Maestas v. Sofamor Danek Group, Inc – Case Brief Summary (Tennessee)

In Maestas v. Sofamor Danek Group, Inc., 33 S.W.3d 805, 807 (Tenn. 2000), the plaintiffs--patients alleged that the defendants'--manufacturers' medical screws caused them to sustain additional injury to their backs after they were hospitalized.

A few years later, parties, including the plaintiffs, initiated a class action against the defendants in the U.S. District Court for the Eastern District of Pennsylvania ("Pennsylvania U.S. District Court"). Id.

The Pennsylvania U.S. District Court denied the class action certification. Id. Thereafter, the plaintiffs filed individual lawsuits against the defendants in a Tennessee circuit court. Id.

Following discovery, the defendants filed a motion for summary judgment, alleging that the plaintiffs' claims were barred by the statute of limitations. Id. The circuit court granted the defendants' motion, and the Tennessee intermediate court affirmed. Id.

The Tennessee Supreme Court granted certiorari, and determined whether "cross-jurisdictional tolling would involve the tolling of the applicable Tennessee statute of limitations during the period in which the plaintiffs sought class certification as part of the unsuccessful classaction filed in the Pennsylvania U.S. District Court. Id.

The Tennessee Supreme Court denoted that adopting the cross-jurisdictional class action doctrine would assist the federal courts in reviewing class actions, but that its courts lacked interest in advancing "efficiency and economy of the class action procedures of another jurisdiction." Id. at 808.

Furthermore, the doctrine would create "fishing expeditions" because complainants would choose Tennessee as their "hub" to file their claims "because its cross-jurisdictional tolling doctrine would have effectively created an overly generous statute of limitations." Id.

To avoid "protective filings," in which "the plaintiffs would wish to preserve their right to file suit in Tennessee while they sought class certification elsewhere," the Tennessee Supreme Court indicated that staying the proceedings would resolve this potential issue. Id. at 808-09.

Lastly, if Tennessee applied the doctrine, it would grant the federal courts authorization to determine whether Tennessee's statute of limitations began to run, which was in strict contradiction to the Tennessee legislature's intent. Id. at 809.

Accordingly, the Tennessee Supreme Court did not adopt the cross-jurisdictional class action tolling doctrine, and affirmed the grant of the summary judgment motion. Id.