Zurich American Insurance Co. v. Nokia, Inc.
Justice Hecht's dissenting opinion argues against the majority's application of the eight-corners rule in cellphone radiation class actions. He contends that while plaintiffs allege "biological injury," they meticulously avoid claiming actual "bodily injury" damages to facilitate class certification. Hecht asserts that the claimed damages, primarily for headsets, are not "because of bodily injury" and that class members are not required to have used phones or suffered personal injury. He highlights class counsel's explicit disclaimers of individual injury claims, concluding that insurers should not be compelled to defend these claims as they do not actually or potentially involve damages due to bodily injury.