Himes v. Somatics, LLC

Summary

The court held that a plaintiff asserting a prescription-device failure-to-warn claim need not prove that a stronger warning would have changed the physician's decision to prescribe. Causation may instead be shown if the physician would have communicated the stronger warning and an objectively prudent person in the patient's position would have declined treatment, even though the physician would still have recommended it. The court also held that the learned intermediary doctrine directs warnings to physicians but does not eliminate the patient's role in the causation analysis.