Miller v. Redwood Toxicology Laboratory, Inc., No. 11-3073 (8th Cir. 2012)
Annotate this CasePlaintiff appealed from the district court's grant of Redwood Toxicology Laboratory's motion to dismiss with prejudice his Minnesota state law claims raised in federal court under the court's diversity jurisdiction. Because plaintiff lacked Article III standing to raise the state statutory claims in federal court where he failed to allege a causal connection between Redwood's actions and any presumed injury suffered by him, and because his negligence claim likewise failed under Rule 12(b)(6), the court affirmed the district court's dismissal.
Court Description: Civil Case - diversity. Miller lacked Article III standing by failing to show causal relationship between any purported misleading statements. Common law negligence claims fail for failure to state a claim.
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