Commentators of every persuasion agree that mass torts, particularly tri-als of asbestos-induced diseases, confront the justice system with serious problems for which it has yet to find solutions. l While merely disposing of these cases has proven a formidable burden to courts, actually doing justice in them seems daunting. A procedure is evolving in the trial of these cases whereby samples of cases are tried and the resulting damages are then applied to the remaining population of cases. In this article, we discuss two aspects of this issue. First, we evaluate collective trials of mass torts under several theories of justice. Though the use of aggregation and sampling is sometimes criticized for failing to approximate the justice afforded by traditional case-by-case determinations, we con-clude that the perception that aggregation provides inferior adjudication is largely illusory. The perception proceeds from relying on the traditional bilateral trial as the touchstone of due process. In fact, aggregation adds an important layer of process which, when done well, can produce more precise and reliable outcomes. Paradoxically, the procedural innovation of aggregation provides a quality of justice that surpasses what courts have, until now, been capable of in any kind of case. 2