Schnulle v. Somatics, LLC

CourtDistrict Court, E.D. Missouri
DecidedJanuary 21, 2022
Docket4:21-cv-00109
StatusUnknown

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

Bluebook
Schnulle v. Somatics, LLC, (E.D. Mo. 2022).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

JANELLE SCHNULLE, ) ) ) Plaintiff, ) ) v. ) Case No. 4:21-CV-00109 JCH ) SOMATICS, LLC, ) ) Defendant. )

MEMORANDUM AND ORDER This matter is before the Court on Defendant Somatics, LLC’s (“Somatics” or “Defendant”) motion to dismiss portions of Count One, as well as Counts Two through Seven of Plaintiff Janelle Schnulle’s (“Schnulle” or “Plaintiff”), complaint for failure to state a claim, pursuant to Fed. R. Civ. P. 12(b)(6), and to strike immaterial allegations from Plaintiff’s complaint pursuant to Fed. R. Civ. P. 12(f). Doc. [11]. Plaintiff responded to the motion (Doc. [15]), Defendant filed a reply (Doc. [16]), and the matter is fully briefed and ripe for disposition. For the reasons set forth below, Defendant’s motion will be granted in part and denied in part. I. Factual and Procedural Background Taken as true for the purpose of this motion, the facts alleged in the complaint are as follows. From April 10, 2015, through January 29, 2016, Plaintiff underwent 33 sessions of Electroconvulsive Therapy (ECT) using the Thymatron System IV device at Mercy Hospital in St. Louis, Missouri. This ECT device was supplied by Somatics, which, manufactures, promotes, and distributes the device. Plaintiff alleges that undergoing ECT treatment with the device caused permanent neurological damages impairing her ability to learn, retain, and recall information. Plaintiff also alleges that despite knowing of the substantial risks associated with ECT treatment, Somatics manufactured and distributed the device and failed to warn of those risks. Plaintiff filed this seven count complaint on January 27, 2021, alleging: negligence (Count One), strict liability (Count Two), breach of implied warranty of merchantability (Count

Three), breach of implied warranty of fitness for a particular purpose (Count Four), breach of express warranty (Count Five), violation of the Missouri Merchandising Practices Act (“MMPA”) (Count Six), and fraud (Count Seven). II. Legal Standard Defendant has moved to dismiss for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6). The purpose of a Rule 12(b)(6) motion to dismiss is to test the legal sufficiency of a complaint so as to eliminate those actions “which are fatally flawed in their legal premises . . . thereby sparing litigants the burden of unnecessary pretrial and trial activity.” Young v. City of St. Charles, 244 F.3d 623, 627 (8th Cir. 2001) (citing Neitzke v. Williams, 490 U.S. 319, 326-27 (1989)). A pleading is deficient and may be dismissed under Rule 12(b)(6) if a

plaintiff fails “to state a claim upon which relief can be granted.” Fed. R. Civ. P. 12(b)(6). Rule 12(b)(6) is read in conjunction with Rule 8(a), which requires “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). To survive a motion to dismiss for failure to state a claim, a plaintiff’s allegations must contain “sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). Rule 8 “does not require ‘detailed factual allegations,’ but it demands more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Id. (quoting Twombly, 550 U.S. at 555). 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.” Id. (citing Twombly, 550 U.S. at 556). “The plausibility standard is not akin to a ‘probability requirement,’ but it asks for more than a sheer possibility that a defendant has acted unlawfully.”

Id. (quoting Twombly, 550 U.S. at 556). The complaint “must contain either direct or inferential allegations respecting all the material elements necessary to sustain recovery under some viable legal theory,” and “enough fact[s] to raise a reasonable expectation that discovery will reveal evidence of [each element].” Twombly, 550 U.S. at 562. The reviewing court must accept the plaintiff’s factual allegations as true and construe them in the plaintiff’s favor, but it is not required to accept the legal conclusions that plaintiff draws from the facts alleged. Iqbal, 556 U.S. at 678; Retro Television Network, Inc. v. Luken Commc’ns, LLC, 696 F.3d 766, 768-69 (8th Cir. 2012). A court must “draw on its judicial experience and common sense,” and consider the plausibility of the plaintiff’s claim as a whole, not the plausibility of each individual allegation. Zoltek Corp. v. Structural Polymer Grp., 592 F.3d 893, 896 n.4 (8th Cir. 2010) (quoting Iqbal,

556 U.S. at 679). Federal Rule of Civil Procedure 9(b) establishes a heightened pleading standard for complaints alleging fraud. The Eighth Circuit has described Rule 9(b)'s particularity requirement: Rule 9(b)'s particularity requirement demands a higher degree of notice than that required for other claims, and is intended to enable the defendant to respond specifically and quickly to the potentially damaging allegations. To satisfy the particularity requirement of Rule 9(b), the complaint must plead such facts as the time, place, and content of defendant's false representations, as well as the details of the defendant's fraudulent acts, including when the acts occurred, who engaged in them, and what was obtained as a result. Put another way, the complaint must identify the “who, what, where, when and how” of the alleged fraud. United States ex rel. Joshi v. St. Luke's Hosp., Inc., 441 F.3d 552, 556 (8th Cir.2006) (internal citations omitted). A plaintiff must state an underlying basis for its assertions sufficient to provide an indicia of reliability. Id. at 557 (citation omitted). While a plaintiff need not allege specific

details of every alleged fraud, the plaintiff must provide some representative examples of the alleged misconduct. Id. III. Discussion A. Negligence—Count One In Count One of her complaint, Plaintiff asserts negligence by Defendant under various theories of liability. More specifically, Plaintiff alleges that Defendant was negligent by: (a) failing to provide adequate warnings to the medical community and the public about the risks of ECT; (b) failing to adequately research, test, and analyze the safety of the ECT device; (c) failing to adequately investigate the reports of serious adverse events, including but not limited to permanent memory loss, neurocognitive decline, death, burning, and brain injury; (d) failing to

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Schnulle v. Somatics, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/schnulle-v-somatics-llc-moed-2022.