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Toll or Suspension? New York Appellate Division Provides Clarity

New York’s Appellate Division, Second Department recently denied two motions arguing an appeal was untimely where the appellant filed a notice of appeal nine days beyond the standard deadline. The appellant successfully...more

SCOTUS Extends Specific Jurisdiction to Ford in Products Cases

The Supreme Court of the United States recently affirmed two state court judgments that had permitted plaintiffs to assert jurisdiction over Ford Motor Company for injuries stemming from allegedly-defective cars. In an 8-0...more

Breast Implant Multidistrict Litigation Claims Pared Down by New Jersey Federal Court

In a mass tort product liability, class action and consumer fraud consolidated litigation involving Allergan's Biocell textured breast implants and tissue expanders, Allergan moved to dismiss plaintiffs' complaints on...more

HHS Further Amends Declaration Under the PREP Act to Expand COVID-19 Vaccinators

The Public Readiness and Emergency Preparedness Act (PREP Act), 42 U.S.C. 247d-6d, provides liability immunity related to the manufacture, testing, development, distribution, administration and use of medical countermeasures...more

New York Medical and Life Sciences: Year in Review 2020

From contraceptives to mesh implants, shampoos to pasta, New York state and federal courts issued decisions in 2020 which further shaped the landscape in the medical and life sciences legal world. To prepare the best product...more

Two New York Appellate Court Decisions Affirm Default Orders Dismissing Plaintiffs’ Complaint

Two recent New York Appellate Division Second Department decisions articulated the standards of review for appeal of orders entered upon the default of the appealing party for its failure to oppose a motion in two different...more

New York’s First Department Limits the Ability for Defendants to Testify as to Custom and Practice in Medical Malpractice Cases

The First Department has limited the role of testimony as to custom and practice in establishing what a defendant physician did in a specific instance in medical malpractice cases in Guido v. Fielding, 190 A.D.3d 49 (2020)....more

New York High Court Recognizes "American Pipe" Cross-jurisdictional Class Action Tolling but Dismissal Restarts the Clock

Recently, the Court of Appeals of New York answered the questions certified to it by the Second Circuit in the affirmative that New York recognizes “American Pipe” (American Pipe v. Constr. Co v. Utah, 414 U.S. 538 (1974))...more

Recent Cases from New York’s Second Department Clarify What is Necessary for a Pre-Note of Issue Dismissal

In recent rulings, New York’s Second Department has clarified the standard to strike pleadings for violation of Court Orders. Contrasting the Tolkoff and Onyenwe cases shows how the Court distinguishes between a violation of...more

11/25/2020  /  Appellate Courts , CPLR , Dismissals , New York

New York Second Department Limits the Ability for Defendants to Testify as to Custom and Practice in Medical Malpractice Cases

The Second Department of the Appellate Division, New York State Supreme Court, has limited the role of testimony as to custom and practice in establishing what a defendant physician did in a specific instance in medical...more

FDA and FTC Take Action Regarding Pandemic-Related Products

In response to the COVID-19 pandemic, numerous manufacturers and distributors of products ranging from CBD, to herbal products and supplements, to ingestible silver, began to market their products as those that could...more

FDA Limits Respirator Manufacturers who can Apply for Authorization Under EUA

The FDA recently reissued an Emergency Use Authorization (“EUA”) for the sale and import of certain non-NIOSH-approved respirators manufactured in China and used by healthcare personnel in the United States but, critically,...more

New York Supreme Court Allows Plaintiff to Plead Statutory Fraud Claim with Medical Malpractice Negligence Cause of Action

A New York Supreme Court allowed a Plaintiff to assert a statutory fraud claim in the context of deceptive business practices under New York General Business Law (“GBL”) § 349 against Plaintiff’s neurologist in conjunction...more

New Jersey Supreme Court Finds Products Liability Act Does Not Bar Consumer Fraud Act Claims Alleging Express Misrepresentations

In responding to the question of law certified by the United States Court of Appeals for the Third Circuit pursuant to Rule 2:12A-3, the New Jersey Supreme Court answered in the affirmative that a claim under the New Jersey...more

The Case of the Exploding Can of PAM: Plaintiffs’ Product Liability Claims Don’t Stick

New York Federal Court granted Defendants’ Daubert motion to exclude design defect expert testimony on a design defect claim for PAM Cooking Spray and dismissed all product liability claims on summary judgment, including...more

New York Federal Court Dismisses Breast Implant Products Liability Claim on Preemption Grounds

MemoryGel silicone breast implants are Class III medical devices, approved by the FDA through the premarket approval (PMA) process in 2006. Premarket approval was a federal requirement imposed on the device. Plaintiff sued in...more

FDA’s Emergency Use Authorization Expands Class of Mask Manufacturers and Distributors Entitled to Immunity

In response to increased concerns regarding insufficient personal protective equipment (“PPE”), the FDA recently issued an Emergency Use Authorization (“EUA”) applicable to face masks for use by both the general public and...more

Government Issues Immunity to Liability for COVID-19 Countermeasures

In times of national public health crises such as the COVID-19 pandemic, manufacturers and distributors of products are often called to the frontlines of battle to create, supply, and administer the tools necessary to combat...more

Judgment by Confession: New York State Quashes Loophole Harming Out-of-State Debtors

A new amendment in New York that restricts the use of judgments by confession will protect debtors and limit the ability of creditors to exploit a loophole. The change prohibits a creditor from filing a confession of...more

FDA Proposes Strengthening Warning Labels on Breast Implants

The Food and Drug Administration has issued a new draft breast implant guidance recommending that manufacturers strengthen labeling about the potential complications and risks of the medical devices, particularly by adding...more

Court Decision Highlights Key Role of Expert Witness in Food Manufacturer Suits

The Appellate Division of New York, Second Department, recently upheld a lower court’s decision denying a defendant manufacturer’s application to perform destructive testing on a plastic object surgically removed from...more

FDA Determines Textured Breast Implants Do Not Require Safety Ban

The Food and Drug Administration (FDA) has announced that data reviewed on the risks associated with textured breast implants and anaplastic large cell lymphoma (BIA-ALCL) does not require a ban of this medical device under...more

FDA Issues Warning for Robotically Assisted Mastectomies and Other Cancer Surgeries

The Food and Drug Administration (FDA) has issued a safety warning regarding the use of robotically assisted surgical devices for mastectomies and other cancer surgeries, asserting that "the safety and effectiveness of...more

Second Circuit Affirms Summary Judgment in Hip Repair Product Liability Action

Harris Beach attorneys Judi Abbott Curry, Victoria A. Graffeo and Marina Plotkin prevailed on plaintiffs’ appeal to the Second Circuit of product liability failure to warn claims against Pioneer Surgical Technology, Inc. and...more

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