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Keywords

lawsuitplaintiffdamagesstatuteappealconsumer protectionclass action
plaintiffstatuteappealconsumer protection

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In re St. Jude Medical, Inc., 425 F.3d 1116

Facts

St. Jude Medical, Inc. produced the Silzone prosthetic heart valve, which had a unique antimicrobial silver coating. After a study indicated a 2% increase in paravalvular leaks for patients with Silzone-coated valves, SJM recalled all unimplanted valves. Numerous lawsuits were filed, leading to a consolidated class action in Minnesota, where the district court certified subclasses for damages under Minnesota's consumer protection statutes and for medical monitoring. The court found common issues predominated and that a class action was the superior method for adjudication.

SJM produced the Silzone prosthetic heart valve. A test conducted by SJM showed a slightly higher risk of paravalvular leaks at the site where the valves were implanted. SJM thereafter recalled all unimplanted Silzone valves.

Issue

Did the district court conduct a sufficient conflicts-of-law analysis before certifying the class, and was the medical monitoring subclass appropriate for certification?

The district court did not conduct a sufficient conflicts-of-law analysis before certifying class and concluding that Minnesota's consumer protection statutes would apply to class, and medical monitoring subclass was not appropriate for class certification.

Rule

To certify a class, plaintiffs must meet the requirements of Rule 23(a) and satisfy one of the subsections of Rule 23(b). A thorough conflicts-of-law analysis is required when applying the law of one state to claims from plaintiffs in multiple states.

To be certified as a class, plaintiffs must meet all of the requirements of Rule 23(a) and must satisfy one of the three subsections of Rule 23(b).

Analysis

The Court of Appeals found that the district court failed to conduct a thorough conflicts-of-law analysis, which is necessary to determine whether Minnesota law could be applied to all plaintiffs' claims. The court noted that state consumer protection laws vary significantly and that the district court's choice of Minnesota law may have been arbitrary or unfair without proper analysis of the contacts between Minnesota and each plaintiff's claims. Additionally, the medical monitoring subclass was deemed unmanageable due to the individual inquiries required for each plaintiff's need for monitoring.

The district court's class certification was in error because the district court did not conduct a thorough conflicts-of-law analysis with respect to each plaintiff class member before applying Minnesota law.

Conclusion

The Court of Appeals reversed the district court's class certification and remanded the case for further proceedings, emphasizing the need for a proper conflicts-of-law analysis and the inappropriateness of the medical monitoring subclass.

For the foregoing reasons, we reverse and remand for further proceedings consistent with this opinion.

Who won?

St. Jude Medical, Inc. prevailed in the appeal because the Court of Appeals found that the district court had erred in its class certification process, particularly regarding the conflicts-of-law analysis and the medical monitoring subclass.

The Court of Appeals, Riley, Circuit Judge, held that: 1 district court did not conduct a sufficient conflicts-of-law analysis before certifying class and concluding that Minnesota's consumer protection statutes would apply to class, and 2 medical monitoring subclass was not appropriate for class certification.

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