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Keywords

negligenceliabilityappealsummary judgmentstrict liability

negligenceliabilitytrialmotionsummary judgmentstrict liability

Related Cases

Hufft v. Horowitz, 4 Cal.App.4th 8, 5 Cal.Rptr.2d 377, Prod.Liab.Rep. (CCH) P 13,253

Facts

Larry D. Hufft underwent surgery in April 1987 to implant an inflatable penile prosthesis (IPP) to treat erectile dysfunction. Following the surgery, Hufft experienced persistent pain and an almost constant erection, leading to multiple corrective surgeries and ultimately the removal of the device. He subsequently sued AMS, the manufacturer of the IPP, along with his doctors, alleging negligence, strict liability, and breach of warranty.

In April of 1987, Hufft underwent surgical implantation of an inflatable penile prosthesis (IPP) to alleviate a penile erectile dysfunction. The IPP caused him to experience an almost constant erection, persistent pain and emotional distress. Three corrective surgeries failed to remedy the problem. Eventually, Hufft had the IPP removed and replaced with a different type of device. He sued his doctors, their medical group and the IPP manufacturer, AMS, seeking recovery against AMS on causes of action for negligence, strict liability and breach of express and implied warranties.

Issue

The main legal issue was whether the rule from Brown v. Superior Court, which immunizes manufacturers of prescription drugs from strict liability for design defects, should be extended to manufacturers of implanted prescription medical devices.

In our review, we must decide whether the rule of Brown v. Superior Court (1988) 44 Cal.3d 1049, 245 Cal.Rptr. 412, 751 P.2d 470, immunizing manufacturers of prescription drugs from strict liability for design defects, should be extended to manufacturers of implanted prescription medical devices.

Rule

A manufacturer is not strictly liable for injuries caused by a prescription drug or implanted medical device if the product was properly prepared and accompanied by warnings of its dangerous propensities that were known or reasonably scientifically knowable at the time of distribution.

Brown holds, “[A] manufacturer is not strictly liable for injuries caused by a prescription drug so long as the drug was properly prepared and accompanied by warnings of its dangerous propensities that were either known or reasonably scientifically knowable at the time of distribution.”

Analysis

The court applied the rule by examining whether AMS had conclusively demonstrated that the IPP was properly manufactured and adequately warned of its risks. While AMS provided evidence of proper manufacturing, it failed to establish that it adequately warned physicians about the specific risks associated with the device, particularly the risk of spontaneous erections, which created a genuine issue of material fact.

Here, although there is no strict liability cause of action for design defect, AMS presented no evidence of the state of its knowledge of the risks at the time it distributed the product. It therefore failed to negate the existence of triable issues of fact as to the adequacy of its warnings. It was not entitled to summary judgment.

Conclusion

The Court of Appeal reversed the summary judgment in favor of AMS, concluding that there were triable issues of material fact regarding the adequacy of warnings and the manufacturer's knowledge of risks.

Reversed and remanded.

Who won?

Larry D. Hufft prevailed in the appeal because the court found that genuine issues of material fact existed regarding AMS's knowledge of the risks associated with the IPP, which precluded summary judgment.

Hufft contends the trial court erred in granting summary judgment because triable issues of material fact exist as to all causes of action.

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Flowers v. Torrance Memorial Hospital Medical Center, 8 Cal.4th 992, 884 P.2d 142, 35 Cal.Rptr.2d 685

Michael v. Hahnemann Medical College & Hospital of Philadelphia, Inc., 404 Pa. 424, 172 A.2d 769

Wharton Transport Corp. v. Bridges, 606 S.W.2d 521, 24 A.L.R.4th 1295

Fletcher v. South Peninsula Hosp., 71 P.3d 833

Syracuse v. Diao, 272 A.D.2d 881, 707 N.Y.S.2d 570, 2000 N.Y. Slip Op. 04565