Recently, the Mississippi Supreme Court, in Paz v. Brush Engineered Materials, Inc., became the fifth consecutive state court of last resort to reject a cause of action for medical monitoring in the absence of an identifiable injury. The case came to the court on a certifi ed question from the Fifth Circuit Court of Appeals and involved employee claims of beryllium exposure while working at defendants’ manufacturing facilities. Class action plaintiff s sought the creation of a courtsupervised medical monitoring fund to detect the possible development of Chronic Beryllium Disease, typically a latent disease which impairs the lungs and often causes death. The court held that adoption of a medical monitoring action for asymptomatic plaintiff s “would require an  unprecedented and unfounded departure from the long-standing traditional elements of a tort action.” The Alabama, Nevada, Kentucky, and Michigan Supreme Courts—the four other courts of last resort to recently consider the issue—have all rejected medical monitoring absent a present physical injury....