Murphy v. Bayer Healthcare Pharmaceuticals, Inc.

CourtDistrict Court, D. Maryland
DecidedApril 1, 2025
Docket8:23-cv-00122
StatusUnknown

This text of Murphy v. Bayer Healthcare Pharmaceuticals, Inc. (Murphy v. Bayer Healthcare Pharmaceuticals, Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Murphy v. Bayer Healthcare Pharmaceuticals, Inc., (D. Md. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

MARIA MURPHY, *

Plaintiff, *

v. * Civ. No. DLB-23-0122

BAYER HEALTHCARE * PHARMACEUTICALS INC., * Defendant.

MEMORANDUM OPINION For seventeen years, Maria Murphy took Betaseron® to treat her relapsing-remitting multiple sclerosis (“MS”). Murphy developed kidney failure and scar tissue on the part of her kidneys that filters blood. A physician determined that this scar tissue was caused by Betaseron®. Murphy sued Bayer Healthcare Pharmaceuticals, Inc. (“Bayer”), the manufacturer of Betaseron®, alleging the company failed to adequately warn her and her health care providers about the risk of kidney malfunction and kidney disease associated with use of the drug. Bayer moved to dismiss Murphy’s complaint for failure to state a claim. Bayer asserted that Murphy’s state law claims should be dismissed on federal preemption grounds. The Court denied the motion. Bayer now moves for reconsideration or, in the alternative, requests that the Court certify for interlocutory appeal its Order denying the motion to dismiss. For the following reasons, the Court denies Bayer’s motion for reconsideration and its request to certify for interlocutory appeal the Order denying the motion to dismiss. I. Background A. Murphy’s Complaint Murphy, an African American woman, was diagnosed with relapsing-remitting MS around 1999.1 ECF 1, ¶¶ 19–20. MS prompts the body’s immune system to attack the nervous system. Id.

¶ 39. On or around April 2002, Murphy was prescribed a drug called Betaseron® to treat her MS. Id. ¶ 21. Betaseron® is an Interferon beta-1b prescription drug that reduces the body’s inflammatory immune response and lessens clinical exacerbations. Id. ¶¶ 38–39. Murphy took Betaseron® almost exclusively from 2002 until 2020. Id. ¶¶ 21, 23–25. She took a different Interferon beta-1b drug between 2015 to 2016 due to a change in her insurance coverage. Id. ¶¶ 24– 25. She self-administered one vial of the drug every other day per the instructions of her physician and the Betaseron® label. Id. ¶ 28. Murphy also adhered to the label’s recommendation to get regular check-ups with her providers and to undergo regular blood tests to monitor her liver function. Id. ¶ 29. Around February 2020, Murphy’s primary care physician, Dr. Sandra Ginsberg, identified

a decline in Murphy’s kidney function and referred her to a specialist, Dr. Stephen Burka. Id. ¶¶ 22, 30. Dr. Burka diagnosed Murphy with stage four renal failure. Id. ¶ 31. A biopsy confirmed that she had focal segmental glomerulosclerosis (“FSGS”)—a disease where scar tissue develops on the kidneys—and irreversible advanced-stage kidney disease. Id. ¶¶ 32–33, 45. Due to the FSGS diagnosis and her worsening kidney function, Dr. Burka recommended that Murphy get an evaluation for a kidney transplant. Id. ¶ 33. Murphy underwent a kidney transplant later that year. Id. ¶ 36. Another specialist, Dr. Reza Zonani, determined the cause of Murphy’s FSGS: the Betaseron®. Id. ¶ 34. Dr. Zonani discontinued Murphy’s use of the drug. Id. ¶ 35.

1 The well-pleaded factual allegations in Murphy’s complaint are accepted as true. Bayer is a Delaware corporation with a principal place of business in New Jersey. Id. ¶ 5. Bayer designs, manufactures, and markets prescription drugs, including Betaseron®. Id. ¶ 16. The company currently holds the Betaseron® New Drug Application (“NDA”), approved by the Food and Drug Administration (“FDA”) in 1993. Id. ¶¶ 14–15. In 2006, the FDA authorized the drug’s

expanded use for Clinical Isolation Syndrome, an onset of neurological symptoms that commonly progress into MS. Id. ¶ 14. In 2019, the FDA approved a subsequent expansion for Betaseron® to treat recurrent MS flare-ups. Id. Today, Betaseron® is used to treat relapsing forms of MS, including relapsing-remitting MS, to limit the frequency of clinical exacerbations. Id. ¶ 38. Since its approval in 1993, the Betaseron® product label has not warned patients in the United States of significant renal disease or dysfunction, Nephrotic Syndrome, or FSGS; nor has it explained that patients who are more susceptible to renal disease, including African American patients, face a higher risk of developing these conditions. Id. ¶¶ 41, 44, 58. The Betaseron® label in the United States also does not caution patients or providers to monitor for the risks of renal dysfunction or disease associated with taking the drug, such as Nephrotic Syndrome or FSGS, and it does not

recommend discontinuing the drug if the patient develops kidney problems. See id. ¶ 44. Murphy alleges that renal failure, Nephrotic Syndrome, and FSGS are known risks associated with Betaseron® and that Bayer knew of these risks. Id. ¶¶ 46, 59. Bayer’s post- marketing surveillance identified the risks of developing Nephrotic Syndrome, including FSGS. Id. ¶ 49. In Canada, the European Union, the United Kingdom, New Zealand, and Australia, the Betaseron® label includes warnings about the risk of developing Nephrotic Syndrome, including FSGS. Id. ¶¶ 47–48, 50–51, 75. For example, the label in the European Union warns that, among other things, “[c]ases of nephrotic syndrome with different underlying nephropathies including collapsing [FSGS] . . . have been reported during treatment with interferon beta products.” Id. ¶ 48. The Betaseron® European Union label also recommends monitoring for early signs and symptoms of Nephrotic Syndrome. Id. Murphy asserts two failure-to-warn claims under state law against Bayer: one for strict liability and one for negligence.2 Id. ¶¶ 66–107. Murphy alleges that Bayer was required to conduct

post-approval surveillance of adverse drug reactions and did not fulfill its obligation to update the Betaseron® label to identify risks, including FSGS and the heightened risk of kidney dysfunction and disease in the African American population. Id. ¶¶ 53–55, 60–61. According to Murphy, Bayer also used direct-to-consumer advertising without warning of these risks. Id. ¶¶ 62–63. She further alleges that health care providers are not warned about the need to monitor patients. Id. ¶¶ 56–57, 60–61. Murphy says that she and her health care providers relied on Bayer’s representations, that she used Betaseron® in a reasonably foreseeable manner, and that she could not have discovered the risk of developing renal disease such as FSGS through the exercise of reasonable care. Id. ¶¶ 79, 82. Murphy alleges that she “has been permanently injured and has incurred pain, suffering,

emotional distress, loss of enjoyment of life, medical expenses, lost wages, and disability, as well as future pain, suffering, emotional distress, loss of enjoyment of life, disability, medical expenses, and diminished earning capacity.” Id. ¶ 37. She seeks damages, attorneys’ fees, and costs. Id. at 21–22. B. Bayer’s Motion to Dismiss and Motion for Reconsideration On September 15, 2023, Bayer moved to dismiss Murphy’s complaint for failure to state a claim. See ECF 42. Bayer argued that Murphy’s state-law claims were preempted by federal law.

2 Murphy also named as a defendant Bayer Pharma AG, a German company with no presence in the United States. The Court dismissed the claims against Bayer Pharma AG for lack of personal jurisdiction on August 14, 2024. See ECF 62. See id.; see also ECF 42-1, at 11–18. Bayer explained that federal law prohibits changes to the Betaseron® label without FDA approval except through the “changes being effected” (“CBE”) regulation. The CBE regulation allows drug manufacturers to unilaterally “add or strengthen a . . . warning” on a drug’s physician label based on “newly acquired information” regarding

“evidence of a causal association” between the drug and a risk of harm. 21 C.F.R. § 314.70(c)(6)(iii).

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