Kane v. Covidien LP

CourtDistrict Court, E.D. New York
DecidedFebruary 12, 2025
Docket2:23-cv-09207
StatusUnknown

This text of Kane v. Covidien LP (Kane v. Covidien LP) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kane v. Covidien LP, (E.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK

Elizabeth Kane, as administrator of the estate of William Kane, deceased, and Elizabeth Kane, individually,

Plaintiff, 2:23-cv-9207 -v- (NJC) (ARL)

Covidien LP, Covidien Sales LLC, Covidien Holding Inc., and Medtronic, Inc.

Defendants.

MEMORANDUM AND ORDER NUSRAT J. CHOUDHURY, United States District Judge: Plaintiff Elizabeth Kane (“Kane”) initiated this action against Covidien LP, Covidien Sales LLC, Covidien Holding Inc., and Medtronic, Inc. (together, “Defendants”) on December 15, 2023, bringing New York tort law claims arising out of her husband William Kane’s death following three abdominal surgeries. (Am. Compl., ECF No. 16 at 1–20.) On behalf of William Kane, Kane brings a breach of implied warranty claim, as well as design defect, manufacturing defect, and failure to warn products liability claims under strict liability and negligence theories. (Am. Compl. ¶¶ 17–67.) On behalf of herself, Kane brings derivative loss of consortium and wrongful death claims. (Id. ¶¶ 68–75.) Before the Court is Defendants’ motion to dismiss the Amended Complaint in its entirety (“Motion”). (Mot. Dismiss, ECF No. 22.) For the following reasons, the Motion is granted in part and denied in part. I grant the Motion with respect to Kane’s breach of implied warranty, design defect, and manufacturing defect claims, and dismiss those claims with prejudice. I deny the Motion with respect to Kane’s failure to warn and derivative loss of consortium and wrongful death claims. BACKGROUND The following facts are taken from Kane’s Amended Complaint and the surgeon’s report detailing William Kane’s September 16, 2021 operation (“Operative Report”), which is attached to, and incorporated by reference in, the Amended Complaint.1 (See generally Am. Compl.;

Operative Report, Am. Compl. Ex. A, ECF No. 16 at 21–24.) Kane is a New York citizen who resides in Centerreach, New York. (Am. Compl. ¶ 5.) Her husband, William Kane, passed away on December 16, 2021. (Id. ¶¶ 6, 69.) On August 30, 2022, Kane was appointed the administrator of William Kane’s estate. (Id. ¶ 6.) Covidien LP is a Delaware limited partnership, and its sole general partner is Covidien Holding Inc., a Delaware corporation. (Id. ¶¶ 7–8; Defs.’ Corrected Corporate Disclosure Statement at 1, ECF No. 28.)2 Covidien LP, Covidien Holding, Inc., and Covidien Sales LLC are collectively referred to as “Covidien.” Medtronic, Inc. is a Minnesota corporation with its principal place of business in Minnesota. (Id ¶ 10.)

Collectively, Defendants are “involved in the design, testing, manufacture, distribution, sales, marketing, regulatory management, and services” related to Defendants’ surgical stapler products. (Id. ¶¶ 7–10.) Relevant here, Kane alleges that Defendants made and sold a set of three

1 Under the Second Circuit’s decision in Clark v. Hanley, I consider documents that are incorporated by reference in the Amended Complaint, integral to the Amended Complaint, or otherwise the subject of judicial notice. 89 F.4th 78, 93 (2d Cir. 2023). 2 Covidien LP has four limited partners: (1) Batts, Inc.; (2) Life Design Systems, Inc.; (3) MSCH LLC, whose sole member is Mallinckrodt US LLC, whose sole member is Mallinckodt, Inc.; and (4) Nellcor Puritan Bennett LLC, whose only member is United States Surgical Corporation. (Defs.’ Corrected Corporate Disclosure Statement at 2.) Covidien LP is the sole member of Covidien Sales LLC. (Am. Compl. ¶ 7.) products used for stapling internal human organs during surgery: (1) “Staple loading unit DST Series GIA Titanium Staples, Blue Cartridge, Size 3.8mm, #GIA6038L”; (2) “Reloadable Stapler, 60mm size, 3.8 open x 1.5mm closed height, Blue, Titanium staples, #GIA6038S”; and (3) “Medtronic TA 60-3.5mm reloadable open stapler, #TA6035S” (together, the “Surgical Stapler”).3 (Id. ¶¶ 20–21.)

On September 3, 2021 William Kane underwent a “small bowel resection, mesh removal and primary abdominal wall closure” surgery to treat an “infected recurrent incisional hernia.” (Operative Report at 357.) On September 11, 2021, William Kane went to the Stony Brook University Hospital emergency room because he was experiencing “nausea, vomiting and abdominal distension.” (Id.) Medical staff at the hospital determined that his incisional hernia had recurred, and the next day, on September 12, 2021, he underwent a second surgery. (Id.; Am. Compl. ¶ 22.) The Amended Complaint describes the September 12, 2021 surgery as “open repair of incarcerated recurrent incisional hernia with biologic mesh, small bowel resection and primary side to side anastomosis” (Am. Compl. ¶ 22), and the Operative Report describes it as an

“exploratory laparotomoy, small bowel resection and abdominal wound closures with biological mesh.” (Operative Report at 357.) Michael Paccione, M.D. (“Dr. Paccione”) performed the surgery. (Id.; Am. Compl ¶ 22.) While the Amended Complaint provides few details on the procedures used to conduct the surgery, it alleges that the surgery involved Dr. Paccione using the Surgical Stapler to seal William Kane’s small bowel. (Am. Compl. ¶ 22.)

3 The Amended Complaint does not clarify whether all or some subset of these three stapler products were used in William Kane’s September 12, 2021 surgery. (See Am. Compl. ¶ 1 (referring to “a defective surgical stapler”); id. ¶¶ 7–8, 10 (referring to multiple “surgical staplers at issue in this case”); id. ¶ 40 (referring to a “surgical stapler system”).) For simplicity, I refer to these products collectively as the “Surgical Stapler.” Following the September 12, 2021 surgery, William Kane experienced “persistent leukocytosis,” and a “CT scan of [his] abdomen . . . revealed pneumoperitoneum with a significant amount of ascites.” (Id.) As a result of these post-operative complications, on September 16, 2021, Dr. Paccione performed an “exploratory laparotomy with lysis of

adhesions, small bowel resection with primary anastomosis and diverting loop ileostomy.” (Id.; Operative Report at 357–58.) Based on his findings during the September 16, 2021 surgery, Dr. Paccione concluded that the Surgical Stapler had failed to fully seal the surgery site following the September 12, 2021 surgery, causing William Kane’s small bowel to leak. (Am. Compl. ¶ 22; see also Operative Report at 358.) Specifically, he reported the following findings: The small bowel was then identified and eviscerated and run in its entirety to reveal an intact initial anastomosis placed on 9/3/21 approximately 10 cm proximal to the ileocecal value and the second anastomosis that was placed on 9/12/21 had anastomotic leak along the staple line with sucuss entericus leaking from the small bowel dehiscence. . . . The small bowel was run in its entirety and a significant amount of serositis was noted just proximal to the small bowel resection site. The free-end of the small bowel staple line was noted to have a leakage along the new staple line consistent with a failed staple line. (Am. Compl. ¶ 22 (quoting Operative Report at 358 (emphasis supplied in Amended Complaint).) According to the Amended Complaint, because “a stapling device can compress delicate organ tissue so tightly,” a surgeon is often not able to know “whether the stapler properly sealed a stomach, or a staple line failure has occurred” until “several days” after surgery. (Id. ¶ 4.) Dr. Paccione reported the failure to a “Stryker Drug Representative,” who was apparently present in the operating room at the September 16, 2021 surgery, although the reason for the drug representative’s presence is not clear from the pleadings. (Operative Report at 358.) William Kane died on December 16, 2021. (Am. Compl.

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