Reid v. Wright Medical Technology, Inc.

Background

Patricia A. Reid sued Wright Medical Technology, Inc. (WMT) and other defendants over artificial hip components implanted during her December 2012 right-hip replacement. The components included a metal femoral head, a cobalt-chromium neck, and a femoral stem produced by WMT. Reid alleged that she expected the components to last at least 20 years without revision or replacement.

In 2015, Reid sought treatment for right-hip pain. Her doctor identified an adverse local tissue reaction that might have been related to metallosis or corrosion. During revision surgery in May 2016, the doctor replaced WMT’s neck and head components and observed corrosion and particulate wear debris throughout the joint. The Food and Drug Administration later recalled the WMT metal femoral head, identifying defective design as the cause of the recall.

Reid’s amended complaint asserted strict liability, negligence, and breach-of-warranty claims. The parties later stipulated to dismissal of all claims against Wright Medical Group, Inc. and Zimmer Biomet Holdings, Inc., as well as the breach-of-warranty count against the remaining defendants; the court dismissed those claims without prejudice. The motion addressed in this opinion concerned only WMT and only the manufacturing-defect theory in Count I.

Motion and Legal Standard

WMT moved under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal for failure to state a legally sufficient claim. WMT argued that Reid had not alleged a specific deviation from the components’ design specifications during manufacturing and had instead described only a design defect or an injury.

Because the case was in federal court based on diversity jurisdiction, the court applied Minnesota substantive law. Under that law, a strict-liability plaintiff must show that the product was defective and unreasonably dangerous for its intended use, that the defect existed when the product left the defendant’s control, and that the defect proximately caused the injury.

The court explained that a manufacturing defect involves a flaw or deviation from a product’s intended design, while a design defect involves an allegedly unsafe design chosen by the manufacturer. A plaintiff must allege that the product deviated from its design or from other flawless products because of a manufacturing defect, but need not plead the manufacturing process with heightened detail beyond the ordinary pleading requirements.

Analysis

The court concluded that Reid’s allegations were sufficient. She alleged that the components failed after about three years, that doctors observed corrosion and wear debris, and that the components did not perform as she expected them to. The court said these allegations showed what failed, how it failed, and how the failure differed from the components’ expected performance.

The court rejected WMT’s argument that an injury alone could not support a manufacturing-defect claim. It agreed that the mere fact of an injury during product use usually is insufficient, but found that Reid alleged more than an injury: she alleged an independent failure of the artificial hip components. Those allegations plausibly supported an inference that the failure was attributable, at least in part, to a manufacturing defect.

Disposition

The court denied WMT’s Partial Motion to Dismiss. The opinion did not decide whether Reid will ultimately prove a manufacturing defect; it decided only that the claim was adequately pleaded to proceed beyond the motion-to-dismiss stage.