Ian Baker, Ind. & Representative of Estate of Jean Baker v. St. Jude Medical S.C. St. Jude Medical, Inc.

CourtCourt of Appeals of Texas
DecidedJune 30, 2005
Docket01-02-00802-CV
StatusPublished

This text of Ian Baker, Ind. & Representative of Estate of Jean Baker v. St. Jude Medical S.C. St. Jude Medical, Inc. (Ian Baker, Ind. & Representative of Estate of Jean Baker v. St. Jude Medical S.C. St. Jude Medical, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ian Baker, Ind. & Representative of Estate of Jean Baker v. St. Jude Medical S.C. St. Jude Medical, Inc., (Tex. Ct. App. 2005).

Opinion

Opinion issued June 30, 2005



In The

Court of Appeals

For The

First District of Texas





NO. 01-02-00802-CV





KEITH BAKER, INDIVIDUALLY, AND IAN BAKER, INDIVIDUALLY AND AS INDEPENDENT EXECUTOR OF THE ESTATE OF JEAN BAKER, DECEASED, Appellants


V.


ST. JUDE MEDICAL, S.C., INC. AND ST. JUDE MEDICAL, INC., Appellees





On Appeal from the Probate Court Number One

Harris County, Texas

Trial Court Cause No. 312,543-402-A





O P I N I O N

          This appeal involves the issue of federal preemption of state law causes of action arising out of the implantation of an allegedly defective heart valve in the deceased, Jean Baker. Specifically, we must decide whether state common–law causes of action asserted by Baker’s heirs against the valve manufacturer are preempted by the manufacturer’s compliance with the Food and Drug Administration’s premarket approval procedures for certain medical devices. Because we hold that state product-liability claims are preempted by federal law in this case, we affirm the summary judgment granted in the manufacturer’s favor.

BACKGROUND

Legislative Background of Medical Devices Act

          In 1976, in response to mounting consumer concern over, among other things, defective intrauterine devices, Congress passed the Medical Device Amendments (MDA) to allow the Food and Drug Administration (FDA) to regulate medical devices. The MDA creates three categories of medical devices. The most stringent FDA control is over Class III devices, which are devices that either “presen[t] a potential or unreasonable risk of illness or injury,” or which are “purported or represented to be for a use in supporting or sustaining human life or for a use which is of substantial importance in preventing impairment of human health.” See 21 U.S.C. § 360c(a)(1)(C)(ii)(I-II). It is undisputed that a heart valve is a Class III medical device.

Obtaining FDA Approval to Market Class III Devices

          1. Full PMA Approval

          Before marketing a Class III device, the manufacturer must either submit its product to the FDA for premarket approval (PMA) or qualify for one of two exceptions to the premarket approval process. To obtain PMA approval, the manufacturer must provide the FDA with “reasonable assurance” that the device is safe and effective. See 21 U.S.C. § 360e(d)(2). To do so, manufacturers submit detailed information regarding their device, which the FDA then reviews for an average of 1200 hours before approving or disapproving the device. Medtronic, Inc. v. Lohr, 518 U.S. 470, 477, 116 S. Ct. 2240, 2247 (1996).

          2. § 510(k) Exemption to PMA approval

          In addition to the “rigorous” PMA process, there are two exemptions by which a manufacturer may gain the FDA’s permission to market a device. Id. at 477-78, 116 S. Ct. at 2247. One of these exemptions permits devices that are “substantially equivalent” to devices existing in 1976 to be marketed and sold without full PMA approval. See 21 U.S.C. § 360j(g)(1). This review is known as a section 510(k) review (after the number of the section in the original act) and is “by no means comparable to the PMA process.” Lohr, 518 U.S. at 479, 116 S. Ct. at 2247. As opposed to the PMA’s average review time of 1200 hours, a § 510(k) review takes an average of only 20 hours to complete. ” Lohr, 518 U.S. at 478, 116 S. Ct. at 2247.           3. PMA Supplementation for Modifications to PMA–Approved Devices

          If a manufacturer wants to modify a Class III device that already has PMA approval, the manufacturer may submit a PMA supplement, rather than obtain an entirely new PMA approval. See U.S. v. Prigmore, 243 F.3d 1, 5 (1st Cir. 2001) (describing PMA supplement process). The PMA supplement “must contain scientific information that provides a basis for approval of the modified device.” Id. (quoting 21 C.F.R. § 814.39(c)). The procedures for a PMA supplement are the same as those for an original PMA, although the FDA requires only that the manufacturer provide materials supporting the proposed modification. Worthy v. Collagen Corp., 967 S.W.2d 360, 364-65 (Tex. 1998); Kemp v. Medtronic., Inc., 231 F.3d 216, 222 (6th Cir. 2000).

Factual Background

          In 1982, the FDA approved St. Jude’s initial PMA application for a mechanical heart valve. During the following years, St. Jude made several improvements to the valve, which were approved through a series of PMA supplements. One of these improvements incorporated a rotating sewing cuff, which eliminated the need for surgery to position the valve before sewing it in place.

          In an effort to combat endocarditis, a life-threatening infection of the heart muscle, St. Jude notified the FDA that it planned to develop a mechanical heart valve with an infection-resistant, sterile, silver coating on the sewing cuff. In May 1997, after an FDA-required animal test was completed, St. Jude submitted a PMA supplement to add the Silzone coating to its already approved heart valve.

          In March 1998, the FDA approved St. Jude’s PMA supplement. As part of its approval, the FDA imposed several post-approval requirements, including how the valve could be marketed. Specifically, the FDA prohibited St. Jude from making any claims about the efficacy of the Silzone coating in preventing endocarditis. St. Jude began marketing the Silzone valve accordingly.

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Ian Baker, Ind. & Representative of Estate of Jean Baker v. St. Jude Medical S.C. St. Jude Medical, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/ian-baker-ind-representative-of-estate-of-jean-bak-texapp-2005.