In products and class action cases involving exposure to purportedly hazardous materials, plaintiffs often have trouble demonstrating concrete physical injuries, and in particular concrete physical injuries that would be common across a class.  To avoid dismissal and bolster class certification, those plaintiffs sometimes bring so-called “medical monitoring” claims, which seek recovery for the present-day costs of testing and other early detection procedures designed to mitigate injuries that might occur sometime in the future.

In Brown v. Saint-Gobain Performance Plastics Corp., 2023 WL 2577257 (N.H. Mar. 21, 2023), the Supreme Court of New Hampshire became the latest state to reject medical monitoring as a standalone cause of action, reaffirming the longstanding, common-sense principle that “possibility [of injury] is insufficient to impose any liability or give rise to a cause of action.”  The court also rejected the plaintiffs’ argument that present-day medical costs arising from increased risk of harm are in and of themselves a compensable injury, holding that “an increased risk of harm is not an injury for purposes of a negligence action.”  Put differently, even though a plaintiff might incur present-day costs, those costs are not recoverable absent an actual, present-day injury.

Although some states allow medical monitoring claims, a number have adopted the same prohibition announced in Saint-Gobain, including Alabama, Illinois, Kentucky, Michigan, Mississippi, New York, and Oregon.  The Supreme Court of New Hampshire’s decision is also notable for its recognition that medical monitoring claims have faced sharp legislative resistance, specifically citing the New Hampshire legislature’s failure to enact a statutory cause of action for medical monitoring in 2020.

Photo of Steve Petkis Steve Petkis

Steve Petkis is a partner in the firm’s Washington, DC office, where he represents a variety of clients in their most sensitive, complex, and high-stakes litigation matters in both state and federal court. He regularly defends life sciences clients and other regulated entities…

Steve Petkis is a partner in the firm’s Washington, DC office, where he represents a variety of clients in their most sensitive, complex, and high-stakes litigation matters in both state and federal court. He regularly defends life sciences clients and other regulated entities against class action and mass tort claims that span jurisdictions.

Steve handles cases from pre-litigation planning through appeal, with a proven record of delivering victories at all stages. He was a member of the trial team that secured a complete defense win for McKesson in a landmark public nuisance case involving prescription opioid medications. In addition, his briefing strategies, fact and expert depositions, and courtroom stand-up have helped steer a number of other clients to highly-favorable resolutions that eliminate billions of dollars in potential exposure.

Steve previously served as a law clerk to Judge Katherine B. Forrest on the United States District Court for the Southern District of New York. He maintains an active pro bono practice focused on civil rights and criminal justice issues.

Photo of Emily Ullman Emily Ullman

Emily Ullman has a complex civil litigation practice focusing on products liability and mass torts work, primarily representing members of the life sciences industry and consumer goods manufacturers and suppliers across federal and state courts. In addition, she counsels companies facing transactions, regulatory…

Emily Ullman has a complex civil litigation practice focusing on products liability and mass torts work, primarily representing members of the life sciences industry and consumer goods manufacturers and suppliers across federal and state courts. In addition, she counsels companies facing transactions, regulatory interactions, or strategic decisions that expose them to tort risk.

Photo of Andrew Soukup Andrew Soukup

Andrew Soukup is a co-chair of the firm’s Class Action Litigation Practice Group. Andrew specializes in representing heavily regulated businesses in class actions, multidistrict litigation, and other high-stakes disputes. Recognized for achieving “big wins in his class action practice,” Andrew has defeated a variety…

Andrew Soukup is a co-chair of the firm’s Class Action Litigation Practice Group. Andrew specializes in representing heavily regulated businesses in class actions, multidistrict litigation, and other high-stakes disputes. Recognized for achieving “big wins in his class action practice,” Andrew has defeated a variety of advertising, consumer protection, privacy, and product defect and safety claims ranging in exposure from millions to billions of dollars.

Andrew’s clients include those in the consumer products, life sciences, financial services, technology, automotive, and media and communications industries. He has helped his clients prevail in litigation in federal and state courts across the country against putative class representatives, government agencies, state attorneys general, and commercial entities.

With a long history of representing companies subject to extensive federal regulation and oversight, Andrew provides a unique ability to help courts understand the complex environment that governs clients’ businesses. Clients turn to Andrew because of his successful outcomes at all stages of litigation, his responsiveness and attention to their matters, his understanding of their businesses, and his creative strategies.

Andrew’s recent successes include:

  • Leading the successful defense of several of the world’s leading companies and brands from claims that they engaged in deceptive marketing or sold defective products, including claims brought under state consumer protection and unfair deceptive acts or practices statutes.
  • Delivering wins in multiple nationwide class actions on behalf of leading financial institutions related to fees, disclosures, and other banking practices, including the successful defense of numerous financial institutions accused of violating the Paycheck Protection Program’s implementing laws, which contributed to Covington’s recognition as a “Class Action Group of the Year.”
  • Helping one of the world’s largest seafood companies defeat ESG-related claims accusing the company of misrepresenting its environmental-friendly production practices.

Andrew has also obtained favorable outcomes for numerous clients in commercial and indemnification disputes raising contract, fraud, and other business tort claims. He helps companies navigate contractual and indemnification disputes with their business partners. And he advises companies on their arbitration agreements, and has helped numerous clients avoid multi-district and class-action litigation by successfully enforcing their arbitration agreements.

Watch: Andrew provides insights on class action litigation, as part of our Navigating Class Actions video series.