Dearinger v. Eli Lilly and Company

CourtDistrict Court, W.D. Washington
DecidedJune 30, 2022
Docket2:21-cv-00060
StatusUnknown

This text of Dearinger v. Eli Lilly and Company (Dearinger v. Eli Lilly and Company) 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
Dearinger v. Eli Lilly and Company, (W.D. Wash. 2022).

Opinion

THE HONORABLE JOHN C. COUGHENOUR 1 2 3 4 5 6 UNITED STATES DISTRICT COURT 7 WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE 9 DAVID DEARINGER and GANNA CASE NO. C21-0060-JCC DEARINGER, 10 ORDER 11 Plaintiff, 12 v. 13 ELI LILLY AND COMPANY ,

14 Defendants. 15

17 This matter comes before the Court on Defendant Eli Lilly and Company’s motion to 18 dismiss for failure to state a claim (Dkt. No. 14). Having thoroughly considered the briefing and 19 the relevant record, the Court hereby GRANTS Defendant’s motion (Dkt. No. 14) and 20 DISMISSES Plaintiffs’ complaint without prejudice for the reasons explained below. 21 I. BACKGROUND 22 Plaintiffs allege that in 2018, Mr. Dearinger suffered an intracerebral hemorrhage leading 23 to a paralytic stroke within two hours of taking Cialis, a prescription drug that Defendant 24 manufactured and sold. (Dkt. No. 10 at 4.) Cialis is used to treat erectile dysfunction, enlarged 25 prostate symptoms, and pulmonary arterial hypertension. (Id.) Plaintiffs claim that, as a result of 26 this stroke, Mr. Dearinger suffered permanent loss of sensory and motor function of the left side 1 of his body. (Id.) They assert five causes of action under Washington’s Products Liability Act, 2 (Chapter 7.72 RCW): (1) design defect; (2) failure to warn at the time of manufacture; (3) failure 3 to warn after manufacturing; (4) breach of warranty; and (5) loss of consortium. (Dkt. No. 10 at 4 7–11.) Plaintiffs allege Defendant knew or should have known Cialis presented a risk of 5 paralytic stroke and failed to adequately warn of this risk. (Id. at 7–10.) Plaintiffs claim that 6 Cialis’s label does not adequately warn of the risk of cerebrovascular events because it warns of 7 the risk of stroke only in the context of “cardiovascular events.” (Dkt. No. 32 at 5.) 8 In April 2021, Defendant filed a motion to dismiss for failure to state a claim. (Dkt. No. 9 14 at 9). It argued, among other things, that under the learned intermediary doctrine, any duty to 10 warn was owed only to Mr. Dearinger’s prescribing physician, such that adequately pleading the 11 claim requires alleging that the doctor would have taken a “different course of action” had 12 Defendant provided a different warning. (Id.) Plaintiffs responded urging the Court to adopt an 13 exception to this doctrine for prescription drugs marketed directly to consumers, (Dkt. No. 25 at 14 12), and the Court certified the question to the Washington State Supreme Court. (Dkt. No. 28.) 15 The Supreme Court declined to recognize this exception and held that the learned intermediary 16 doctrine applies to prescription drugs marketed directly to consumers. (Dkt. No. 30-1 at 19.) The 17 parties then each submitted additional briefs (Dkt. Nos. 32, 34). 18 II. DISCUSSION 19 A. Legal Standard 20 To survive a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), “a 21 complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is 22 plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. 23 Twombly, 550 U.S. 544, 570 (2007)). A claim has facial plausibility when the plaintiff pleads 24 factual content that allows the court to draw the reasonable inference that the defendant is liable 25 for the misconduct alleged. Id. The Court accepts as true all material allegations of fact and 26 construes the complaint in a light “most favorable to the non-moving party,” however merely 1 “conclusory allegations of law and unwarranted inferences” will not defeat an otherwise proper 2 Rule 12(b)(6) motion. See Vasquez v. L.A. Cty., 487 F.3d 1246, 1249 (9th Cir. 2007) (internal 3 citation omitted). 4 The Court “ha[s] an obligation to give a liberal construction to the filings of pro se 5 litigants.” Blaisdell v. Frappiea, 729 F.3d 1237, 1241 (9th Cir. 2013). The Court will thus hold 6 Plaintiffs’ filings “to less stringent standards than normal pleadings drafted by lawyers.” Hughes 7 v. Rowe, 449 U.S. 5, 9 (1980) (internal quotation marks omitted). 8 B. Plaintiffs’ Failure-to-Warn Claims (Dkt. No. 10 at 7–8) 9 The Court cannot determine at this stage whether the warning provided by Defendant as 10 to the risk of cerebrovascular stroke was legally adequate. See Montalbano v. Ariad Pharm., Inc., 11 2015 WL 11198245, slip op. at 6 (S.D. Fla. 2015) (determining adequacy of the warning was not 12 well-advised at 12(b)(6) stage and better suited for summary judgement or trial); Webb v. Stryker 13 Corp., 2016 WL 11783344, slip op. at 3 (W.D. Pa. 2016) (plaintiffs need not allege, at the 14 pleadings stage, precisely how a warning was deficient or how an adequate warning would have 15 prevented injury). This is generally a question of fact for the jury and only becomes a question of 16 law where the warning is “accurate, clear, and unambiguous.” Ludy v. Eli Lilly and Company, 17 2020 WL 3510811 slip op. at 4 (S.D. Ind. 2020) (internal quotation marks omitted). In this case, 18 there is sufficient ambiguity in Cialis’s label and about whether a more specific stroke warning 19 was needed to prevent the Court from deciding the issue at the pleadings stage. 20 Plaintiffs’ claim, however, is still inadequately pled, as they fail to allege whether a 21 different label would have affected the prescribing physician’s decision to prescribe Cialis to Mr. 22 Dearinger. A failure to warn claim requires a plaintiff to show that (1) the defendant failed to 23 adequately warn, (2) the plaintiff suffered damages, and (3) the defendant’s failure to warn 24 proximately caused the plaintiff’s damages. Breen v. Ethicon, Inc., 2021 WL 673485 slip op. at 5 25 (W.D. Wash. 2021). But under the learned intermediary doctrine, a pharmaceutical manufacturer 26 satisfies its duty to warn the patient by properly warning the prescribing physician of the risks of 1 its product. Dearinger v. Eli Lilly & Co., 510 P.3d 326, 329 (Wash. 2022). The Washington State 2 Supreme Court confirmed that this principle applies even when a drug manufacturer advertises 3 its product directly to consumers. Id. at 331–33. Thus, to establish proximate cause, plaintiffs 4 must allege that a different warning would have impacted the physician’s decision to prescribe 5 this medication. See Tutwiler v. Sandoz, Inc., 726 F. App’x 753, 756 (11th Cir. 2018) (finding 6 allegations insufficient as plaintiff failed to allege that her physician would not have prescribed 7 the drug if he had been aware of the risks). 8 Even accepting Plaintiffs’ allegations that Cialis contained an inadequate warning about the 9 risk of suffering a particular type of stroke, they still have failed to allege that the prescribing 10 physician would have acted differently had Defendant provided an adequate warning. Id. The Court 11 believes that Plaintiffs can cure this defect by amending their complaint to properly allege proximate 12 cause of Mr. Dearinger’s injuries within the framework of the learned intermediary doctrine. 13 C. Preemption (Dkt. No. 14 at 10) 14 Defendant claims that Plaintiffs’ design defect claim is preempted because federal law 15 forbids Defendant from changing Cialis’s label design without prior FDA approval. (Dkt. No. 14 16 at 11).

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Dearinger v. Eli Lilly and Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dearinger-v-eli-lilly-and-company-wawd-2022.