Pope v. AstraZeneca AB

CourtSuperior Court of Delaware
DecidedApril 5, 2021
DocketN20C-06-116
StatusPublished

This text of Pope v. AstraZeneca AB (Pope v. AstraZeneca AB) is published on Counsel Stack Legal Research, covering Superior Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pope v. AstraZeneca AB, (Del. Ct. App. 2021).

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

JEFFERY POPE AND CYNTHIA ) POPE, ) ) Plaintiffs, ) ) C.A. No.: N20C-06-116 FAR v. ) ) ASTRAZENECA AB, ) ASTRAZENECA ) PHARMACEUTICALS LP, and ) BRISTOL-MYERS SQUIBB CO. ) ) Defendants. )

MEMORANDUM OPINION Upon Consideration of Defendants’ Motion to Dismiss, GRANTED

Raeann Warner, Esq., Jacobs & Crumplar, P.A., Wilmington, Delaware and Rebecca B. King, Esq., Tracey, Fox, King & Walters (Pro Hac Vice). Attorneys of Plaintiffs.

Michael P. Kelly, Esq., James J. Freebery, Esq., Daniel J. Brown, Esq., and Hayley J. Reese, Esq., McCarter & English, LLP, Wilmington, Delaware and Stephen D. Raber, Esq., Matthew D. Heins, Esq., and Griffin R. Farha, Esq., Williams & Connolly LLP (Pro Hac Vice). Attorneys for Defendants.

Rennie, J. I. INTRODUCTION

Plaintiffs, Jeffery Pope and Cynthia Pope (“Plaintiffs”), bring this suit

against Defendants, AstraZeneca AB, AstraZeneca Pharmaceuticals LP, and

Bristol-Myers Squibb Co. (“Defendants”), to recover for medical injuries that were

allegedly caused by Defendants’ medication, Farxiga. Defendants filed this

Motion to Dismiss pursuant to Superior Court Rule 12(b)(6). For the reasons that

follow, Defendants’ Motion to Dismiss is GRANTED.

II. STATEMENT OF THE CASE

A. Factual Background

Plaintiff, Jeffery Pope (“Pope”) began taking Farxiga in January 2016.

Pope’s healthcare provider prescribed Farxiga to treat his Type 2 diabetes as well

as to aid in weight loss.1 On June 11, 2018, Pope was diagnosed with Fournier’s

gangrene.2 As a result, he underwent emergency surgery and additional life-saving

procedures. Pope was hospitalized for approximately ten days.

Farxiga is a prescription drug approved by the Food and Drug

Administration (“FDA”) for the treatment of Type 2 diabetes. Farxiga does not

have FDA approval for weight loss.

1 See Plaintiffs’ Answering Brief in Opposition to Defendants’ Motion to Dismiss at 1 [hereinafter “Pl.s’ Resp.”]; see also Compl. ¶¶ 44–45. 2 See Pl.s’ Resp. at 1 (“Fournier’s gangrene, also known as necrotizing fasciitis of the perineum, is a deadly flesh-eating infection of the genitals and area around the genitals.”). 2 B. Procedural Background

On June 10, 2020, Plaintiffs filed a Complaint against Defendants for

injuries allegedly caused by Pope’s use of Farxiga. 3 On August 12, 2020,

Defendants filed their Motion to Dismiss Pursuant to Superior Court Civil Rule

12(b)(6).4 On October 8, 2020, Plaintiffs filed their Answering Brief in

Opposition. On October 23, 2020, Defendants filed their Reply. This Court heard

oral argument on December 3, 2020.

III. STANDARD OF REVIEW

In considering, a motion to dismiss for failure to state a claim under Superior

Court Civil Rule 12(b)(6), 5 all well-pleaded allegations in the complaint must be

accepted as true.6 Even vague allegations are considered well-pleaded if they give

the opposing party notice of a claim.7 The Court must draw all reasonable

inferences in favor of the non-moving party;8 however, it will not “accept

conclusory allegations unsupported by specific facts,” nor will it “draw

3 In their Complaint, Plaintiffs assert eight counts against Defendants: Negligence (Count One); Breach of Implied Warranty of Merchantability (Count Two); Breach of Implied Warranty of Fitness for a Particular Purpose (Count Three); Breach of Express Warranty (Count Four); Strict Product Liability – Failure to Warn (Count Five); Strict Product Liability – Defective Design (Count Six); Punitive Damages (Count Seven); and Loss of Consortium as to Cynthia Pope (Count Eight). 4 See Defendants’ Motion to Dismiss; see also Defendants’ Opening Brief in Support of its Motion to Dismiss [hereinafter “Def.s’ Mot.”]. 5 Super. Ct. Civ. R. 12(b)(6). 6 Spence v. Funk, 396 A.2d 967, 968 (Del. 1978). 7 In re Gen. Motors (Hughes) S’holder Litig., 897 A.2d 162, 168 (Del. 2006) (quoting Savor, Inc. v. FMR Corp., 812 A.2d 894, 896–97 (Del. 2002)). 8 In re Gen. Motors (Hughes) S’holder Litig., 897 A.2d at 168. 3 unreasonable inferences in favor of the non-moving party.”9 Dismissal under Rule

12(b)(6) must be denied if the plaintiff could recover under “any reasonably

conceivable set of circumstances susceptible of proof under the complaint.”10

IV. CONTENTIONS OF PARTIES

Defendants assert that Plaintiffs’ pleadings fail to state a claim upon which

relief can be granted for the following reasons: (1) Farxiga’s FDA-approved

warnings were adequate as a matter of law under Section 82.007; 11 and (2) Farxiga

is not unreasonably dangerous, and a safer-alternative requirement is preempted.

On these bases, Defendants argue that Plaintiffs’ derivative claims, which are

inextricably intertwined with Plaintiffs’ failure to warn and design defect claims,

also fail. In response, Plaintiffs argue that each claim is adequately pled with

sufficient facts for support.

V. DISCUSSION

In assessing Defendants’ Motion to Dismiss, the Court applies Texas law to

the substantive issues. In doing so, the Court finds that: (1) Plaintiffs’ Failure to

Warn claims fail under Section 82.007; (2) Plaintiffs cannot satisfy the elements to

establish a Design Defect claim; and (3) Plaintiffs’ Negligence claims are

derivative or are not properly pled.

9 Price v. E.I. DuPont de Nemours & Co., 26 A.3d 162, 166 (Del. 2011) (internal citation omitted). 10 Spence, 396 A.2d at 968 (citing Klein v. Sunbeam Corp., 94 A.2d 385, 391 (Del. 1952)). 11 See Tex. Civ. Prac. & Rem. Code § 82.007. 4 A. Plaintiffs’ Failure to Warn Claims Fail Under Section 82.007

Texas Civil Practice and Remedies Code Section 82.007 (“Section 82.007”)

establishes a rebuttable presumption that pharmaceutical companies are not liable

in failure-to-warn cases where the FDA approved the warnings accompanying the

product. 12 Here, the warnings and information that accompanied Farxiga’s

distribution, were approved by the FDA “for a product approved under the Federal

Food, Drug, and Cosmetic Act.”13 Plaintiffs do not dispute that Farxiga is FDA

approved for the treatment of Type 2 diabetes. Hence, Farxiga’s “FDA-approved

warning label is presumed to be an adequate warning” as it pertains to such

treatment, and there exists a presumption of non-liability under Section 82.007.14

A plaintiff may rebut that presumption by showing one of the following: (1)

“fraud on the FDA[;]” (2) that the product was sold after the FDA ordered that it

be removed from the market; (3) that the manufacturer promoted the product for a

use not approved by the FDA; (4) that there existed an off-label prescription; or (5)

12 See Tex. Civ. Prac. & Rem. Code § 82.007(a)(1); see also Lofton v. McNeil Consumer & Specialty Pharm., 672 F.3d 372, 374 (5th Cir.

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