Eighth Circuit Decertifies Products Liability Class Based on Insufficient Choice-of-Law Analysis

The Eighth Circuit in In re St. Jude Medical, Inc., --- F.3d ----, 2005 WL 2509282 (8th Cir. Oct. 12, 2005) has held that where class members hail from numerous states, a choice-of-law analysis for the claims of each cannot be avoided simply because the law of the forum state permits "any person" to bring suit under its consumer protection statutes. Because the district court failed to engage in the required choice-of-law analysis, the Eighth Circuit decertified the class and remanded the case for further proceedings.