MSP Recovery Claims, Series LLC v. Fresenius Medical Care Holdings, Inc.

131 F.4th 51
CourtCourt of Appeals for the First Circuit
DecidedMarch 17, 2025
Docket23-1820
StatusPublished
Cited by1 cases

This text of 131 F.4th 51 (MSP Recovery Claims, Series LLC v. Fresenius Medical Care Holdings, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the First Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
MSP Recovery Claims, Series LLC v. Fresenius Medical Care Holdings, Inc., 131 F.4th 51 (1st Cir. 2025).

Opinion

United States Court of Appeals For the First Circuit

No. 23-1820

MSP RECOVERY CLAIMS, SERIES LLC; MSPA CLAIMS 1 LLC; SERIES PMPI,

Plaintiffs, Appellants,

v.

FRESENIUS MEDICAL CARE HOLDINGS, INC.; FRESENIUS USA, INC.; FRESENIUS USA MANUFACTURING, INC.; FRESENIUS USA MARKETING, INC.; FRESENIUS USA SALES, INC.,

Defendants, Appellees.

APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS

[Hon. Nathaniel M. Gorton, U.S. District Judge]

Before

Montecalvo, Lynch, and Kayatta, Circuit Judges.

Janpaul Portal, with whom Aida M. Landa, John W. Cleary, and MSP Recovery Law Firm were on brief, for appellants. James F. Bennett, with whom Megan S. Heinsz, Hannah F. Preston, Dowd Bennett LLP, Maria R. Durant, and Hogan Lovells US LLP were on brief, for appellees.

March 17, 2025 KAYATTA, Circuit Judge. Plaintiffs MSP Recovery Claims,

Series LLC; MSPA Claims 1, LLC; and Series PMPI (collectively

"MSP") filed the present suit in September 2018, six years after

their claims first accrued in 2012. In the normal course, this

delay would have rendered the suit untimely under all relevant

statutes of limitations. MSP contends, however, that an

earlier-filed putative class action tolled the statutes of

limitations from 2013 through 2019 under the rule of American Pipe

& Construction Co. v. Utah, 414 U.S. 538 (1974). The district

court disagreed. For the following reasons, so do we.

I.

A.

Defendants Fresenius Medical Care Holdings, Fresenius

USA, Fresenius USA Manufacturing, and Fresenius USA Marketing1

(collectively "Fresenius") manufacture and distribute GranuFlo, an

acid concentrate used in hemodialysis treatments. On March 29,

2012, Fresenius issued a public memorandum explaining that

GranuFlo could lead to cardiopulmonary arrest in certain patients

and advising doctors to "exercise their best clinical judgment"

when prescribing and administering treatments.

This announcement triggered a stream of wrongful death

and personal injury lawsuits against Fresenius, including, as

1 Defendant Fresenius USA Sales dissolved in 2010 and is no longer a legal entity.

- 2 - relevant here, a putative class action filed on March 21, 2013, in

the Eastern District of Louisiana (the "Berzas action"). See Class

Action Compl., Berzas v. Fresenius Med. Care Holdings, Inc.,

No. 13-cv-00529 (E.D. La. Mar. 21, 2023). The Berzas action was

a "product liability action to recover damages for injuries

sustained . . . as the direct and proximate result of the wrongful

conduct of the Defendants in connection with the designing,

developing, manufacturing, distributing, labeling, advertising,

marketing, promoting, and selling of" GranuFlo and NaturaLyte (a

related product). Id. at 2. The nine named plaintiffs sought

damages for themselves and declared a desire to represent a class

of

[a]ll consumers and third-party payors in the United States and its territories who, for purposes other than resale, purchased, reimbursed and/or paid for NATURALYTE and/or GRANUFLO from May 1, 2003 to present. For purposes of the Class definition, individuals and entities "purchased" NATURALYTE and/or GRANUFLO if they paid some or the entire purchase price.

Id. at 46. They alleged that GranuFlo and NaturaLyte were

defective and that Fresenius had engaged in deceptive and unfair

trade practices in marketing and distributing the products. Id.

at 49–57.

The Berzas action was transferred to the District of

Massachusetts as part of the consolidated multidistrict litigation

("MDL") of all GranuFlo claims. On February 13, 2014, the parties

- 3 - entered into a revised case management order. Pursuant to that

order, each Berzas plaintiff agreed to adopt the pleadings

contained in a "Master Complaint" that "set forth the claims that

individual Plaintiffs and/or the estates and/or heirs of deceased

persons may assert against Defendants in this litigation." Each

plaintiff further agreed to adopt and submit a "Short Form

Complaint" that would incorporate the Master Complaint and

"replace" that party's original complaint.

On March 18, 2014, five of the nine named Berzas

plaintiffs filed Short Form Complaints on behalf of themselves and

their deceased next of kin. Each of those five Short Form

Complaints included a section specifying on whose behalf the claims

were being brought and a checklist of the counts articulated in

the Master Complaint that the specific action incorporated.

Without fail, each of the complaints identified only the named

plaintiff and/or that plaintiff's next of kin as the represented

parties. The other four named plaintiffs filed stipulations of

dismissal on June 27, 2014.

To recap, in June of 2014 the court record as to the

Berzas action was clear: The Berzas plaintiffs no longer had

before the court any request to pursue claims on behalf of any

class. That apparent clarity, though, only lasted seven months.

In January of 2015, the court stated that the 2014 adoption of the

Master Complaint and the filing of the Short Form Complaint did

- 4 - not "necessarily supersede[]" a plaintiff's original complaint

"for purposes of motion to dismiss practice." The court noted

that an amended complaint, once filed, typically replaces the

complaint that came before. However, it suggested that the normal

rule might not apply to the MDL context, where the Master Complaint

served as a mere "administrative device."

Statements by counsel for both sides created further

confusion. At a March 2, 2015 conference with the court, which

the Berzas plaintiffs' counsel did not attend, the district court

mentioned to MDL plaintiffs' counsel and defense counsel that the

Judicial Panel on Multidistrict Litigation statistics showed no

remaining GranuFlo class actions pending. Defense counsel replied

that there were three such actions that he knew of off the top of

his head, including Berzas. When asked why the class actions

were still "hanging out there," defense counsel stated, "In all

candor, I don't remember the specifics of Berzas. . . . I can

certainly do some digging on those cases and get back to you about

it." In light of that response, the court stated that it might

revisit the issue and that it planned to "contact the Clerk at the

Panel and say, 'We have got three class actions in this MDL.'"

In the next status conference on April 10, 2015, MDL

plaintiffs' counsel said to the court that Berzas was a still-

pending class action. He added that leadership counsel was

nevertheless "not planning on moving for certification," and that

- 5 - "these cases were filed, for the most part, with respect to the

issue of equitable tolling for the purposes of the limitations

period, and for now our preference is to just leave them as they

are." The court asked if any of the cases had "tried to fit

themselves into a Short Form?" Defense counsel responded that

"there are Short Forms that have been filed on behalf of the

individual[]named plaintiffs in every case except the Rodriguez

case," and that "[i]n all of the other cases," a group that

included Berzas, "Short Form Complaints have been filed, but the

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

Related

Cite This Page — Counsel Stack

Bluebook (online)
131 F.4th 51, Counsel Stack Legal Research, https://law.counselstack.com/opinion/msp-recovery-claims-series-llc-v-fresenius-medical-care-holdings-inc-ca1-2025.