Quote that qualifier if you use the finding.
Limitations
Ingham recites each internal document under the express predicate "According to Plaintiffs' evidence" and under the standard "Viewing the evidence in the light most favorable to the verdict." The court's HOLDING is that Plaintiffs made a submissible case for punitive damages; it is NOT an independent judicial finding that each recounted document says what plaintiffs said it says. Phrase as: 'the Missouri Court of Appeals, upholding the punitive award, recounted plaintiffs' evidence that...' The MSHA number is an occupational air sample; the Blount quote carries its own below-OSHA-limit qualifier that must travel with it.
Source
Case Citation — Ingham v. Johnson & Johnson, No. ED107476 (Mo. Ct. App. E.D. June 23, 2020)