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Riley v. Becton Dickinson Vascular Access, Inc.

United States District Court for the Eastern District of Pennsylvania

913 F.Supp. 879 (1995)

Facts

Lynda Riley (plaintiff) was a nurse. While removing an Angiocath intravenous catheter needle made by Becton Dickinson Vascular Access, Inc. (Beckton) (defendant), the patient moved suddenly, and Riley accidentally stuck herself. The needle infected Riley with the human immunodeficiency virus (HIV). Riley sued, contending that the Angiocath needle was defective because it was unreasonably dangerous. Riley argued that there was an available and feasible alternative with a needle that would be withdrawn into a protective sheath. With the Angiocath, accidental HIV infections are about 3.5 per 500 million uses. Using an alternative would lower that rate to one infection per 500 million uses. The alternative would be 10–36 percent more expensive. Furthermore, the alternative would require additional training and does not work as well as the Angiocath. Beckton moved for summary judgment, arguing that the Angiocath is not unreasonably dangerous.

Rule of Law

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Issue

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Holding and Reasoning (Troutman, J.)

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