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Haley v. Medtronic, Inc.

United States District Court, Central District of California · Civil Procedure

Civil ProcedureClass CertificationRule 23class actionFRCP 23(a)FRCP 23(b)(3)FRCP 23(b)(2)numerosity

Facts

Plaintiff sought to represent a nationwide class of recipients of allegedly defective pacemaker leads manufactured by defendant. The court noted that approximately 66,166 of the leads had been implanted, more than 43,000 remained active, and recipients were dispersed throughout the United States. Plaintiff alleged common misconduct in defendant's design, manufacture, testing, distribution, and representations concerning the leads, including alleged fraud in concealing their failure rate. About twenty-five related lawsuits were already pending around the country.

Issue

Whether a nationwide class of pacemaker-lead recipients should be certified under Rule 23(b)(3) when common questions about defendant's conduct existed but numerous individualized issues and multistate-law problems would affect trial management. Whether class certification was also proper under Rule 23(b)(2) for a requested medical monitoring program.

Rule

A party seeking class certification must make a prima facie showing of each Rule 23(a) prerequisite and an appropriate basis under Rule 23(b). Under Rule 23(b)(3), certification requires both that common questions predominate and that a class action be superior to other available methods for fair and efficient adjudication; even where common issues predominate, certification may be denied if significant individualized issues and manageability problems make class treatment not superior. Rule 23(b)(2) certification is not appropriate when the principal relief sought is money damages rather than primarily declaratory or injunctive relief.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In federal court in Arizona, Lena Ortiz seeks to certify a nationwide class against Desert Crest Surgical Systems, alleging one defect in an implanted insulin port used in thousands of patients across the country. She offers common proof about the device's design and company testing, but each patient was treated by different doctors, received different warnings, and claims different physical complications and damages under different states' laws.

How should the court most likely rule on Rule 23(b)(3) certification?

Explanation. Rule 23(b)(3) requires both predominance and superiority. Under the majority opinion, a court may find that common questions about a defendant's design, manufacture, testing, and representations predominate, yet still deny certification because individualized issues of causation, injury, reliance, and damages, combined with the need to apply many states' laws, make the action unmanageable and therefore not superior. The opinion expressly rejects both an automatic bar on products-liability classes and the idea that predominance alone is enough.