McAuliffe v. Microport Orthopedics, Inc.

CourtDistrict Court, N.D. Illinois
DecidedSeptember 2, 2021
Docket1:20-cv-07322
StatusUnknown

This text of McAuliffe v. Microport Orthopedics, Inc. (McAuliffe v. Microport Orthopedics, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McAuliffe v. Microport Orthopedics, Inc., (N.D. Ill. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

JANICE MCAULIFFE, as Executor ) for the Estate of Walter McAuliffe, ) ) Plaintiff, ) ) No. 20 C 7322 v. ) ) Judge John Z. Lee MICROPORT ORTHOPEDICS, INC., ) a Delaware corporation, BIOMET ) ORTHOPEDICS, LLC, BIOMET, INC., ) BIOMET U.S. RECONSTRUCTION, ) LLC, BIOMET MANUFACTURING, ) LLC f/k/a BIOMET MANUFACTURING ) CORP., ZIMMER, INC., and ZIMMER ) BIOMET HOLDINGS, INC., ) ) Defendants. )

MEMORANDUM OPINION AND ORDER

Following a left hip replacement in October 2016, Walter McAuliffe developed metallosis, or metal poisoning, caused by dangerous levels of cobalt being released from each of the implant’s two components: a femoral head (i.e., a ball) manufactured by MicroPort Orthopedics, Inc. (“MicroPort”); and an acetabular revision system (i.e., a socket) manufactured by Zimmer, Inc. (“Zimmer”). Walter filed this action against MicroPort and Zimmer (as well as other Zimmer entities) shortly before passing away for apparently unrelated reasons, after which his surviving spouse, Janice McAuliffe, took over as Plaintiff. Before the Court is MicroPort’s motion to dismiss Counts III through VI of Janice’s amended complaint for failure to state a claim. For the reasons set forth below, the motion is granted in part and denied in part. I. Background* Walter received a total replacement of his left hip from Dr. Tad Gerlinger at Rush University Medical Center in Chicago, Illinois on October 14, 2016. Am. Compl.

¶¶ 7−8, ECF No. 39. The hip implant consisted of two components that form a ball- and-socket prosthetic joint: a MicroPort femoral head made of cobalt chromium and a Zimmer Trebecular Metal Acetabular Revision System. Id. ¶¶ 9−10. Water relied on Dr. Gerlinger to recommend these particular components. Id. ¶¶ 11–12. Following the surgery, the MicroPort and Zimmer metal components began to poison Walter by releasing dangerous amounts of cobalt into his body. Id. ¶¶ 14−16,

19. Walter subsequently developed metallosis, or more specifically cobalt toxicity, a type of metal poisoning. Id. ¶¶ 17–19. As a result of these injuries, Walter had to undergo a second invasive surgery on November 19, 2018, to revise the implants. Id. ¶ 20. Ultimately, Janice attributes Walter’s injuries to defects in each component of the metal-on-metal hip prosthesis that he received. Id. ¶ 27. Walter filed this action in state court in late 2020, raising six counts: (I) strict products liability design and manufacturing defect; (II) negligent design and

manufacture; (III) strict products liability failure to warn; (IV) negligent failure to warn; (V) breach of implied warranties; and (VI) fraudulent concealment. After the action was removed to federal court based on diversity jurisdiction, MicroPort moved to dismiss Counts III through VI for failure to state a claim. See Def. MicroPort’s

* The following well-pleaded factual allegations are accepted as true for purposes of the motion to dismiss. Mot. Dismiss Counts III–VI, ECF No. 19. As for the Zimmer entities, they have since been voluntarily dismissed. See 8/23/21 Min. Entry, ECF No. 44. Walter passed away soon thereafter. His wife, Janice, then moved to

substitute herself as party plaintiff under Federal Rule of Civil Procedure 25(a) and filed the operative amended complaint under the Illinois Survival Act, 755 Ill. Comp. Stat. 5/27-6. Because the amended complaint is substantively identical to its predecessor, MicroPort has elected to stand on its motion to dismiss. II. Legal Standard To survive a motion to dismiss under Rule 12(b)(6), a complaint must “state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544,

570 (2007). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). This standard “is not akin to a probability requirement, but it asks for more than a sheer possibility that a defendant has acted unlawfully.” Id. (cleaned up). When considering a motion to dismiss, courts accept “all well-pleaded factual

allegations as true and view them in the light most favorable to the plaintiff.” Lavalais v. Vill. of Melrose Park, 734 F.3d 629, 632 (7th Cir. 2013). At the same time, courts are “not bound to accept as true a legal conclusion couched as a factual allegation.” Papasan v. Allain, 478 U.S. 265, 286 (1986). Accordingly, “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice” to state a claim. Iqbal, 556 U.S. at 678. III. Analysis MicroPort moves to dismiss the complaint’s claims of failure to warn (Counts III and IV), breach of an implied warranty of fitness for a particular purpose (Count

V), and fraudulent concealment (Count VI). The Court addresses each claim or group of claims in turn. A. Failure to Warn (Counts III and IV) MicroPort moves to dismiss Counts III and IV for a variety of reasons. It first argues that Janice fails to plead that the medical community did not already know about the risk of metallosis associated with metal-on-metal hip implants. In Illinois, “a manufacturer’s duty to warn physicians is limited and does not extend to risks

already known to the medical community.” Aquino v. C.R. Bard, Inc., 413 F. Supp. 3d 770, 790 (N.D. Ill. 2019) (citing Hansen v. Baxter Healthcare Corp., 764 N.E.2d 35, 42 (Ill. 2002)). Here, however, the complaint is silent as to the medical community’s knowledge. Although Janice contends that risks associated with metal-on-metal hip implants “were not those of the type generally ascertained or known by the public or to Decedent,” she does not mention the medical community. Am. Compl. ¶ 24.

Accordingly, MicroPort’s motion to dismiss Counts III and IV is granted on this basis. At the same time, the Court rejects MicroPort’s other arguments for dismissing these counts. MicroPort leans on the learned intermediary doctrine, which provides that “a manufacturer has no duty to warn patients of the risks of . . . medical products so long as it provides sufficient warnings to the physician.” Aquino, 413 F. Supp. 3d at 789. But MicroPort overlooks Janice’s allegations that it failed to warn both Walter and Dr. Gerlinger of the risks of metallosis. Compl. ¶¶ 58, 79. Relying on Grzanecki v. Smith and Nephew, Inc., MicroPort also complains that Janice “does not allege any specifics regarding [its] warnings, beyond the conclusory allegation that the warnings

issued were insufficient.” See No. 18 C 204, 2018 WL 2297452, at *2 (N.D. Ill. May 30, 2019). But the Court fails to see what specifics Janice could have alleged about warnings that she contends were never given. In other words, whatever warnings MicroPort gave, Janice alleges that they failed to disclose the risk of metallosis associated with metal-on-metal hip implants. See Am. Compl. ¶¶ 46−49. That is specific enough to state a claim that MicroPort’s warnings, to the extent it had a duty

to provide them, were deficient. B. Breach of Implied Warranty of Fitness for a Particular Purpose (Count V)

MicroPort next moves to dismiss Count V on the grounds that Janice fails to allege the existence of an implied warranty of fitness for a particular purpose.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Papasan v. Allain
478 U.S. 265 (Supreme Court, 1986)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Hansen v. Baxter Healthcare Corp.
764 N.E.2d 35 (Illinois Supreme Court, 2002)
Schrager v. North Community Bank
767 N.E.2d 376 (Appellate Court of Illinois, 2002)
Trustees of the Aftra Health Fund v. Biondi
303 F.3d 765 (Seventh Circuit, 2002)
Corwin v. Connecticut Valley Arms, Inc.
74 F. Supp. 3d 883 (N.D. Illinois, 2014)
Lavalais v. Village of Melrose Park
734 F.3d 629 (Seventh Circuit, 2013)
Rosenstern v. Allergan, Inc.
987 F. Supp. 2d 795 (N.D. Illinois, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
McAuliffe v. Microport Orthopedics, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcauliffe-v-microport-orthopedics-inc-ilnd-2021.