Hansen v. Baxter Healthcare Corp.
Illinois Supreme Court
764 N.E.2d 35 (2002)
- Written by Mary Phelan D'Isa, JD
Facts
Baxter Healthcare, Corp. (Baxter) (defendant), manufactured and distributed intravenous (IV) tubing sets. Baxter offered two different types of connectors for its sets: friction-fit and Luber-lock. The Luber-lock connectors had a threaded collar to secure the tubing to the catheter to overcome an inadvertent disconnection problem with the friction-fit connectors when they were used in central lines. Baxter and its employees knew that Luber-lock connectors should be used in central lines but did not warn or share that information with the medical community. Andrina Hansen (plaintiff) died after successful stomach surgery when her friction-fit catheter in her central line came apart, causing her to suffer a seizure and an air embolism. Andrina’s estate sued Baxter for products liability. The jury returned a general verdict for the estate. Baxter appealed and argued: (1) the consumer-expectation test for finding a defective design should have been based on the expectations of Hansen’s doctors and not Hansen; and (2) the jury’s verdict could not be supported under the risk-utility test for design defect.
Rule of Law
Issue
Holding and Reasoning (Kilbride, J.)
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