043117P.pdf   10/12/2005  Lester Grovatt  v.  St. Jude Medical
   U.S. Court of Appeals Case No:  04-3117
   District of Minnesota   
   [PUBLISHED] [Riley, Author, with Bowman and Benton, Circuit Judges]
   Civil case - class actions. In a case consolidating suits out of many
   district courts concerning defendant's recalled prosthetic heart valve, the
   district court erred in certifying a consumer protection class seeking
   damages based on Minnesota's consumer protection statutes, as the
   district court did not conduct a thorough conflicts-of-law analysis as to
   each plaintiff class member before applying Minnesota law; protection of
   out-of-state parties' constitutional rights requires an inquiry into their
   claims' contacts with Minnesota and their individual state laws before
   concluding Minnesota law may apply; district court also erred in
   certifying a medical monitoring class as each plaintiff's need for medical
   monitoring is highly individualized and states which recognize this claim
   as stating a separate cause of action have different elements triggering
   culpability.