Gerber Baby Food Lawsuit – December 2024 Update

Individuals are filing Gerber baby food lawsuits because of brain disorders allegedly caused by heavy metals in baby food manufactured by Gerber and other companies. These lawsuits have been consolidated into MDL# 3:24-md-3101-JSC In re: Baby Food Products Liability Litigation in the Northern District of California. As of December 2024, there are 75 lawsuits pending in the federal product liability litigation. The presiding judge is Jacqueline Scott Corley. This lawsuit is in the early stages, and the parties are still adding more plaintiffs and discussing fact-gathering deadlines. People are continuing to file Gerber baby food lawsuits today.

Gerber Baby Food Lawsuit Timeline & News – December 2024

November 8, 2024: Gerber MDL Judge Enters Pretrial Order Setting Important Deadlines

On November 8, 2024, the federal Judge overseeing the Gerber baby food lawsuit entered an order setting important deadlines to help the case move forward smoothly. For example, the order says that the parties can start to gather information from certain experts in April 2025 and that there will be a five-day expert hearing starting December 8, 2025. The next hearing in this lawsuit is on December 12, 2024. 

June 18, 2024: Plaintiffs in Gerber MDL Suggest Scope of Questioning for Expert Hearing on Heavy Metal Exposure and Autism

On June 18, 2024, the plaintiffs in the federal Gerber lawsuit filed a legal document suggesting possible topics to discuss with experts in an upcoming hearing. The defendants want to discuss all baby food in general. The plaintiffs would like the focus to be on heavy metal exposure—such as from baby food—and the development of autism spectrum disorder or ADHD. 

June 13, 2024: Gerber MDL Plaintiffs Submit Brief To Protect Information During Fact-Gathering Stage

On June 13, 2024, the Gerber baby food MDL plaintiffs filed a legal brief supporting a discovery motion they filed. The plaintiffs had requested an order to safeguard confidential and sensitive information. Because the fact-gathering stage of this case may involve thousands of documents, the parties discussed terms to prevent unnecessary disclosure to the public. The plaintiffs submitted this brief to support its proposed terms for this order. 

April 11, 2024: Multiple State Gerber Baby Food Lawsuits Consolidated in Federal MDL Case

On April 11, 2024, the United States Judicial Panel on Multidistrict Litigation created a consolidated baby food product liability lawsuit in federal court in the Northern District of California. This MDL has grown to include about 75 lawsuits against Gerber, Nestle, Campbell, Beech-Nut, and other baby food manufacturers. Parents continue to sue in state court and in this multidistrict litigation to seek damages for their children and families. 

December 22, 2023: Missouri Mom Files Lawsuit Against Gerber Because of Heavy Metals in Baby Food

On December 22, 2023, Geraldine Nji filed a lawsuit against Gerber, Beech-Nut, Nestle, Walmart, Campbell, and Plum on behalf of her son, H.N., who has severe autism spectrum disorder (ASD). Geraldine believes that heavy metals—e.g., lead, inorganic arsenic, cadmium, and mercury—in her son’s baby food injured his brain and caused ASD. She requests a jury trial and full compensation, including past and future medical expenses.

What is the Gerber Baby Food Lawsuit About?

Parents and concerned advocates are suing Gerber over concerns that the company’s products caused infants and children to suffer brain damage and develop conditions like autism spectrum disorder and ADHD. Reports surfaced revealing the high levels of cadmium, lead, mercury, and inorganic arsenic in Gerber’s baby food products. Plaintiffs in these lawsuits believe Gerber knew or should have known about the high levels of neurotoxins in their products, but Gerber ignored the risks and failed to take action or warn parents. 

Because so many people filed baby food lawsuits, many of the cases were consolidated into one large federal MDL in the Northern District of California. Gerber denies the allegations that parents and others have made against it. Still, these lawsuits highlight the need for stricter regulations and testing for foods made for infants and small children. This litigation is ongoing, and people can join in this fight by filing a legal claim. A trained product liability lawyer can help parents and concerned loved ones understand their options and take steps to hold Gerber accountable for the harm they inflicted on vulnerable infants and children. 

Gerber Baby Food Lawsuit Information
Lawsuit Name:	In re: Baby Food Products Liability Litigation
Main Injuries:	Autism spectrum disorder and ADHD
Defendants:	Gerber
Mass tort or class action?	Mass tort
MDL Number:	3:24-md-3101-JSC
Pending Cases:	75
Court Name (Venue):	Northern District of California
Have There Been Settlements?	No
Active Lawsuit?	Yes

Why Are People Filing Gerber Baby Food Lawsuits?

People are suing Gerber because they believe neurotoxins in their baby food cause neurological damage to children. People making these claims rely on research and recent reports showing that Gerber and other baby food manufacturers sold dinners, applesauce, juices, snacks, teething biscuits, and other baby foods with very high amounts of lead, cadmium, mercury, and inorganic arsenic. 

For example, when a Congressional Report was issued in 2021, Gerber said it rarely tested its products for mercury, so it was unaware of how much mercury was in Gerber’s baby food. Mercury, lead, cadmium, and inorganic arsenic are known neurotoxins that can cause severe and permanent brain damage, such as decreased IQ, developmental delays, and behavioral disturbances. Research also suggests a link between these chemicals and the later development of ADHD and autism spectrum disorder (ASD). 

Allegations Against Gerber

The plaintiffs accuse Gerber of selling baby food with unsafe levels of heavy metals in them. They claim these neurotoxins damaged the fragile developing brains of infants and children, who later developed conditions like ASD and ADHD. Plaintiffs say that Gerber knew about the extremely high level of heavy metals in the ingredients and finished products, yet did nothing to warn parents or source safer ingredients. 

For example, according to the 2019 Healthy Babies Bright Future report, Gerber’s rice single grain cereal had 74 parts per billion of inorganic arsenic. Additionally, one version of Gerber’s MultiGrain Cereal (i.e., Sitter 2nd Foods) had 26.2 parts per billion (ppb) of cadmium. A 2021 Congressional Report revealed that Gerber tested for lead, inorganic arsenic, and cadmium but still allowed baby foods with dangerous levels of neurotoxins to be sold to the public. 

Gerber’s Response to These Allegations

Although Gerber denies the allegations made against it, Gerber also acknowledged the findings in the 2021 Congressional Report. In a public statement, it affirmed its commitment to sourcing safe ingredients and producing healthy and nontoxic foods for our nation’s babies. Gerber expressed its willingness to collaborate with stakeholders and the FDA to help provide safe and nutritious goods. 

Gerber says it now regularly tests its products for toxins like lead, inorganic arsenic, cadmium, and mercury. Additionally, Gerber maintains that it tracks agricultural practices to limit the amount of naturally occurring neurotoxins in its ingredients and finished products. Even so, Gerber only made these commitments in 2021 in the wake of a searing report by Congress. Moreover, Gerber is under scrutiny from regulators and plaintiffs to make sure what they put on the shelves is truly non-toxic.  

Gerber Baby Food Lawsuit Spotlight

H.N., a minor, by and through his mother and Next Friend, Geraldine Nji v. Gerber Products Company et al, Case Number 4:23-cv-942

Geraldine Nji sued Gerber, Nestle, Hain, Beech-Nut, and other corporate defendants on behalf of the plaintiff, H.N., a minor. Geraldine’s child consumed large quantities of baby food and formula developed by the defendants and which had high levels of known neurotoxins. Geraldine’s child has developed severe autism spectrum disorder and is unable to “live a fulfilling life.” 

Based on public reports and her own investigation, Geraldine believes Gerber knew the toxic contents of its baby food but failed to warn the public about this. Additionally, Geraldine believes Gerber had an obligation to change its practices to reduce the amount of heavy metals in its food and the risk of neurodevelopmental harm to H.N. and other children. Geraldine filed her lawsuit in the Western District of Missouri and is requesting compensatory and punitive damages. 

About the Defendant: Gerber

Gerber began its operations in 1927 and creates a wide range of baby food products, including cereals, meals, baby foods, snacks, and beverages. Gerber also has a line of organic goods that include cereals, baby foods, snacks, and beverages. The lawsuit claims that many of Gerber’s products may be toxic and have the potential to cause brain injuries. 

What Stage is the Gerber Baby Food Lawsuit In?

The litigation against Gerber is ongoing and in its early stages. The plaintiffs and Gerber are still filing pretrial motions and resolving discovery deadlines and disputes. The plaintiffs have presented a host of evidence about the heavy metals in Gerber’s products and research showing how those substances can cause neurodevelopmental harm, like autism spectrum disorder. 

Gerber is trying to sidestep liability by pointing out that these substances can also appear naturally in the soil. However, the parents and other advocates involved in the lawsuit have evidence that the level of heavy metals in Gerber’s foods is much higher than what would normally be in the soil. Additionally, the heavy metal content of Gerber’s foods may be unsafe, regardless of whether it is naturally occurring or introduced during production. 

What Heavy Metals Can Be Found In Gerber Foods?

Many of Gerber’s foods contain lead, cadmium, inorganic arsenic, and mercury. These substances can be found naturally in soil, especially in contaminated areas. However, agricultural and industrial processes can create an unhealthy imbalance and increase the amount of these toxins in the soil. The plants then pick up the heavy metals, and the contaminated plants are harvested and used in Gerber’s baby foods.  

Gerber acknowledges the presence of these toxic substances in the soil, and it also claims to be taking steps to reduce or eliminate these high levels of lead, cadmium, mercury, and inorganic arsenic. That said, for many babies who consumed this food before Gerber undertook these efforts to increase the safety of its products, the damage is already done. 

Health Risks Due To Heavy Metals in Baby Food

Heavy metals can interrupt an infant’s neurological development, decreasing the baby’s IQ, and causing them to experience attention deficits, hyperactivity, impulsivity, and symptoms of autism. For example, inorganic arsenic was found in higher concentrations in the hair of children with autism versus their neurotypical peers. Likewise, long-term exposure to lead is associated with a “significant” difference in IQ test scores of children under 12. Because of children’s body size, how they metabolize food, and how much they eat in proportion to their body weight, children are at a greater risk when ingesting heavy metals. 

Baby Food Products With Potentially High Levels of Arsenic

Baby food containing rice tends to have a significantly higher concentration of organic and inorganic arsenic. A 2019 study published by Healthy Babies Bright Futures found that 73 percent of the 168 baby foods it tested had arsenic in them. A follow-up study conducted by Consumer Reports in 2023 found that, while the overall heavy metal content of most of the 14 baby foods it tested showed improvement in quality and safety, there is still a long way to go. These studies revealed that baby foods containing rice, fruit juices, and vegetables (especially root vegetables) tend to carry the highest amount of heavy metals. 

Baby Food Products With Potentially High Levels of Lead

The 2019 Healthy Babies Bright Futures study found that a startling 94 percent of the 168 baby foods it tested contained lead. Eighty-three percent of the products tested had more than public advocates’ recommended 1 ppb of lead in them. Ingredients that pose the highest risk to an infant’s developing brains include fruit juices—particularly apple and grape juices, which can soar above the 10 ppb proposed by the FDA—and root vegetables—like carrots and sweet potatoes grown in contaminated soil. Rice-based baby foods tend to have trace amounts of lead in them, as do teething biscuits.

Baby Food Products With Potentially High Levels of Cadmium

According to the 2019 Healthy Babies Bright Futures study, 75 percent of the 168 baby foods they looked at had cadmium in them. Of those, about 15 percent had cadmium content that health experts considered concerning. Consumers Reports’ 2023 study found moderate improvements in the cadmium consent of baby foods it studies. Consumer Reports stresses the need for continued efforts to improve safety, and it cautions parents against feeding their children food made from rice, carrots, sweet potatoes, spinach, and leafy greens grown in contaminated soil. 

Baby Food Products With Potentially High Levels of Mercury

The 2021 Congressional Report revealed most companies do not test for mercury.  In that report, Gerber said it rarely tested for mercury and did not provide Congress with its testing data. Healthy Babies Bright Futures indicates that 32 percent of baby foods it analyzed had mercury in them. Baby foods that may have the highest risk of mercury contamination include purées with fish, rice-based meals and snacks, fruit juices—especially apple and grape—and root vegetables like carrots and sweet potatoes.   

Gerber Baby Food Products With Heavy Metal Contamination

Multiple studies revealed that many of Gerber’s products contain at least one heavy metal, and many of its baby foods contain more than one. Despite knowledge of the presence of lead, cadmium, mercury, and inorganic arsenic in its goods, Gerber continued to push its products out into commerce, putting thousands of babies at risk. 

Some of Gerber’s products that have or had inorganic arsenic in them include the following:

• Gerber Oatmeal Single Grain, Supported Sitter 1st Foods: 39.7 ppb
• Gerber Puffs: 49.7 ppb
• Gerber Puffs Banana Crawler: 43.7 ppb
• Gerber Puffs Blueberry Crawler: 48.8 ppb
• Gerber Puffs Strawberry Apple Crawler: 43.7 ppb
• Gerber Puffs Sweet Potato Crawler: 41.4 ppb
• Gerber Rice Cereal Single Grain Supported Sitter 1st Foods: 122 parts per billion (ppb)
• Gerber Rice Organic, Single Grain Cereal, Supported Sitter 1st Foods: 118 ppb
• Gerber Teethers Strawberry Apple Spinach: 89.1 ppb
• Gerber Teethers Banana Peach, 7+ Months: 73.7 ppb

The following Gerber baby foods were found to contain lead:

• Gerber Organic Apple Blueberry Spinach – Sitter 2nd Food: 1.5 ppb
• Gerber Apple Sweet Potato with Cinnamon – Toddler 12+ months: 3.1 ppb
• Gerber Arrowroot Biscuits – Crawler 10+ months: 12.5 ppb
• Gerber Barley Single Grain Cereal – Supported Sitter 1st Foods: 3 ppb
• Gerber Beef and Gravy 2nd Foods: 2.1 ppb
• Gerber Puffs Banana Cereal Snack – Crawler 8+ months: 9.2 ppb
• Gerber Carrot Pear Blackberry – Sitter 2nd Foods: 3.6 ppb
• Gerber Carrot – Supported Sitter 1st Foods: 11 ppb
• Gerber Carrot – Sitter 2nd Food: 9.4 ppb
• Gerber Carrot Sweet Potato Pea – Sitter 2nd Foods: 6.7 ppb
• Gerber Chicken Rice Dinner – Sitter 2nd Foods: 2.3 ppb
• Gerber Diced Carrots Veggie Pick-Ups: 11.8 ppb
• Gerber Fruit & Veggie Melts – Truly Tropical Blend – Freeze-Dried Fruit & Vegetable Snack – Crawler, 8+ months: 12.2 ppb
• Gerber Fruit & Vegetable Snack – Crawler, 8+ months: 12.2 ppb
• Gerber Green Bean – Sitter 2nd Food: 0.8 ppb
• Gerber Green Bean – Supported Sitter 1st Foods: 0.7 ppb
• Gerber Ham and Gravy 2nd Foods: 1 ppb
• Gerber Lil’ Sticks Chicken Sticks – Toddler: 3.5 ppb
• Gerber Mashed Potatoes & Gravy with Roasted Chicken and a Side of Carrots – Toddler: 2.4 ppb
• Gerber Organic Mango Apple Carrot Kale – Sitter 2nd Foods: 1.1 ppb
• Gerber MultiGrain Cereal – Sitter 2nd Foods: 5.3 ppb
• Gerber Peach – Sitter 2nd Foods: 2.4 ppb
• Gerber Pea – Sitter 2nd Foods: 0.7 ppb
• Gerber Pear – Sitter 2nd Foods: 1.1 ppb
• Gerber Rice Single Grain Cereal: 3.9 ppb
• Gerber Sweet Potato Supported Sitter 1st Foods Tub: 20.3 ppb
• Gerber Sweet Potato – Sitter 2nd Food: 29.3 ppb
• Gerber Sweet Potato – Supported Sitter 1st Foods: 14.6 ppb
• Gerber Teether Wheels – Apple Harvest – Crawlers: 2.1 ppb
• Gerber Turkey Rice Dinner – Sitter 2nd Foods: 5.2 ppb
• Gerber Whole Wheat Whole Grain Cereal – Sitter 2nd Foods: 5.5 ppb
• Gerber Yogurt Blends Strawberry Snack – Crawler 8+ months: 1 ppb

Some of Gerber’s products that contain cadmium are listed below:

• Gerber Carrot, Natural for Baby, Sitter 2nd Foods: 25.8 ppb
• Gerber Carrot Sitter 2nd Foods: 24.7 ppb
• Gerber Oatmeal Single Grain, Supported Sitter 1st Foods: 15.3 ppb
• Gerber Puffs: 19.7 ppb

Scientific Studies About How Heavy Metals Can Affect Child Development

As evidence mounts, researchers have studied possible links between  heavy metals in a child’s diet and an autism or ADHD diagnoses. According to their findings, neurotoxins like lead, cadmium, inorganic arsenic, and mercury can greatly disrupt a child’s neurological development. The resulting impacts can include a decrease in IQ, difficulties with memory, behavior, attention, and impulsivity, and symptoms of autism spectrum disorder. Infants and small children—who are still developing—are especially vulnerable to the effects of heavy metals and other toxins in the products they consume. 

Many scientific studies have found links between heavy metals in a child’s diet and that child developing neurological issues. For example, a study published in the journal Frontiers in Pediatrics looked at data from 54 studies regarding heavy metal levels in hair and blood samples taken from children. The study found that children with ASD were more likely to have higher levels of lead, cadmium, mercury, and arsenic in their systems. Each of these heavy metals have been found to be present in large amounts in certain Gerber baby foods.

U.S. Government’s Regulatory Response to Heavy Metals in Baby Food

Federal and state regulatory authorities took action after a Congressional report in 2021 uncovered concerning levels of heavy metals in many baby food products on the market in the United States. For example, members of the United States Senate introduced the Baby Food Safety Act of 2024, which (if passed) would empower the FDA to establish and impose limits on the levels of heavy metals in baby foods sold in the United States. Additionally, this Act would require companies to regularly test for these metals and take steps to eliminate or reduce them to reach safe levels. 

The FDA launched its Closer to Zero Initiative in 2021 to help decrease the amount of lead, cadmium, mercury, and arsenic in food intended for infants and small children. The state of California followed suit with the passage of California’s AB-899, which requires companies to conduct monthly tests for heavy metals in baby foods starting January 1, 2024, and publicly post the results beginning on January 1, 2025. 

What Damages Can People Sue Gerber For?

People who file a lawsuit against Gerber can request a range of damages to compensate them and their families for the significant losses they have experienced because of contaminated baby food. For example, plaintiffs might ask for money to cover the past and future costs of diagnosing and treating autism spectrum disorder. Covered expenses in this category could include transportation costs, medications, educational support and physical, occupational, and speech therapy. If the parents need to make modifications to their home or purchase assistive devices—like a device to help their child communicate—they may qualify for reimbursement. 

Other damages might include payment of court costs, attorney’s fees, emotional distress, and loss of quality of life. If the child cannot earn an income because of their autism spectrum disorder, they and their parents may qualify for compensation to address this. Finally, Gerber may have to pay punitive damages, which would punish them for their willful failure to take action to protect this nation’s most vulnerable population. 

Who Qualifies to File a Gerber Baby Food Lawsuit?

Someone may qualify to file a lawsuit against Gerber if they meet the following criteria:

• The child was born on or after January 1, 2007.
• The child consumed specific brands of baby foods for at least six months.
• The child was diagnosed with autism spectrum disorder before turning 14 years old.

The contaminated brands of baby food that the child must have eaten for at least six months include those made by Gerber, Parent’s Choice, Earth’s Best Organic, Sprout Organic, Plum Organics, HappyFAMILY, or HappyBABY. 

What Would Prevent Someone From Filing a Gerber Baby Food Lawsuit?

Children may not qualify for compensation from Gerber if they were preterm—e.g., born before 37 weeks—were born before January 1, 2007, or weighed less than 5.5 pounds at birth. Additionally, children may be ineligible to file a lawsuit if they were diagnosed with autism after turning 14, were diagnosed with certain syndromes or conditions, or consumed the contaminated food for less than six months. Children born to mothers who had health or pregnancy-related complications—like diabetes or tobacco usage—may also be unable to sue. Finally, if the child was involved in another related litigation—like the suit involving Tylenol and childhood ADHD—they may not be able to participate in this active case.

What Proof Do You Need to File a Gerber Baby Food Lawsuit?

To prove a child qualifies for compensation from Gerber, the person needs to gather high-quality evidence. For example, they need to have a qualifying and confirmed diagnosis of autism spectrum disorder, medical records that show the child’s developmental progress, and any neurological delays they experienced. Likewise, the person needs to have receipts, bank statements, and other proofs of purchase to show that the baby consumed the contaminated foods for at least six months. The parent can also gather evidence such as food diaries and pediatrician notes to show what the child ate during their life.  

8 Steps to File a Gerber Baby Food Lawsuit

Filing a lawsuit against Gerber involves gathering the necessary evidence to show that your baby consumed the contaminated food and received an autism diagnosis before turning 14. You may want to discuss your concerns and explore your legal options by consulting with a product liability lawyer. They can help you identify and comply with your filing deadlines—called the statute of limitations. 

Once you file your case, you would participate in a formal fact-gathering process called discovery, and then try to negotiate an out-of-court settlement. If you cannot reach a settlement, you can go to trial to try to win a jury verdict or judgment. If you win your case, you would receive compensation, or, if you lose, you would have the option to file an appeal.

These are the 8 steps for filing a Gerber baby food lawsuit:

1. Talk to a product liability lawyer
2. Gather your child’s medical history
3. Figure out what legal claims you can make against Gerber and other baby food manufacturers
4. File a Gerber baby food autism lawsuit before the deadline expires
5. Complete the discovery phase of your lawsuit
6. Try to negotiate a settlement
7. Go to trial if you cannot settle the case against Gerber
8. Receive a settlement award or judgment if you win your case

A seasoned lawyer who handles claims against Gerber and other baby food manufacturers can help you understand and complete the above steps. 

What to Expect When Filing a Gerber Lawsuit

When filing a lawsuit against Gerber, keep in mind that it may take some time before you resolve the lawsuit. You and the opposing side would need to engage in extensive fact-gathering, which may involve sending out and responding to requests for information. Additionally, you may talk to witnesses who can give their impression of your child’s symptoms or discuss Gerber’s internal testing processes. You can use the information you discover during this stage to help support your legal arguments or refute the ones that Gerber brings up. 

What is the Deadline for Filing a Gerber Baby Food Lawsuit?

The courts impose a deadline—called a statute of limitations—on when people can file lawsuits against Gerber or other baby food manufacturers. The deadline depends on things like where the original lawsuit is filed, the particular claims the person is making, and other factors. The deadline for Gerber baby food autism lawsuits can vary, and factors like the child’s age and the emergence of new research can extend the deadline even further. Parents and concerned family members are encouraged to speak with a trained attorney for help understanding what deadlines apply to their child’s case and what they need to do to meet these.

Gerber Baby Food Lawsuit Settlements and Awards

Some settlements for Gerber baby food autism lawsuits may reach up to $1.5 million in limited cases, such as if a child has severe ASD symptoms. That said, receiving a damages award is not guaranteed, and many factors can impact the likelihood and amount of someone’s settlement. For example, the overall strength of the plaintiff’s lawsuit and whether they filed before the deadline expired can influence the final result. Additionally, the long-term impacts of the child’s autism spectrum disorder and its associated symptoms may change what damages they can receive if they win their lawsuit. Because there is so much variability in settlements, parents and advocates are encouraged to talk to a knowledgeable lawyer to determine a case-specific estimate in their situation.

Factors Affecting the Value of a Gerber Baby Food Lawsuit

The actual settlement someone receives in a Gerber baby food lawsuit depends on a range of factors, such as:

• The impact of the ASD on the child and parent’s lives
• How much of each Gerber product their child consumed
• The strength of the claims the family has against Gerber or other baby food manufacturers
• Whether the person can prove that they meet the eligibility criteria to receive compensation 
• How quickly they file their lawsuit against Gerber

A trusted product liability lawyer can help children and their families fight for the maximum compensation available to them under state and federal law. 

Learn More About Gerber Baby Food Lawsuits From Our Legal Team

Gerber had a responsibility to take steps to protect infants and toddlers from avoidable harm caused by eating contaminated baby foods. Reports show that Gerber knew about the dangerous levels of lead, cadmium, and inorganic arsenic in its products—and failed to test for mercury—yet they continued to market their products as safe. As growing evidence reveals, children may have suffered greatly because of Gerber’s willful mistakes. 

If your child ate contaminated baby foods for at least six months and was diagnosed with autism before turning 14, you may qualify for compensation. Our law firm has helped dozens of individuals and families recover damages from negligent corporations that make mistakes that hurt or kill vulnerable members of the public. Our team respects your pain and is here to help you take a stand against Gerber and other baby food manufacturers to compensate you for your losses and help protect other infants from harm. Contact us today to schedule a free case review.

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