Haley v. Medtronic, Inc.

169 F.R.D. 643

 

RULE:

When tort claims present liability and damage issues that are highly individualized, they do not qualify for class certification under Fed. R. Civ. P. 23(b).

FACTS:

Plaintiff implant recipient filed a motion for class certification in her tort action against defendant manufacturer.

ISSUE:

Was a class action suit a superior method of adjudicating plaintiff's tort action against an implant manufacturer where each class member would have to litigate numerous and substantial separate issues to establish a right to recover individually?

ANSWER:

No.

CONCLUSION:

The court denied plaintiff's motion, holding that class action treatment would not be a superior method of adjudicating the claims. The court held that the products liability case presented issues of liability and damages that were highly individual and therefore did not qualify under the requirements of both Rules 23(a) and (b). The court held that the difficulties likely to be encountered in the management of the action made certification inappropriate under Fed. R. Civ. P. 23(b)(3)(D). Class action was not superior because each class member would have to litigate numerous and substantial separate issues to establish a right to recover individually after liability to the class was established.

The court denied plaintiff implant recipient's motion for class certification in her tort action against defendant manufacturer, holding that there was no similar single issue common to all the plaintiffs that would render class action treatment superior.

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