State v. Cardinal Health

CourtVermont Superior Court
DecidedOctober 31, 2024
Docket279-3-19 cncv
StatusPublished

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

Bluebook
State v. Cardinal Health, (Vt. Ct. App. 2024).

Opinion

STATE'O'F VERMONT'

SUPERIOR COURT CIVIL DIVISION Chittenden Unit Docket N0. 279-3-19 Cncv

State of Vermont vs. Cardinal Health, Inc. et a1

ENTRY REGARDING MOTION T0 DISMISS Count 1, Duty to Prevent Misuse, Abuse & Diversion (279—3—19 Cncv) VERMONTSUPERIOR COURT FILED Title: Motion to Dismiss (Motion 4) . V . .

Filer: Defendants MAY 1 2 2020

Attorney: Jonathan A. Lax et al. .

‘ ‘ ’ CHlTTENDEN UN'T _ '

’Fiied Date: June 17, 2019

Opposition filed on 08/01/2019 by Attorney Jill S. Abrams et al. for Plaintiff State of Vermont; Reply filed on 09/16/2019 by Attorney Jonathan A. Lax et al. for Defendants; Defendants’ Supplemental Brief filed 01/14/2020; State’s Supplemental Brief filed 01/29/2020; Defendants’ Supplemental Reply filed 02/05/2020; State's Notice of Supplemental Authority filed 02/21/2020

The State brings this case seeking damages and injunctive relief for defendants’

role in distributing opioids in Vermont. Defendants move to dismiss. Oral argument took

place on the motion in December, and post—trial memoranda were complete in February.

Discussion

The complaint asserts four causes of action: two counts of Consumer Protection

Act violations, negligence, and public nuisance. Defendants Cardinal Health, Inc. and

McKesson Corporation (jointly “Distributors”) are alleged to be two pharmaceutical

wholesalers that distribute opioids in Vermont. Their motion seeks dismissal of all four

counts of the complaint.

Grant of a motion to dismiss for failure to state a claim “is proper only when it is

. beyondndoubt that thereexist no facts or circumstances[] consistent with the complaint that would entitle the plaintiff to relief. . [T]he threshold a plaintiff must cross in order ..

m

to meet—Our notice-pleading Standard is exceedingly low.” Book iii—Geld,— 2008 VT 81, 1T4;

184 Vt. 575 (quotation and citations omitted). Such motions “are disfavored and should

be rarely granted.” IQ. In analyzing the motion, the court must “assume as true all factual

allegations pleaded by the nonmoving party.” Amiot v. Ames, 166 Vt. 288, 291

(1997)(citation omitted). In other words, the question is whether Plaintiff could win at

trial if the allegations were proved.

Negligence The negligence claim is, in sum, that Distributors breached common law and

statutory duties to “prevent the diversion of controlled substances into illegitimate

channels.” Complaint 11 386. They are alleged to have breached these duties by creating

ineffective monitoring systems, failing to implement adequate anti-diversion programs,

failing to report suspicious orders, and failing to prevent shipment of suspicious orders.

E. ‘H 389. This allegedly “fueled the Widespread circulation of opioids into illegitimate

channels in Vermont,” causing or substantially contributing to “the abuse, misuse and

diversion” of opioids, leading to Widespread addiction and increased costs to the State to

address that epidemic. E. 11 390.

The economic loss doctrine bars the State’s claim here. With some exceptions, that

doctrine “prohibits recovery in tort for purely economic losses.” Sutton v. Vermont Reg’l

_C_t1;, 2019 VT 71, ‘H 3o. The State argues that the doctrine applies only when there was a contract between the parties. At least one other court has accepted such an argument in a

similar case. Citv of Boston v. Purdue Pharma LP, No. 1884CV02860, 2020 WL 416406,

at *9 (Mass. Super. Jan. 3, 2020)(rejecting economic loss theory because “the claims are

not contract-related”). The doctrine, however, is not so limited in Vermont. That is clear m ’7.“

from the Court’s recent decision in Sutton. First, the Court quoted an earlier decision for '

the—roposition that—"‘negligenCe law does nOt generally recognize é duty to 'eiercise

reasonable care to avoid intangible economic loss to another unless one’s conduct has

inicted some accompanying physical harm, which does not include economic loss.”

2019 VT 71, 1] 3o (quoting Gus’ Catering Inc. v. Menusoft SVS., 171 Vt. 556, 558

(2000) (mem.)). Next, the Court explained that one of the reasons for the doctrine is the

very fact that economic injuries can be widespread, “causing economic loss to thousands

of people” without a direct connection to the defendant. Su_tto_n, 2019 VT 71, 1] 32 (quoting Restatement (Third) of Torts § 1 cmt. (c)(1))(noting distinction between impact of badly

driven car, causing physical harm only to others nearby, and potential impact of single

negligent utterance, causing economic loss to many people who rely on it). As another

court has explained, the doctrine “bars recovery for economic loss even if the loss does

not arise from a commercial relationship between the parties—even if for example a

negligent accident in the Holland Tunnel backs up trafc for hours, imposing

cumulatively enormous and readily monetizable costs of delay.” Rardin v. T & D Mach.

Handling, Inc., 890 F.2d 24, 28 (7th Cir. 1989). Thus, the Court has rejected the argument

that the doctrine only applies when the parties have a contract. Long Trail House Condo.

Ass’n v. Engelberth Const., Inc., 2012 VT 80, 11‘“ 13-15, 192 Vt. 322 (doctrine does not turn

on “whether the parties had the opportunity to allocate risks”); accord Aetna Inc. v. Insys

Therapeutics, Inc., 324 F. Supp. 3d 541, 556 (E.D. Pa. 2018) under Pennsylvania law,

“contractual privity is not a prerequisite for the application of the doctrine”).

The State argues that its injuries are not economic losses, but “social losses.” Opp.

at 21-22. The court is not persuaded. The court has found no cases creating a special legal

category of “social loss” distinct from physical or economic damages in tort law. The m m quotation the State provides from Dobbs is misleading, as it leaves out a crucial part of ' " the 'sehtehcet the quotatio is 'n'ie'rely a View att'i‘ibut'ed'to Judge Posher,1 not a Statehiér'it'”

of the current state of the law or even Dobbs’ View of what the law should be. The absence

of physical injury here is what matters. The fact that the State’s claimed damages are for

increased health care costs, law enforcement costs, and addiction treatment costs does

not change the analysis. Accord Springeld Hydroelectric Co. v. CODD, 172 Vt. 311, 315

(2001)(“compensation for the damages [Plaintiffs] were forced to pay to third parties,”

were as solely barred economic damages.) There can be exceptions to the economic loss rule when there is a special

relationship between the parties. Sutton, 2019 VT 71, 1] 31. The State argues that it has a

“special relationship” with Distributors justifying an exception here. However, the sorts

of special professional relationships that are considered as exceptions to this rule are not

analogous to the situation here. Such exceptions apply when the defendant is a “provider

of a specialized professional service.” EBWS, LLC v. Britlv Corp., 2007 VT 37, ‘H 32, 181

Vt. 513. Examples are a lawyer-client, investor-recruiter, or doctor-patient relationship.

See Sachs v. Downs Rachlin Martin PLLC. 2017 VT 100 n. 5, 206 Vt. 157; Sutt_on, 2019

VT 71, 1] 33; Walsh v. Cluba, 2015 VT 2, 1] 3o, 198 Vt. 453. The fact that Distributors

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State v. Cardinal Health, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-cardinal-health-vtsuperct-2024.