Judge: Michael Shultz, Case: 22STCV12268, Date: 2022-09-13 Tentative Ruling

Case Number: 22STCV12268    Hearing Date: September 13, 2022    Dept: A

22STCV12268 Alberto Siordia v. Zoll Medical Corporation

Tuesday, September 13, 2022 at 8:30 a.m.

 

[TENTATIVE] ORDER SUSTAINING DEMURRER TO PLAINTIFF’S COMPLAINT

 

I.            BACKGROUND

The complaint, filed on April 12, 2022, alleges claims for general negligence and products liability arising from Plaintiff’s use of a product made by Defendant, a LifeVest® 4000 (“LifeVest”) which was prescribed by Plaintiff’s doctor. Plaintiff alleges the LifeVest released a shock or jolt due to a defective condition.

 

II.            ARGUMENTS

A.      Demurrer filed September 6, 2022

Defendant argues that Plaintiff’s claims are pre-empted by federal law unless Plaintiff can allege a parallel state claim. Plaintiff has not alleged that the medical device at issue, which is preapproved by the Federal Drug Administration (“FDA”), violated Federal Food, Drug, and Cosmetic Act (“FDCA”) that would give rise to recovery under state law even in the absence of the FDCA. The allegation alone that the device was defective is insufficient to allege the claims.

B.      No opposition filed.

C.      Reply filed on June 6, 2022

Defendant argues that contrary to Plaintiff’s opposition [which has not been filed with the court], Defendant is not asking for complete immunity from state claims. Plaintiff’s recitation to other case law around the country does not address the Plaintiff’s failure to allege a violation of federal law that also gives rise to recovery under California law. Without an allegation that Defendant violated a parallel state law, Plaintiff’s claims are pre-empted.

 

III.            LEGAL STANDARDS

A demurrer tests the sufficiency of a complaint as a matter of law and raises only questions of law. Schmidt v. Foundation Health (1995) 35 Cal.App.4th 1702, 1706. In testing the sufficiency of the complaint, the court must assume the truth of (1) the properly pleaded factual allegations; (2) facts that can be reasonably inferred from those expressly pleaded; and (3) judicially noticed matters. Blank v. Kirwan (1985) 39 Cal.3d 311, 318.

The court may not consider contentions, deductions, or conclusions of fact or law. Moore v. Conliffe (1994) 7 Cal.4th 634, 638. Because a demurrer tests the legal sufficiency of a complaint, the plaintiff must show that the complaint alleges facts sufficient to establish every element of each cause of action. Rakestraw v. California Physicians Service (2000) 81 Cal.App.4th 39, 43. Where the complaint fails to state facts sufficient to constitute a cause of action, courts should sustain the demurrer. Code Civ. Proc., § 430.10(e); Zelig v. County of Los Angeles (2002) 27 Cal.4th 1112, 1126.

Sufficient facts are the essential facts of the case "with reasonable precision and with particularity sufficiently specific to acquaint the defendant with the nature, source, and extent of his cause of action.” Gressley v. Williams (1961) 193 Cal.App.2d 636, 643-644. Whether the Plaintiff will be able to prove the pleaded facts is irrelevant. Stevens v. Superior Court (1986) 180 Cal.App.3d 605, 609–610.

A demurrer may also be sustained if a complaint is “uncertain.” Uncertainty exists where a complaint’s factual allegations are so confusing, they do not sufficiently apprise a defendant of the issues it is being asked to meet. Williams v. Beechnut Nutrition Corp. (1986) 185 Cal.App.3d 135, 139, fn. 2; Code Civ. Proc., § 430.10(f).

A pleading is required to assert general allegations of ultimate fact. Evidentiary facts are not required. Quelimane Co. v. Stewart Title Guaranty Co. (1998) 19 Cal. 4th 26, 47; Lim v. The.TV Corp. Internat. (2002) 99 Cal. App. 4th 684, 690. However, unlike federal courts, California state courts are not a notice pleading jurisdiction, and notice alone is not a sufficient basis for any pleading. California is a fact pleading jurisdiction. Merely putting an opposing party on notice is not sufficient. Bach v. County of Butte (1983) 147 Cal.App.3d 554, 561; see Diodes, Inc. v. Franzen (1968) 260 Cal.App.2d 244, 250.

 

IV.            DISCUSSION

The court takes judicial notice of the Premarket Approval Plan for the LifeVest issued by the U.S. Food and Drug Administration. RJN, Ex. A. The FDA approved the vest on December 18, 2001. RJN Ex. B. Evid. Code, § 452(c) and (h). https://www.accessdata.fda.gov/ cdrh_docs/pdf/P010030A.pdf.

Pursuant to the Medical Device Amendments of 1976 (“MDA”), "[e]xcept as provided in subsection (b), no State or political subdivision of a State may establish or continue in effect with respect to a device intended for human use any requirement--

(1) which is different from, or in addition to, any requirement applicable under this chapter to the device, and

(2) which relates to the safety or effectiveness of the device or to any other matter included in a requirement applicable to the device under this chapter." 21 U.S.C.A. § 360k (West). The complaint here alleges state law claims for products liability and negligence arising from the LifeVest’s unsafe condition. Complaint, page 5.

To determine whether preemption applies , the court first considers whether the Federal Government has established requirements applicable to the LifeVest, and whether the state-law claims are “different from, or in addition to,” the federal requirements relating to safety and effectiveness. Riegel v. Medtronic, Inc. (2008) 552 U.S. 312, 322. The FDA granted premarket approval of the use of the LifeVest subject to conditions. Defendant’s RJN, Ex. B. Among other things, the FDA required Defendant to submit annual, post-approval reports as a condition of continued approval. RJN, Ex. B, .pdf page 27, 29. Therefore, Defendant has satisfied the first prong for express preemption.

The second prong requires a determination of whether the misconduct violates a parallel state law claim as the "failure to plead parallel federal and state law violations with regard to manufacturing defects is fatal” to Plaintiff’s state law claims. De La Paz v. Bayer Healthcare LLC (N.D. Cal. 2016) 159 F.Supp.3d 1085, 1097 [Plaintiff’s failure to allege a breach of any parallel state law duties that could escape preemption warranted dismissal]. Here, the complaint does not allege any state claim that is parallel to any violation of federal requirements necessary to survive preemption. 

           

V.            CONCLUSION

Based on the foregoing, demurrer to the complaint is SUSTAINED. Leave to amend is ordinarily given if there is a reasonable possibility that the defect can be cured. However, it is the Plaintiff’s burden to show in what manner he can amend his complaint and how that amendment will change the legal effect of his pleading"].” Association of Community Organizations for Reform Now v. Department of Industrial Relations (1995) 41 Cal.App.4th 298, 302.

In the absence of an opposition filed by Plaintiff, the court cannot determine whether or in what manner Plaintiff can cure the defects. However, the court will hear from the Plaintiff to determine whether leave to amend will be granted.