The Supreme Court on Monday announced it was granting review in Bruesewitz v. Wyeth, a test of the scope of the pre-emption provision of the National Childhood Vaccine Injury Act of 1986. It also noted that Chief Justice John Roberts Jr. “took no part” in the consideration or decision of the Court to take the case.

Though the justices almost never reveal their reasons for recusal, this one is almost certainly based on the fact that, as of the last financial disclosure form filed by Roberts in May 2009, he owned stock valued at $15,000 or less in Pfizer Inc. Pfizer acquired rival Wyeth in late 2009.

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