## Facts

- St. Jude Medical, Inc. manufactured prosthetic heart valves with a silver “Silzone” coating.
- A clinical study indicated an increased risk of paravalvular leakage in patients implanted with Silzone valves.
- St. Jude recalled Silzone valves that had not yet been implanted.
- Patients implanted with Silzone valves filed lawsuits nationwide; cases were centralized for pretrial proceedings in an MDL in the District of Minnesota.
- Plaintiffs sought class treatment of consumer-protection claims under Minnesota statutes (MFAA, MCFA, MUTPA) on behalf of patients from multiple states.

## Issues

1. Whether Minnesota consumer-protection statutes could be applied to a multistate class consistent with due process limits requiring sufficient Minnesota contacts and with applicable choice-of-law rules.
2. Whether differences among states’ consumer-protection laws required excluding some states’ residents from a Minnesota-law class to satisfy Rule 23(b)(3) predominance and superiority.

## Decision

- The district court conducted a post-remand choice-of-law analysis focused on constitutional contacts and conflicts among states’ consumer-protection regimes.
- The court held that the consumer laws of 18 states would preclude the proposed consumer-law class claims as framed under Minnesota statutes.
- The court redefined and re-certified a narrowed consumer-protection class limited to plaintiffs from states whose laws did not conflict with proceeding under the Minnesota consumer statutes in the proposed class format.
- The ruling effectively denied class treatment for residents of the 18 excluded states while allowing a reduced class to proceed.

## Legal Principles

- A forum state may not apply its substantive law to claims lacking sufficient forum contacts consistent with due process.
- Choice-of-law analysis must account for material differences among states’ consumer-protection laws; conflicts can bar applying one state’s statute to out-of-state claimants.
- Variations in state consumer statutes (including reliance requirements, standing limits, restrictions on private or class actions, remedies, and procedural prerequisites) can defeat Rule 23(b)(3) predominance if they require state-by-state adjudication.
- A court may address manageability and predominance concerns by narrowing a proposed class definition to jurisdictions whose laws permit common adjudication under the selected substantive theory.

## Conclusion

The court, acting on remand, refused to treat Minnesota consumer statutes as uniformly governing all putative class members’ claims and instead narrowed the consumer-protection class after finding that the laws of 18 states conflicted with the proposed Minnesota-law class theory, creating constitutional and Rule 23(b)(3) obstacles to a broader class.


In re St. Jude Med., Inc., Silzone Heart Valves Prods. Liab. Litig., No. 01-1396, 2006 WL 2943154 (D. Minn. Oct. 13, 2006)