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Lockheed Martin Corp. v. Carrillo
California Supreme Court
63 P.3d 913 (2003)
Facts
Roslyn Carrillo and other residents of the city of Redlands (collectively, the residents) (plaintiffs) were exposed to drinking water contaminated with toxic chemicals discharged by Lockheed Martin Corp. (defendant). The residents brought a tort action in California state court, seeking damages in the form of a court-supervised fund for medical monitoring, and moved for class certification. Lockheed Martin opposed class certification, arguing that the residents could not show that common issues predominated in the litigation because individual doses varied based on duration of exposure and water use. The residents claimed that the class could be defined based on a medically significant minimum dose, restricted to those with daily exposure to contaminated water for a minimum time period within the relevant geographic area. Although the residents’ medical experts acknowledged that disease risks were dose dependent, the trial court certified the class. Parties objecting to certification appealed. The California Court of Appeal reversed the trial court’s order granting class certification, finding that individual issues predominated over common issues in cases involving variable toxic exposures. The California Supreme Court granted the residents’ petition for review.
Rule of Law
Issue
Holding and Reasoning (Werdegar, J.)
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