Class Action Certification Standards for Medical Monitoring Claims: LOCKHEED MARTIN CORP. v. SUPERIOR COURT of San Bernardino County

Class Action Certification Standards for Medical Monitoring Claims: LOCKHEED MARTIN CORP. v. SUPERIOR COURT of San Bernardino County

Introduction

In Lockheed Martin Corporation et al. v. Superior Court of San Bernardino County (2003), the Supreme Court of California addressed the complex issue of class certification in the context of medical monitoring claims. Plaintiffs in this case sought to represent a large group of residents alleging that Lockheed Martin and other defendants had discharged toxic chemicals into San Bernardino County's water supply over several decades. The plaintiffs aimed to establish a class action for medical monitoring and punitive damages to address the widespread contamination and its potential health impacts.

The key issue centered on whether the plaintiffs had met the stringent requirements for class certification under California's Code of Civil Procedure section 382. Specifically, the court evaluated if common issues of law and fact predominated over individual concerns, thereby justifying the formation of a class action.

Summary of the Judgment

The Supreme Court of California affirmed the judgment of the Court of Appeal, which had reversed the trial court's order certifying the class. The Supreme Court concluded that the plaintiffs failed to demonstrate that common issues predominated sufficiently to warrant class certification. Although recognizing that medical monitoring claims can be appropriate for class actions, the court found that the complexity and individualized nature of exposure levels and health consequences in this case undermined the predominance of common issues. Consequently, the court held that the trial court had abused its discretion in certifying the class.

Analysis

Precedents Cited

The judgment heavily relied on several key precedents to frame its analysis:

  • POTTER v. FIRESTONE TIRE RUBBER CO. (1993): Established that medical monitoring costs can be compensable damages if they are a reasonably certain consequence of toxic exposure.
  • Washington Mutual Bank v. Superior Court (2001): Clarified the standards for class certification, emphasizing that plaintiffs must demonstrate both an ascertainable class and a well-defined community of interest.
  • CITY OF SAN JOSE v. SUPERIOR COURT (1974): Emphasized the need for class actions to predominate over individual litigations to justify certification.
  • O'Connor v. Boeing North American, Inc. (2000): Highlighted the challenges of class certifying medical monitoring claims due to their individualized nature.
  • Goasdone v. American Cyanamid Corp. (2002): Demonstrated the refusal to certify medical monitoring classes when individual issues outweighed common ones.

Impact

This judgment has significant implications for future class action litigations involving medical monitoring claims. It reinforces the high threshold required for class certification in such contexts, particularly when individual exposures and health outcomes vary widely among class members.

Legal practitioners must now be more cautious and thorough when proposing class actions for medical monitoring, ensuring that common issues not only exist but truly predominate. This decision may also limit the use of class actions in environmental and toxic exposure cases, pushing litigants towards individual or alternative collective mechanisms.

Complex Concepts Simplified

Class Action: A lawsuit where one or several persons sue on behalf of a larger group.

Medical Monitoring Claims: Legal claims seeking compensation for ongoing medical examinations to detect diseases caused by exposure to toxic substances.

Predominance: A requirement that common issues outweigh individual issues in a class action.

Substantial Evidence: Evidence that a reasonable mind might accept as adequate to support a conclusion.

Abuse of Discretion: A legal standard where a decision is deemed unreasonable, arbitrary, or without a sound basis in evidence.

Conclusion

The decision in Lockheed Martin Corporation et al. v. Superior Court of San Bernardino County sets a stringent precedent for class action certifications in medical monitoring claims. By highlighting the necessity for common issues to not only exist but also to predominate, the court ensures that class actions remain a tool for cases where collective litigation offers clear judicial and practical benefits.

While recognizing the potential public health benefits of medical monitoring programs, the court delineates the boundaries within which such claims can be effectively managed as class actions. This balance promotes fairness and efficiency, preventing the judicial system from being overwhelmed by overly complex and individualized class lawsuits.

Case Details

Year: 2003
Court: Supreme Court of California

Judge(s)

Kathryn Mickle WerdegarJanice Rogers BrownCarlos R. Moreno

Attorney(S)

Holme, Roberts Owen, Linnea Brown; Gibson, Dunn Crutcher, Robert S. Warren, Robert W. Loewen and Daniel S. Floyd for Petitioners Lockheed Martin Corporation and Highland Supply Corporation. Payne Fears, David Sweet, Alan G. Ross; Law Offices of Terry Bridges and Terry Bridges for Petitioner Highland Supply Company. Bowman Brooke, Anthony S. Thomas; Seyfarth, Shaw, Fairweather Geraldson, John D. Dwyer, Steven B. Katz and Carrie L. Daughters for Petitioner FMC Corporation. Wood, Smith, Henning Berman, David F. Wood, Ann G. Zuckerman, James C. MacDonald; Brunick, Alvarez Battesby and Leland P. McElhaney for Petitioner Baumac Corporation. Zevnik Horton Guibord McGovern Palmer Fognani, John D. Fognani, Michael John Miguel and K. Eric Adair for Petitioners PETRO-TEX Chemical Corporation and El Paso Tennessee Pipeline Co. Nossman, Guthner, Knox Elliott and Patrick J. Richard as Amici Curiae on behalf of Petitioners. Hugh F. Young, Jr., and Harvey M. Grossman for The Product Liability Advisory Council, Inc., as Amicus Curiae on behalf of Petitioners. Atlantic Legal Foundation and Martin S. Kaufman for Ronald E. Gots, Leonard Hamilton, Ronald Hart, Clark W. Heath, Michael Gough, A. Alan Moghissi, Rodney W. Nichols, Frederick Seitz, Barry H. Smith, James Wilson and Richard Wilson as Amici Curiae on behalf of Petitioners. Crowell Moring, Victor E. Schwartz and Luther Zeigler for The Coalition for Asbestos Justice, Inc., as Amicus Curiae on behalf of Petitioners. Horvitz Levy, David M. Axelrad, Lisa Perrochet and Mary-Christine Sungaila for American Chemistry Council, Chemical Industry Council of California, ExxonMobil Corporation and Union Oil Company of California dba UNOCAL as Amici Curiae on behalf of Petitioners. Sedgwick, Detert, Moran Arnold and Frederick D. Baker for Defense Research Institute as Amicus Curiae on behalf of Petitioners. Spriggs Hollingsworth, Donald W. Fowler, Rebecca A. Womeldorf, Marc S. Mayerson; National Chamber Litigation Center and Robin S. Conrad for United States Chamber of Commerce as Amicus Curiae on behalf of Petitioners. Robie Matthai, Pamela E. Dunn and Natalie A. Kouyoumdjian for State Farm General Insurance Company and United Services Automobile Association as Amici Curiae on behalf of Petitioners. Crosby, Heafy, Roach May, James C. Martin, Michael K. Brown; Daniel J. Popeo and Paul D. Kamenar for Washington Legal Foundation as Amicus Curiae on behalf of Petitioners Lockheed Martin Corporation and Highland Supply Company. No appearance for Respondent. Engstrom, Lipscomb Lack, Walter J. Lack, Gary A. Praglin, Richard P. Kinnan; Masry Vititoe, Edward S. Masry; Girardi Keese, Thomas V. Girardi, Howard B. Miller; Ward Ward and Alexandra S. Ward for Real Parties in Interest.

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