Trejo v. Johnson

220 Cal. Rptr. 3d 127, 13 Cal. App. 5th 110, 2017 Cal. App. LEXIS 596
CourtCalifornia Court of Appeal, 5th District
DecidedJune 30, 2017
DocketB238339
StatusPublished
Cited by39 cases

This text of 220 Cal. Rptr. 3d 127 (Trejo v. Johnson) is published on Counsel Stack Legal Research, covering California Court of Appeal, 5th District primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Trejo v. Johnson, 220 Cal. Rptr. 3d 127, 13 Cal. App. 5th 110, 2017 Cal. App. LEXIS 596 (Cal. Ct. App. 2017).

Opinion

WILLHITE, J.

*116After taking Motrin, an over-the-counter ibuprofen medication manufactured and sold by McNeil Consumer Healthcare (McNeil), plaintiff Christopher Trejo suffered a reaction in the form of a rare skin disease, Stevens-Johnson Syndrome, and the more severe variant, Toxic Epidermal Necrolysis (collectively SJS/TEN).1 He sued McNeil and its corporate parent, Johnson & Johnson, on various theories of products liability, four *117of which went to trial: strict liability failure to warn and negligent failure to warn, based on defendants' failure to include the symptoms of SJS/TEN (skin reddening, rash, and blisters) on Motrin's warning label, and strict liability design defect and negligent design defect, based on McNeil's failure to sell an allegedly safer product, dexibuprofen (an isomer or component of ibuprofen ) rather than ibuoprofen.

Returning a special verdict, the jury found McNeil liable for negligent failure to warn (but not for strict liability failure to warn), negligent design defect, and strict liability design defect under the consumer *134expectation test (but not under the risk-benefit test). The jury found Johnson & Johnson liable for strict liability design defect on a consumer expectation theory (but not on a risk-benefit theory), and not liable on plaintiff's other claims.

In this appeal by defendants, we hold that the jury's verdict finding McNeil liable for negligent failure to warn must be reversed because it is fatally inconsistent with the verdict finding McNeil not liable for strict liability failure to warn. Accordingly, we reverse the negligent failure to warn verdict, and remand for a new trial on the claims against McNeil for negligent and strict liability failure to warn. We also conclude that the negligent failure to warn special verdict was defective on a second ground: the failure to include the necessary question whether a reasonable manufacturer under the same or similar circumstances would have warned of the danger (an issue we consider because there might be a retrial).

Further, we hold that the verdicts against McNeil for negligent and strict liability design defect, as well as against Johnson & Johnson for strict liability design defect, must be reversed, because the design defect claims were based on a theory-failure to sell dexibuprofen-that is impliedly preempted by the United States Supreme Court's decision in Mutual Pharmaceutical Co., Inc. v. Bartlett (2013) --- U.S. ----, 133 S.Ct. 2466, 2473, 186 L.Ed.2d 607 ( Bartlett ). We also conclude that the strict liability design defect verdicts must be reversed on a second ground: the jury found McNeil and Johnson and Johnson liable solely under the consumer expectation test, but that test does not apply when, as here, the question of design defect involves complex questions of feasibility, practicality, risk, and benefit beyond the common knowledge of jurors. Accordingly, we reverse the verdicts finding McNeil liable for negligent and strict liability design defect, and finding Johnson and Johnson liable for strict liability design defect. Because plaintiff's negligent and strict liability design defect claims are preempted, and because the only theory of strict liability design defect found by the jury (the consumer expectation test) does not apply, none of plaintiff's design defect claims can be retried.

*118Therefore, the ultimate disposition is that the judgment as to McNeil and Johnson and Johnson is reversed, and the case is remanded for retrial on the sole remaining claims in the case: those against McNeil for negligent and strict liability failure to warn.

FACTUAL AND PROCEDURAL BACKGROUND

I. Factual Background

A. Ibuprofen

Ibuprofen is a non-steroidal anti-inflammatory drug (NSAID). It was approved by the Food and Drug Administration (FDA or agency) for prescription use in the United States to treat arthritis and pain in 1974, and for over-the-counter (OTC) use in 1984. Both prescription and OTC ibuprofen are composed of the same ingredient, differing only in the dosage amounts. In 2006, the FDA estimated that approximately 29 million prescriptions for ibuprofen were dispensed per year, and that OTC ibuprofen had approximately 100 million users per year.

There are many different OTC ibuprofen products, both generic and brand name, sold by various companies. They all have the same labeling, regardless of the manufacturer. Motrin is a brand name ibuprofen product. McNeil acquired the right to produce Motrin from the Upjohn Manufacturing Company before the events giving rise to this action. In 1994, the FDA

*135approved McNeil's application for OTC ibuprofen gelcaps, concluding "the drug is safe and effective for use as recommended in the submitted labeling."

Regarding the risk of SJS and TEN from taking ibuprofen, in 1989, the FDA provided McNeil with a medical officer review informing the company that, in 1982, 10 billion doses of ibuprofen were used worldwide, and that SJS was an adverse reaction reported with ibuprofen products at a rate of less than one percent. The labeling approved by the FDA in the 1980's for prescription ibuprofen contained a reference to SJS and TEN as possible adverse events. However, the FDA-approved label for OTC ibuprofen did not refer to SJS, TEN, skin reddening, rash or blisters. The labels differed because prescription labeling is intended for use by physicians, while OTC labeling is aimed at consumers.

The warning label on the bottle of OTC Motrin plaintiff took in October 2005 included the following FDA-approved warnings and instructions:

"Warnings *119"Allergy alert : Ibuprofen may cause a severe allergic reaction which may include:
"• hives • facial swelling • asthma (wheezing) • shock ...
"Do not use if you have ever had an allergic reaction to any other pain reliever/fever reducer....
"Stop use and ask a doctor if
"• an allergic reaction occurs. Seek medical help right away.
"• pain gets worse or lasts more than 10 days
"• fever gets worse or lasts more than 3 days
"• stomach pain or upset gets worse or lasts
"• redness or swelling is present in the painful area
"• any new symptoms appear"

The label did not include specific warnings about skin reddening, rash, and blisters as possible allergic reactions.

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Bluebook (online)
220 Cal. Rptr. 3d 127, 13 Cal. App. 5th 110, 2017 Cal. App. LEXIS 596, Counsel Stack Legal Research, https://law.counselstack.com/opinion/trejo-v-johnson-calctapp5d-2017.