In re St. Jude Medical

St. Jude Medical, Inc. (St. Jude) (defendant) manufactured heart-valve implants. St. Jude learned that the valves created problems and recalled all valves that had not been implanted. Patients who already had the implants (plaintiffs) sued St. Jude throughout the United States. The cases were consolidated in federal court in Minnesota, where St. Jude was headquartered. Minnesota was also the state in which St. Jude had manufactured the valves, made the decisions that were being challenged, and fielded phone calls about the valves from potential patients. The district court initially certified two nationwide classes: (1) patients seeking medical monitoring of their implants and (2) patients seeking damages for consumer-law violations. St. Jude appealed, and the Eighth Circuit decertified the classes. The Eighth Circuit held that a nationwide medical-monitoring class was unmanageable because there were too many factual differences among the patients and legal differences among state medical-monitoring laws. The Eighth Circuit also held that the district court could not certify a nationwide class of patients seeking consumer-law damages until it had analyzed whether (1) the patients’ claims had sufficient contacts with Minnesota to satisfy the United States Constitution and (2) Minnesota substantive law was the preferred law to apply to all 11,000 claims. The case was then remanded to the district court to analyze these issues. On remand, the district court determined that the consumer laws in 18 of the other 49 states would preclude the proposed class’s consumer-law claims.