Allen v. Wright Medical Technology, Inc.

CourtDistrict Court, E.D. Missouri
DecidedSeptember 13, 2022
Docket4:21-cv-01444
StatusUnknown

This text of Allen v. Wright Medical Technology, Inc. (Allen v. Wright Medical Technology, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Allen v. Wright Medical Technology, Inc., (E.D. Mo. 2022).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION VERNON ALLEN and MELANIE ALLEN, ) ) Plaintiffs, ) ) v. ) Case No. 4:21-cv-01444-SEP ) WRIGHT MEDICAL TECHNOLOGY, INC. ) ) Defendant. MEM ORAND U )M AND ORDER

Before the Court is Defendant Wright Medical Technology, Inc.’s Motion to Dismiss Counts II and V of Plaintiffs’ Complaint. Doc. 11. The Motion is fully briefed and ready for disposition. For the reasons set forFtAhC bTSe lAoNwD, BthAeC KMGoRtOioUnN Dis denied. Plaintiffs filed a Complaint in the Circuit Court for the City of St. Louis, Missouri, claiming that a surgically implanted artificial knee device designed, manufactured, distributed, and sold by Defendant, caused them injury. Doc. 4. Plaintiff Vernon Allen, in whose knee the device was implanted, alleges that the device injured him directly; Plaintiff Melanie Allen, Vernon’s spouse, brings a claim for loss of consortium. The Complaint sets forth six counts: Count I: negligence; Count II: strict products liability for manufacturing defect; Count III: strict products liability for design defect; Count IV: strict products liability for inadequate warning; Count V: negligent misrepresentation; Count IV: loss of consortium. Defendant removed the action to this Court on December 9, 2021. Doc. 1. Defendant filed this Motion on January 18, 2022, seeking to dismiss Counts II and V under Federal Rule st of Civil Procedure 12(b)(6). Doc. 11. On February 1 , Plaintiffs filed a motion to voluntarily dismiss Count II pursuant to Federal Rule of Civil Procedure 41(a)(1)(A). Doc. 13. The Court th granted Plaintiffs’ motion on February 7 . Doc. 18. Therefore, the only remaining issue is the sufficiency of Count V. LEGAL STANDARD

The purpose of a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6) is Neitzke v. Williams to test the legal sufficiency of a complaint. When considering a Rule 12(b)(6) motion, a court Braden v. Wal- assumes the factual allegations of a complaint are true, ,490 U.S. 319, 326- 2M 7a r (t 1 S 9t 8o 9r )e ,s a, I nn dc . draws all reasonable inferences in the non-movant’s favor. , 588 F.3d 585, 595 (8th Cir. 2009) (citation omitted). The sufficiency of a complaint is ordinarily tested by the general pleading standard of Federal Rule of Civil Procedure 8, which provides that a complaint must contain “a short and plain statement of the claim showing that the pleader is entitled to relief.” To survive a Ashcroft v. Iqbal motion to dismiss, the complaint must “contain sufficient factual matter, accepted as true, to Bell Atlantic Corp. v. Twombly, ‘state a claim to relief that is plausible on its face.’” , 556 U.S. 662, 678 (2009) (quoting 550 U.S. 544, 555 (2007)). “A pleading that offers Id. Twombly ‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause of action will not Id. Twombly do.’” (quoting , 550 U.S. at 570). “Nor does a complaint suffice if it tenders ‘naked assertions’ devoid of ‘further factual enhancement.’” (quoting , 550 U.S. at 555). Iqbal, Rule 8 “demands more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” 556 U.S. at 678. Streambend Properties II, LLC v. Ivy Tower All claims “grounded in fraud,” however, must meet the heightened pleading standard Minneapolis, LLC of Federal Rule of Civil Procedure 9(b). , 781 F.3d 1003, 1010 (8th Cir. 2015) (citations omitted). To satisfy Rule 9(b), “the complaint must plead such facts as the time, place, and content of the defendant’s U.S. ex rel. Joshi false representations, as well as the details of the defendant’s fraudulent acts, including when v. St. Luke’s Hosp., Inc. the acts occurred, who engaged in them, and what was obtained as a result.” , 441 F.3d 552, 556 (8th Cir. 2006) (citations omitted). In essence, the Ascente Bus. Consulting, LLC v. DR myCommerce plaintiff must plead the “who, what, where, when, and how” of the circumstances constituting fraud. , 9 F.4th 839,845 (8th Cir. 2021) (citations omitted). DISCUSSION In Count V Plaintiffs allege a claim for negligent misrepresentation. Doc. 4 ¶¶ 125-29. To plead a claim for negligent misrepresentation under Missouri law, Plaintiffs must allege (1)the speaker supplied in formation in the course of his business; (2) because of the speaker’s failure to exercise reasonable care, the information was false; (3) the information was intentionally provided by t he speaker for the guidance of limited persons in a particular business transaction; (4)the hearer justifiably relied on the information; and (5)due to the hearer’s reliance on the information, the hearer suffered a Renaissancep eLceuansiinagry, L lLoCss v. . Vermeer Mfg. Co. , 322 S.W.3d 112, 134 (Mo. banc 2010) (citation oI.m ittedR)u. le 9(b) does not apply to claims for negligent misrepresentation . See Defendant argues that Count V must be dismissed because it fails to satisfy the particularity requirement of Federal Rule of Civil Procedure 9(b). Doc. 12 at 5. There is conflicting precedent among federal courts as to whether Rule 9(b) applies to claims for negligent misrepresentation, but the Eighth Circuit does not require district courts to apply Rule 9(b) to such claims, and the trend in this District is to analyze claims for negligent Streambend Properties II, LLC v. Ivy Tower Minneapolis, LLC misrepresentation under the general pleading requirements of Rule 8(a). Defendant relies on , for Streambend Streambend the proposition that claims “grounded in fraud” must meet Rule 9(b). Doc. 12 at 15 (citing , 781 F.3d at 1010). But did not apply Rule 9(b) to negligent misrepresentations. 781 F.3d at 1011, 1013. The Eighth Circuit noted that “[a]t least some id. N. Am. Catholic Educ. Programming Found., Inc. v. of our sister circuits also apply Rule 9(b) to ‘associated claims’” such as negligent Cardinale misrepresentation, at 1011 (quoting negligent misrepresentations , 567 F.3d 8, 15 n.4 (1st Cir. 2009)), but the Court later explained that “if there are no specific averments of fraud, only allegations of innocent or Id. and omissions, then the sufficiency of th[e] claim is governed by the notice pleading standards of Rule 8(a).” at 1013 (emphasis added). Moreover, the Eighth Circuit had In re earlier held that “federal courts may not apply the heightened pleading standard of Rule 9(b) NationsMart Corp. Securities Litig. outside the two specific instances—fraud and mistake—explicitly found in the Rule.” , 130 F.3d 309, 315 (8th Cir. 1997).

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Related

Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Braden v. Wal-Mart Stores, Inc.
588 F.3d 585 (Eighth Circuit, 2009)
Renaissance Leasing, LLC v. Vermeer Manufacturing Co.
322 S.W.3d 112 (Supreme Court of Missouri, 2010)
Jack Carlon v. Michael E. Thaman
130 F.3d 309 (Eighth Circuit, 1997)
Ascente Business Consulting v. DR myCommerce
9 F.4th 839 (Eighth Circuit, 2021)

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Bluebook (online)
Allen v. Wright Medical Technology, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/allen-v-wright-medical-technology-inc-moed-2022.