Becton Dickinson and Co. v. Usrey
This interlocutory appeal concerns the propriety of certifying a class action of Texas healthcare workers who sustained needlesticks from defectively designed syringes and needle-bearing medical devices manufactured by Becton Dickinson and Company and Sherwood Medical Company. The class sought reimbursement for post-needlestick testing costs, excluding claims for emotional distress or infection. The trial court certified the class, but the appellate court reversed this decision, concluding that common issues, particularly causation and comparative responsibility, do not predominate over individual issues as required by Rule 42 of the Texas Rules of Civil Procedure, especially under the more conservative approach mandated by Southwestern Refining Co. v. Bernal. The court found that needlestick injuries often involve unique circumstances, including the fault of the healthcare worker, employers, and third parties, which necessitate individual analysis. Furthermore, the trial court's proposed plan for handling individual comparative fault issues was deemed unfair and unduly restrictive.