Price v. Stryker Corporation
270 F. Supp. 3d 226
| D.D.C. | 2017Background
- On July 17, 2014 Imelda Price, an OR nurse at Washington Hospital Center, adjusted a monitor on a Stryker Standard Video Cart; the monitor and/or armature detached, struck and injured her.
- Plaintiffs sued Stryker Corporation and related entities in D.C. Superior Court alleging negligence, strict products liability, breach of implied warranty, and loss of consortium; case was removed to federal court.
- Plaintiffs allege the Cart lacked a locking mechanism, that Stryker failed to warn and failed to properly service/maintain the Cart.
- Defendants moved under Rule 12(b)(6) to dismiss all claims for failure to state a claim.
- Court dismissed husband Kenneth Price’s loss of consortium claim on choice-of-law grounds (applies Virginia law, which does not recognize the claim).
- Court dismissed Imelda Price’s breach of implied warranty claim as duplicative of her strict liability claim, but denied dismissal as to negligent design and strict liability theories regarding the lack of a locking mechanism.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Choice of law for loss of consortium | D.C. law should apply because D.C. has strong interest and recognizes the claim | Virginia law should apply because plaintiffs are domiciled in Virginia and Virginia does not recognize spouse’s loss of consortium | Virginia law governs; loss of consortium claim dismissed (Virginia does not recognize the claim) |
| Breach of implied warranty vs. strict liability | Warranty claim valid and should survive; plaintiff asserted privity via hospital contract | Warranty claim is duplicative of strict liability where no privity alleged; should be dismissed | Breach of implied warranty dismissed as duplicative of strict liability (no privity alleged in complaint) |
| Sufficiency of design-defect pleading | Alleged absence of locking mechanism is a feasible, safer design and caused injury | Complaint fails to identify precise defective component/location or causal mechanism; therefore insufficient | Design-defect allegations (lack of locking mechanism causing detachment) are sufficient at pleadings stage; negligent design and strict liability claims survive |
| Causation for design-defect theories | Alleged that absence of locking mechanism caused monitor/armature detachment and injury | Plaintiff cannot specify exactly how injury occurred, so causation is speculative | Allegations adequately link defect to injury; causation element pleaded sufficiently |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility pleading standard for federal complaints)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (complaint must plead facts plausibly suggesting entitlement to relief)
- Cardenas v. Muangman, 998 A.2d 303 (D.C. 2010) (choice-of-law: domicile state law governs spouse’s loss of consortium claim)
- Warner Fruehauf Trailer Co. v. Boston, 654 A.2d 1272 (D.C. 1995) (elements and tests for products strict liability and product defect types)
- Westinghouse Elec. Corp. v. Nutt, 407 A.2d 606 (D.C. 1979) (manufacturer’s duty to design reasonably safe product; standard for negligent design)
- Hull v. Eaton Corp., 825 F.2d 448 (D.C. Cir. 1987) (need to consider risks, costs, benefits, and alternative designs to show product unreasonably dangerous)