In re TMJ Implants Products Liability Litigation
United States Court of Appeals for the Eighth Circuit
97 F.3d 1050 (1996)
Facts
Patient-recipients of prosthetic jaw implants (plaintiffs) used to correct temporomandibular joint (TMJ) disorders brought products-liability actions against the suppliers of the Teflon materials (defendants) used in the devices, alleging that the implants failed and damaged the surrounding bone where they were implanted and caused pain to the recipients. The implants were designed, tested, manufactured, packaged, and sold by Vitek, Inc., a bankrupt company. Evidence was presented that prior to the manufacture of the device, Vitek was informed that the suppliers’ Teflon products were not made for medical applications, that several scientific reports revealed that pure Teflon caused problems when used in load-bearing joints, and that eight years after the Food and Drug Administration (FDA) approved the devices, they were ordered off the market because they fragmented and irritated human tissue. The district court granted the suppliers’ motion for summary judgment on the design-defect claims, and the patient-recipients appealed. The suppliers argued that because they were component suppliers and there were no allegations that their Teflon was defective, they were entitled to summary judgment, as other courts in TMJ implant cases had already held.
Rule of Law
Issue
Holding and Reasoning (Bowman, J.)
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