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Keywords

tortplaintiffliabilitystatutesummary judgment
tortplaintiffdamagesliabilitystatute

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Bruesewitz v. Wyeth LLC, 562 U.S. 223, 131 S.Ct. 1068, 179 L.Ed.2d 1, 79 USLW 4067, Prod.Liab.Rep. (CCH) P 18,580, 11 Cal. Daily Op. Serv. 2262, 2011 Daily Journal D.A.R. 2686, 22 Fla. L. Weekly Fed. S 790

Facts

Hannah Bruesewitz's parents filed a vaccine injury petition in the Court of Federal Claims, claiming that Hannah became disabled after receiving a DTP vaccine manufactured by Lederle Laboratories. After their claim was denied, they rejected the judgment and filed suit in Pennsylvania state court, alleging that the defective design of the vaccine caused Hannah's disabilities. Wyeth, the manufacturer, removed the case to federal court, where the court granted summary judgment in favor of Wyeth, stating that the relevant Pennsylvania law was preempted by the NCVIA.

Hannah Bruesewitz's parents filed a vaccine injury petition in the Court of Federal Claims, claiming that Hannah became disabled after receiving a DTP vaccine manufactured by Lederle Laboratories.

Issue

Whether the preemption provision in the National Childhood Vaccine Injury Act bars state-law design-defect claims against vaccine manufacturers.

We consider whether a pre-emption provision enacted in the National Childhood Vaccine Injury Act of 1986 (NCVIA) bars state-law design-defect claims against vaccine manufacturers.

Rule

The NCVIA preempts all design-defect claims against vaccine manufacturers if the injury or death resulted from side effects that were unavoidable, even if the vaccine was properly prepared and accompanied by proper directions and warnings.

No vaccine manufacturer shall be liable in a civil action for damages arising from a vaccine-related injury or death associated with the administration of a vaccine after October 1, 1988, if the injury or death resulted from side effects that were unavoidable even though the vaccine was properly prepared and was accompanied by proper directions and warnings.

Analysis

The Court analyzed the text of the NCVIA, concluding that the statute's language indicates that a vaccine's design is not subject to question in a tort action. The Court reasoned that if a manufacturer could be held liable for failing to use a different design, the term 'unavoidable' would be rendered meaningless. The absence of design-defect liability in the Act suggests that Congress deliberately chose not to include it, reinforcing the conclusion that design defects are not a basis for liability under the NCVIA.

The Court analyzed the text of the NCVIA, concluding that the statute's language indicates that a vaccine's design is not subject to question in a tort action. The Court reasoned that if a manufacturer could be held liable for failing to use a different design, the term 'unavoidable' would be rendered meaningless.

Conclusion

The Supreme Court affirmed the lower court's decision, holding that the NCVIA preempts all design-defect claims against vaccine manufacturers.

The Supreme Court affirmed the lower court's decision, holding that the NCVIA preempts all design-defect claims against vaccine manufacturers.

Who won?

Wyeth prevailed in the case because the Supreme Court found that the NCVIA preempted the design-defect claims brought by the plaintiffs, thereby protecting the manufacturer from liability.

Wyeth prevailed in the case because the Supreme Court found that the NCVIA preempted the design-defect claims brought by the plaintiffs, thereby protecting the manufacturer from liability.

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