Class Action Certification: Ennis v. Johnson & Johnson, 2024 BCSC 1759
Judge: The Honourable Mr. Justice Armstrong Decision Release Date: September 23, 2024Kelly Ennis brought a class action lawsuit against Johnson & Johnson, its consumer companies, and subsidiaries under the Class Proceedings Act, alleging that the company’s talc-based product, Johnson’s® Baby Powder, contributed to the development of ovarian cancer in users who applied it perineally. Ms. Ennis, who had used Baby Powder in the genital region for most of her teenage and adult life, was diagnosed with epithelial ovarian cancer in 2021.The certification hearing faced numerous challenges. In a November 2020 decision, the court had initially allowed certification but required the plaintiff to provide additional information on the methodology to prove general causation. This was necessary to establish a plausible way to link the use of Baby Powder with the development of ovarian cancer on a class-wide basis. The plaintiff then presented an expert report from Dr. Daniel W. Cramer, a clinical epidemiologist, who opined that there was a statistically significant association between perineal Baby Powder use and epithelial ovarian cancer.Justice Armstrong considered whether this evidence met the standard required for certification. Dr. Cramer’s methodology highlighted various risk factors, including menopausal status and hormone therapy, and compared these against the average increased risk presented by Baby Powder use. He suggested that the carcinogenic pathway of talc was similar to that of asbestos, causing chronic inflammation and DNA damage. Despite the defendants’ experts countering that ovarian cancer consists of different types with distinct causes and characteristics, the court found Dr. Cramer’s methodology to be a realistic means to test general causation.Although the defendants argued that individual factors like genetics and lifestyle would still dominate any causation analysis, the court concluded that the class could be certified for those who used Baby Powder perineally and were subsequently diagnosed with epithelial ovarian cancer. However, the...