139 F.4th 656
8th Cir.2025Background
- Julie Sprafka underwent knee replacement surgery in 2016 using DePuy’s ATTUNE system, which later failed due to debonding of the tibial baseplate.
- Sprafka filed a lawsuit against DePuy, asserting strict liability and negligent products liability claims based on design defect and failure to warn.
- She retained Dr. Truman, a biomedical engineer, as an expert on the design defect; her treating physician, Dr. Breien, was disclosed as a non-retained expert.
- DePuy moved to exclude Dr. Truman’s opinions under Rule 702/Daubert and sought summary judgment, arguing expert testimony was essential for Sprafka’s claim.
- The district court excluded Dr. Truman’s expert testimony as unreliable and speculative, and then granted summary judgment for DePuy.
- Sprafka appealed both rulings, claiming Dr. Truman’s exclusion was error and that Dr. Breien’s opinions independently supported her claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Exclusion of Dr. Truman’s Testimony | Truman’s opinions were reliable and admissible. | Truman’s opinions were speculative, unreliable. | Properly excluded under Rule 702. |
| Grant of Summary Judgment | Dr. Breien’s testimony sufficed for design defect. | No admissible expert testimony for claim; Breien not sufficient. | Proper to grant summary judgment; claim unsupported. |
| Sufficiency of Failure to Warn Claim | Implied/argued issue not preserved on appeal. | Failure to warn claim fails with design defect claim. | Waived/forfeited on appeal; not addressed. |
Key Cases Cited
- Bilotta v. Kelley Co., 346 N.W.2d 616 (Minn. 1984) (merging negligence and strict liability in product defect and failure to warn claims under Minnesota law)
- Daubert v. Merrell Dow Pharmaceuticals Inc., 509 U.S. 579 (1993) (establishing the modern framework for admissibility of expert testimony)
- Gen. Elec. Co. v. Joiner, 522 U.S. 136 (1997) (standard of review for exclusion of expert testimony is abuse of discretion)
- Markel v. Douglas Techs. Grp., Inc., 968 F.3d 888 (8th Cir. 2020) (expert testimony is required for complex product liability claims beyond common understanding)