Bosley v. DePuy Synthes Sales Inc

District Court, W.D. Washington·Decided October 3, 2023·No. 2:21-cv-01683·Unknown

Opinion

FOR THE WESTERN DISTRICT OF WASHINGTON

DERRICK C. BOSLEY, SR. ) Case No. C21-1683-MLP Plaintiff, ) ) PRETRIAL ORDER ) ) vs ) ) DEPUY SYNTHES SALES, INC. d/b/a/ ) RECONSTRUCTION; DEPUY ) ) ORTHOPAEDICS, INC.; DEPUY ) INTERNATIONAL LIMITED; JOHNSON ) & JOHNSON; JOHNSON & JOHNSON ) SERVICES, INC.; JOHNSON & JOHNSON ) INTERNATIONAL; MEDICAL DEVICE ) BUSINESS SERVICES, INC.; DEPUY, ) INC.; DEPUY SYNTHES PRODUCTS, ) ) INC.; DEPUY SYNTHES, INC.; DEPUY ) IRELAND UNLIMITED COMPANY; ) DEPUY SYNTHES JOHNSON & ) JOHNSON IRELAND LTD.; AND ) RELATED ENTITIES A, B AND C, ) ) ) Defendants. )

Jurisdiction is vested in this Court by virtue of and pursuant to 28 U.S.C. §1332 in that the amount in controversy alleged exceeds $75,000.00, exclusive of interest and costs, and this is an action by an individual Plaintiff against Defendants1 who are citizens of different states.

The Plaintiff will pursue the following claims at trial: 1. First Cause of Action - Washington Product Liability Act, Unsafe Design, Strict Liability. 2. Fifth Cause of Action - Washington Product Liability Act, Failure to Warn. The Defendants intend to assert certain affirmative defenses that they will pursue at trial and in response to Plaintiff’s claims, including, but not limited to, the following:

1. Plaintiff’s Complaint fails, in whole or part, to state a claim upon which relief may be granted. 2. Plaintiff fails to, and cannot, present evidence to support his claims against the Defendants. NOTE: Plaintiff objects to this asserted defense. 3. Plaintiff fails to meet his burden to show that Defendants are liable for his alleged injuries. NOTE: Plaintiff objects to this asserted defense.

1 In submitting this Joint Pretrial Order, Defendants do not waive and expressly reserve their objections to the entirety of Plaintiff’s pretrial disclosures, which were due (per LCR 16(h)) on August 10, 2023, but which were not served on Defendants until August 24, 2023. 4. Plaintiff fails to provide reliable expert testimony to support his claim that Defendants’ alleged conduct caused his injuries. Bruns v. PACCAR, Inc., 890 P. 2d 469, 477 (Wash. Ct. App. 1995). NOTE: Plaintiff objects to this asserted defense. 5. Plaintiff knowingly and voluntarily assumed any and all risks associated with the use of the ATTUNE® product at issue in this case and was subjectively aware of facts which cover any and all risks. Such assumption of the risks bars in whole or in part the damages Plaintiff seeks to recover in this case. 6. Plaintiff’s alleged injuries attributable to the use of the ATTUNE® product in this case, if any, were not legally caused by the ATTUNE® product, but instead were legally caused by intervening and superseding causes or circumstances. 7. Plaintiff’s alleged damages, if any, are barred in whole or in part by Plaintiff’s failure to mitigate such damages. 8. Plaintiff’s causes of action are barred by the applicable statutes of limitation, statutes of repose, doctrines of laches and/or estoppel. 9. Plaintiff’s claims are barred in whole or in part because the ATTUNE® product was, at all relevant, times manufactured and sold consistent with available technology, scientific knowledge, and the state of the art, and in compliance with all federal, state, and local laws and regulations, and was accompanied by product information and warnings that were reasonable, full and adequate and in accordance with FDA regulating requirements and the state of medical and scientific knowledge then in existence. Compliance with such codes, statutes, rules, regulations and standards demonstrates that due care was exercised with respect to the design, manufacture, testing, marketing and sale of the ATTUNE® product, and that Defendants are entitled to a presumption that the ATTUNE® product is neither defective, nor unreasonably dangerous. Plaintiff’s claims and any recovery are accordingly barred. 10. Plaintiff’s claims should be diminished in whole or in part by the amount paid to Plaintiff by any party or non-party with whom Plaintiff has settled or may settle. 11. Plaintiff’s damages, if any, are barred or limited by the payments received from collateral sources. 12. Plaintiff’s causes of action are barred by the learned intermediary doctrine. 13. Plaintiff’s claims are barred by the doctrines of informed consent, release and waiver. 14. Upon information and believe, if Plaintiff incurred any injuries or damages as a result of Plaintiff’s use of the ATTUNE® product, which Defendants deny, such injuries or damages were due to an alternative cause, without any negligence or culpable conduct by the Defendants. NOTE: Plaintiff objects to this asserted defense. 15. To the extent Plaintiff’s claims are based on alleged misrepresentations or omissions made to the FDA, such claims are barred pursuant to Buckman Co. v. Plaintiff’s Legal Comm., 531 U.S. 341 (2001). 16. If the ATTUNE® product is unsafe in any way, it was unavoidably unsafe. Plaintiff’s action is, therefore, barred by Comment K of §402A of the Restatement (Second) of Torts and/or other applicable law. See Hahn v. Richter, 543 Pa. 558, 673 A.2d 888 (1996). 17. Plaintiff’s injuries and damages, if any, were proximately caused by the negligence or fault of Plaintiff, or persons or parties whose identities are unknown at this time, and such comparative negligence or fault is sufficient to proportionately reduce or bar Plaintiff’s recovery. 18. Even if there was negligence on its part in the manufacture and sale of the ATTUNE® product, which Defendants expressly deny, such negligence was not the proximate or producing cause of the alleged injuries or damage. 19. The injuries and damages claimed by Plaintiff, if any, were caused in whole or in part by the acts or omissions of persons or entities over whom Defendants have no control or right of control. 20. Plaintiff’s claims should be dismissed, reduced, offset, or barred in accordance with the principles of comparative negligence. 21. Plaintiff’s claims are barred in whole or in part under Sections 2, 4, 6(c), and 6(d) of the Restatement (Third) of Torts: Product Liability. ADMITTED FACTS The following facts are admitted by the Parties: 1. On October 2, 2013, Plaintiff underwent a right total knee arthroplasty to treat his osteoarthritis. As part of the total knee arthroplasty procedure, his surgeon, Dr. William Barrett, implanted the ATTUNE® Knee System, which was designed, manufactured, and sold by the Defendants. 2. Plaintiff underwent a left total knee arthroplasty on August 13, 2014 to treat the osteoarthritis in his left knee. During this August 13, 2014 arthroplasty surgery, Plaintiff was implanted with the ATTUNE® Knee System in his left knee. 3. On January 23, 2019, Plaintiff returned to Dr. Barrett’s office complaining of left knee pain and was seen by Jana Flener, PA-C, who ordered x-ray imaging of Plaintiff’s left knee. 4. Dr. Barrett recommended Plaintiff proceed with a revision surgery. 5. The pre-operative and post-operative diagnosis for Plaintiff’s March 19, 2019 revision surgery was “failed fixation of left total knee.” 6. On March 19, 2019, Plaintiff underwent a revision of his left knee wherein the ATTUNE® Knee System that was implanted in his left knee on August 13, 2014 was removed and replaced. The following are the issues of law to be determined by the court: (a) Whether Defendants are liable to Plaintiff under the Washington Product Liability Act for Plaintiff’s harm and damages resulting from the allegedly defective design of the tibial component of the ATTUNE® Knee System implanted in his left leg in 2014, as set forth in his Second Amended Complaint, proximately caused by the fact that the Attune

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Bosley v. DePuy Synthes Sales Inc, (W.D. Wash. 2023).

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Related

Buckman Co. v. Plaintiffs' Legal Committee
531 U.S. 341 (Supreme Court, 2001)
Hahn v. Richter
673 A.2d 888 (Supreme Court of Pennsylvania, 1996)
Bruns v. Paccar, Inc.
890 P.2d 469 (Court of Appeals of Washington, 1995)