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Fernandez v. Takata Seat Belts

3/24/2005

strumentalities of a single state, such as various law enforcement agencies").


Even if we were to adopt the juridical link doctrine, we would conclude that the doctrine does not confer standing on Fernandez under the circumstances of this case. Fernandez does not allege a conspiracy or concerted action between the automobile manufacturers, nor does she allege that they had some legal relationship. See, e.g., Easter, 381 F.3d at 962 (finding that juridical link doctrine did not apply because plaintiffs "presented no evidence that their alleged injuries were the result of a conspiracy or concerted scheme between the . . . [defendants]"); Alexander v. PSB Lending Corp., 800 N.E.2d 984, 993 (Ind. Ct. App. 2003) (concluding that because plaintiffs did not allege any "contractual relationship, concerted conduct, or conspiracy" between defendants with whom named plaintiffs did not have direct contact, application of the juridical link doctrine was not warranted).


IV.


Finally, " lthough, as a matter of discretion, we can waive the requirement of standing, we do so only in exceptional circumstances, generally in cases involving issues of great public importance that are likely to recur." Hull, 192 Ariz. at 71, 25, 961 P.2d at 1019. Fernandez, however, has presented no circumstance that persuades us to waive the requirement of standing. She does not contend that her case concerns a matter of statewide importance, involves constitutional questions, or presents issues of such great public importance that we should exercise our discretion and waive standing for her class action claims. Id. at 71-72, 25-29, 961 P.2d at 1019-20.


V.


For the foregoing reasons, we vacate in part the decision of the court of appeals and affirm the ruling of the trial court dismissing the automobile manufacturers from the lawsuit.


Michael D. Ryan, Justice CONCURRING


Charles E. Jones, Chief Justice


Ruth V. McGregor, Vice Chief Justice


Rebecca White Berch, Justice


Andrew D. Hurwitz, Justice






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