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In Lockheed Martin Corp. v. Superior Court, the California Supreme Court rejected certification for a proposed medical monitoring class, but declined to set a per se bar against class treatment of such claims. The court held that individual issues predominated because the class members had not provided substantial evidence that they could resolve dosage issues with common proof. In rejecting certification, the court improperly focused on the substantive merits of the case and raised a manageability concern for future classes of medical monitoring claimants. Although the decision expressly allows for class treatment of medical monitoring claims under certain circumstances, it limits class-wide adjudication of environmental pollution and chemical exposure claims because it requires excessive scrutiny of the merits for certification. [ABSTRACT FROM AUTHOR]