Health Law——Actual Injury From Medical Device Not Required to Confer Standing in Claim For Medical Monitoring——Sutton v. St. Jude Medical, S.C., Inc., 419 F.3d 568 (6th Cir. 2005)

Under the Supreme Court’’s interpretation of Article III of the United States Constitution, a plaintiff must suffer an injury-in-fact in order to obtain standing in federal court.  Recently, courts have relaxed this requirement and have awarded medical monitoring damages to plaintiffs who had not yet manifested any physical injury.  In Sutton v. St. Jude Medical S.C., Inc., the United States Court of Appeals for the Sixth Circuit considered whether the plaintiff had standing to bring a claim for medical monitoring against the manufacturer of an implanted medical device, where the plaintiff suffered no physical injury.  The court of appeals reversed the district court’’s decision and concluded that the potential for future injury constituted an injury-in-fact. . . .