Steele v. Collagen Corp.

54 Cal. App. 4th 1474, 63 Cal. Rptr. 2d 879, 97 Cal. Daily Op. Serv. 3683, 97 Daily Journal DAR 6255, 1997 Cal. App. LEXIS 383
CourtCalifornia Court of Appeal
DecidedMay 15, 1997
DocketC021697
StatusPublished
Cited by24 cases

This text of 54 Cal. App. 4th 1474 (Steele v. Collagen Corp.) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Steele v. Collagen Corp., 54 Cal. App. 4th 1474, 63 Cal. Rptr. 2d 879, 97 Cal. Daily Op. Serv. 3683, 97 Daily Journal DAR 6255, 1997 Cal. App. LEXIS 383 (Cal. Ct. App. 1997).

Opinions

Opinion

NICHOLSON, J.

Federal preemption is a relatively simple concept, especially when Congress has explicitly provided the terms of preemption. (See Brown v. Hotel Employees (1984) 468 U.S. 491, 500-501 [104 S.Ct. 3179, 3184-3185, 82 L.Ed.2d 373, 382-383].) It provides order. Instead of having 50 or more standards with respect to a given human pursuit, there is one. When a preemptive federal standard is applied evenhandedly, it provides both the protection of the federal standard and some leeway to develop further state standards where the federal standard does not apply. With respect to medical devices that represent the highest risk to human life, the federal government imposes standards specific to each of those devices, and Congress has declared that the federal standard is preemptive.

Plaintiff Patricia Steele sued defendant Collagen Corporation, the maker of Zyderm Collagen Implants, because she developed an autoimmune disorder after receiving a test injection of Zyderm. The trial court concluded that all of her causes of action were preempted and granted Collagen Corporation’s motion for summary judgment. We reverse and remand because, even though there is an applicable federal regulatory standard of care for the design, manufacture, and marketing of Zyderm, it is unclear whether Steele asserts Collagen Corporation violated the federal regulatory standard of care or it violated a preempted state common law tort standard of care.

Procedure

Steele sued Collagen Corporation alleging causes of action for strict liability, negligence, breach of implied warranty, breach of express warranty, fraud, and negligent misrepresentation against Collagen Corporation. She later amended her complaint adding a cause of action alleging unfair trade practices. The basis of her complaint is that Zyderm caused her to suffer from an autoimmune disorder.

Collagen Corporation moved for summary judgment. It asserted Steele’s causes of action are preempted by the Medical Device Amendments (MDA) to the federal Food, Drug, and Cosmetic Act because Zyderm was approved by the Food and Drug Administration (FDA). (See 21 U.S.C. §§ 360c, 360k.) In its separate statement of undisputed facts, Collagen Corporation claimed it had submitted Zyderm to the FDA for premarket approval and [1478]*1478that the FDA had given its approval, certifying that Zyderm “had been shown to be safe and effective for use as recommended in the submitted labeling.” Collagen Corporation, however, did not claim as an undisputed fact that it had conformed to all of the requirements arising from the FDA approval. The trial court agreed that Steele’s causes of action were preempted. It granted the motion for summary judgment and entered judgment in favor of Collagen Corporation.

Steele appeals.

Discussion

I

The Medical Device Amendments

In 1976, Congress enacted the MDA, which provided for the classification and regulation of devices intended for human use. (21 U.S.C. § 360c.) The most stringent controls apply to devices placed in class III under the MDA. “Before a new Class III device may be introduced to the market, the manufacturer must provide the FDA with a ‘reasonable assurance’ that the device is both safe and effective. See 21 U.S.C. § 360e(d)(2). Despite its relatively innocuous phrasing, the process of establishing this ‘reasonable assurance,’ which is known as the ‘premarket approval,’ or ‘PMA’ process, is a rigorous one. Manufacturers must submit detailed information regarding the safety and efficacy of their devices, which the FDA then reviews, spending an average of 1,200 hours on each submission. . . . [Citations.]” (Medtronic, Inc. v. Lohr (1996) 518 U.S. _ [116 S.Ct. 2240, 2246-2247,135 L.Ed.2d 700, 710-711] (hereafter Medtronic).)

“Once the product receives PMA [premarket approval], the sponsor of the product may begin to market the product. Any subsequent changes in the product require submission of a PMA supplement application. (21 C.F.R. § 814.39 (1995).) Furthermore, to ensure continued validity of the PMA, the product sponsor is required to submit postapproval reports at one-year intervals, identifying any changes in the device or any reports from clinical investigation or scientific literature concerning the device. (21 U.S.C. § 360i; 21 C.F.R. § 814.84 (1995).)” (Scott v. CIBA Vision Corp. (1995) 38 Cal.App.4th 307, 315 [44 Cal.Rptr.2d 902].)

“Not all, nor even most, Class III devices on the market today have received premarket approval because of two important exceptions to the PMA requirement. First, Congress realized that existing medical devices [1479]*1479could not be withdrawn from the market while the FDA completed its PMA analysis for those devices. The statute therefore includes a ‘grandfathering’ provision which allows pre-1976 devices to remain on the market without FDA approval until such time as the FDA initiates and completes the requisite PMA. See 21 U.S.C. § 360e(b)(1)(A); 21 CFR § 814.1(c)(1). Second, to prevent manufacturers of grandfathered devices from monopolizing the market while new devices clear the PMA hurdle, and to ensure that improvements to existing devices can be rapidly introduced into the market, the Act also permits devices that are ‘substantially equivalent’ to preexisting devices to avoid the PMA process.” (Medtronic, supra, 518 U.S. at p. _ [116 S.Ct. at p. 2247, 135 L.Ed.2d at p. 711], fn. omitted.)

Zyderm is a class III device that received FDA premarket approval in 1981. In 1991, at the behest of Congressman John D. Dingell, the FDA reconsidered its 1981 approval of Zyderm. Congressman Dingell expressed concern that Zyderm caused adverse reactions in the immune system. After reconsidering Collagen Corporation’s application, the FDA determined the market approval for Zyderm was appropriate.

II

Federal Preemption

Federal preemption is grounded in the supremacy clause of the United States Constitution and provides that a state law is preempted if Congress so intends. (Cipollone v. Liggett Group, Inc. (1992) 505 U.S. 504, 516 [112 S.Ct. 2608, 2617, 120 L.Ed.2d 407, 422].) Congress may make its intention explicit by including preemptive language in a law or it may imply preemption by the law’s structure and purpose. (Id. at pp. 516-517 [112 S.Ct. at pp. 2617-2618, 120 L.Ed.2d at pp. 422-423].) Any state law that conflicts with a federal law is preempted.

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Steele v. Collagen Corp.
54 Cal. App. 4th 1474 (California Court of Appeal, 1997)

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54 Cal. App. 4th 1474, 63 Cal. Rptr. 2d 879, 97 Cal. Daily Op. Serv. 3683, 97 Daily Journal DAR 6255, 1997 Cal. App. LEXIS 383, Counsel Stack Legal Research, https://law.counselstack.com/opinion/steele-v-collagen-corp-calctapp-1997.