Bosley v. DePuy Synthes Sales Inc

CourtDistrict Court, W.D. Washington
DecidedApril 7, 2022
Docket2:21-cv-01683
StatusUnknown

This text of Bosley v. DePuy Synthes Sales Inc (Bosley v. DePuy Synthes Sales Inc) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bosley v. DePuy Synthes Sales Inc, (W.D. Wash. 2022).

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 8 DERRICK C. BOSLEY, SR., 9 Plaintiff, Case No. C21-1683-MLP 10 v. ORDER 11 DePUY SYNTHES SALES INC., et al., 12 Defendants. 13

14 I. INTRODUCTION 15 This matter is before the Court on Plaintiff Derrick Bosley, Sr.’s motion for leave to 16 amend his amended complaint (“Plaintiff’s Motion”). (Pl.’s Mot. (dkt. # 29).) Defendants filed a 17 response in opposition to Plaintiff’s Motion (Defs.’ Resp. (dkt. # 32)) and Plaintiff submitted a 18 reply (Pl.’s Reply (dkt. # 33)). Having considered the parties’ submissions, the governing law, 19 and the balance of the record, the Court GRANTS Plaintiff’s Motion (dkt. # 29) for the reasons 20 discussed below. 21 II. DISCUSSION 22 Plaintiff generally alleges that Defendants are liable to him for defectively designing, 23 manufacturing, and/or selling without proper warning, the DePuy Attune Knee System (“Attune 1 Device”), which Plaintiff had implanted in his left leg in August 2014. (See Am. Compl. (dkt. 2 # 5) at ¶ 1.) Pursuant to the allegations in his complaint, Plaintiff alleges that the Attune Device 3 loosened, failed, and that the failure of the Attune Device was caused by the defective design 4 and/or construction of the device. (Id. at ¶¶ 2-4.)

5 Relevant to the instant matter, Plaintiff proposes nine amendments to his first amended 6 complaint. (Pl.’s Mot. at 2.) Seven of Plaintiff’s proposed amendments appear to restyle his 7 allegations, or merely clarify aspects of his complaint, and Defendants raise no objection to these 8 proposed amendments.1 (See Defs.’ Resp.) Therefore, Plaintiff is granted leave to amend those 9 portions of his complaint. 10 Plaintiff’s remaining contested amendments are considered in turn: 11 A. Strict Liability Claim 12 First, Plaintiff proposes an amendment to his first cause of action for unsafe design under 13 the Washington Product Liability Act (“WPLA”) that would plead the claim pursuant to a strict 14 liability standard instead of negligence. (Pl.’s Mot. at 2.) Defendants object to this amendment,

15 arguing that the amendment “is barred by the Restatement (Second) of Torts § 402A Comment k, 16 which Washington has expressly adopted,” and is therefore futile. (Defs.’ Resp. at 4-6.) 17 Federal Rule of Civil Procedure 15 provides that “a party may amend its pleading only 18 with the opposing party’s written consent or the court’s leave.” Fed. R. Civ. P. 15(a)(2) 19 20 1 Specifically, Plaintiff proposes amendments to: (1) clarify who the term “the Defendants” references; (2) replace the language “manufacturing and selling” with “designing, manufacturing, and/or selling” as 21 consistent with the tense of similar words or phrases throughout the Complaint; (3) replace the language “baseplate” with “component” throughout the Complaint; (4) replace the language “manufacturer” with 22 “Defendants” in a portion of the Complaint; (5) eliminate repetition in various portions of the Complaint; (6) conform the failure to warn allegations with the Washington Product Liability Act; and (7) replace a 23 reference to “RCW 19.86.090” with “the Washington Consumer Protection Act, RCW 19.86[.]” (Pl.’s Mot. at 2.) 1 Generally, “[t]he court should freely give leave [to amend] when justice so requires.” Id. “[T]his 2 policy is to be applied with extreme liberality.” Owens v. Kaiser Found. Health Plan, Inc., 244 3 F.3d 708, 712 (9th Cir. 2001) (quoting Morongo Band of Mission Indians v. Rose, 893 F.2d 4 1074, 1079 (9th Cir. 1990)).

5 Courts use five factors to “assess the propriety of a motion for leave to amend”: (1) bad 6 faith; (2) undue delay; (3) prejudice to an opposing party; (4) futility; and (5) previous 7 amendments by the plaintiff. Allen v. City of Beverly Hills, 911 F.2d 367, 373 (9th Cir. 1990). 8 Not all these factors are necessarily weighted equally, as “it is the consideration of prejudice to 9 the opposing party that carries the greatest weight.” Eminence Capital, LLC v. Aspeon, Inc., 316 10 F.3d 1048, 1052 (9th Cir. 2003). However, “[a]bsent prejudice, or a strong showing of [the other 11 four] factors, there exists a presumption under Rule 15(a) in favor of granting leave to amend.” 12 Id. (citation omitted). 13 Pertinent to Plaintiff’s sought amendment, Washington has incorporated the Restatement 14 (Second) of Torts § 402A, and comment k therein, under the WPLA. RCW 7.72.030; Taylor v.

15 Intuitive Surgical, Inc., 187 Wash.2d 743, 760-61 (2017) (en banc). Under section 402A, strict 16 liability is provided for anyone “who sells any product in a defective condition unreasonably 17 dangerous to the user or consumer[.]” Restatement (Second) of Torts § 402A(1) (Am. Law Inst. 18 1965). Comment k provides an exception to strict liability for “[u]navoidably unsafe products” 19 that are “quite incapable of being made safe for their intended and ordinary use.”2 Id. at cmt. k; 20

2 Comment k reads: 21

Unavoidably unsafe products. There are some products which, in the present state of 22 human knowledge, are quite incapable of being made safe for their intended and ordinary use. These are especially common in the field of drugs. An outstanding example is the 23 vaccine for the Pasteur treatment of rabies, which not uncommonly leads to very serious and damaging consequences when it is injected. Since the disease itself invariably leads to 1 see also Taylor, 187 Wash.2d at 761-62 (“[W]here a product is inherently dangerous by nature 2 but is still desirable because of its public benefit, it is an ‘unavoidably unsafe’ product under 3 comment k.”). However, in Taylor, the Washington Supreme Court found that “proper 4 preparation, marketing, and warnings” are necessary prerequisites for a manufacturer to be

5 exempt from strict liability as “comment k specifies that the exception is not available to a 6 manufacturer who fails to adequately warn.” 87 Wash.2d at 762. Therefore, only once these 7 prerequisites have been met can the exemption from strict liability apply. Id. 8 Here, Defendants appear to contend that because the Attune Device is a medical device 9 or product, Defendants are exempted from Plaintiff’s strict liability design defect claim solely by 10 the import of comment k. (Defs.’ Resp. at 5.) However, Defendants fail to address the “proper 11 preparation, marketing, and warning prerequisites” necessary to qualify for the strict liability 12 exemption under comment k.3 Because Plaintiff clearly challenges the adequacy of Defendants’ 13

14 a dreadful death, both the marketing and the use of the vaccine are fully justified, notwithstanding the unavoidable high degree of risk which they involve. Such a product, properly prepared, and accompanied by proper directions and warning, is not defective, 15 nor is it unreasonably dangerous. The same is true of many other drugs, vaccines, and the like, many of which for this very reason cannot legally be sold except to physicians, or 16 under the prescription of a physician.

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Related

Jack Allen v. City of Beverly Hills
911 F.2d 367 (Ninth Circuit, 1990)
Tansy v. Dacomed Corp.
1994 OK 146 (Supreme Court of Oklahoma, 1994)
Taylor v. Intuitive Surgical, Inc.
389 P.3d 517 (Washington Supreme Court, 2017)
Waldorf v. Shuta
3 F.3d 705 (Third Circuit, 1993)
United States v. Banks
10 F.3d 1044 (Fourth Circuit, 1993)
Transue v. Aesthetech Corp.
341 F.3d 911 (Ninth Circuit, 2003)

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