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Doe v. Miles Laboratories, Inc.

United States District Court for the District of Maryland
675 F. Supp. 1466 (1987)

Written by David Bloom, JD

Facts

Jane Doe (plaintiff) developed vaginal bleeding after giving birth. Doe went to the emergency room, where she was given a blood-transfusion product made by Miles Laboratories, Inc. (Miles) (defendant). Doe contracted an undetectable AIDS-related disease from the blood-transfusion product. Doe sued Miles for damages, alleging various theories of liability, including strict products liability in tort. Miles moved for summary judgment, seeking dismissal of the strict-products-liability claim as a matter of law on the grounds that strict products liability was inapplicable to blood or blood-related products.

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Summary JudgmentA final ruling that there is no genuine issue of material fact in dispute and that the moving party is entitled to judgment as a matter of law. Summary judgment may also be called summary disposition.
Loss of ConsortiumA personal injury claim for the deprivation of benefits such as affection, companionship, and assistance that one family member is entitled to receive from another.
Punitive DamagesDamages awarded to the plaintiff over and above just compensation in order to punish the defendant and serve as a deterrent.
Strict LiabilityImposition of liability upon a defendant regardless of the defendant’s conduct or fault. Under strict liability in the tort context, an actor is liable regardless of whether the actor was negligent or otherwise culpable. Strict liability in the tort context is imposed only in limited circumstances; it may be applied in cases involving abnormally dangerous activities, injuries caused by animals, and products liability. In criminal law, strict liability imposes criminal liability with no proof of fault. Strict liability may extend to all elements of a crime or only to some elements. In many jurisdictions, strict liability is also known as absolute liability.
NegligenceConduct that falls below the expected standard of care that a reasonably prudent person would have exercised under like circumstances.
Strict Products LiabilityProvides that a manufacturer or distributor is liable if its product is defective, the defect existed when the product left its hands, and the defect caused injury to an end user that was reasonably foreseeable.
Products LiabilityAn area of law in which manufacturers, distributors, suppliers, retailers, and others who make products available to the public are held liable for injuries caused by those products under theories of negligent design, manufacture, or failure to provide adequate warnings.
Breach of WarrantyA breach of a promise made by a seller of property or other goods, if the purchaser has relied upon the promise and the truth of the statement is necessary to the validity of the contract.