Buckman Co. v. Plaintiffs Legal Comm., 531 U.S. 341 (2001), was a United States Supreme Court case decided in 2001. The case concerned whether the FDCA (Food, Drug and Cosmetic Act), a federal statute, pre-empted a state-law fraud-on-the-FDA claim. Although finding it on different grounds, the Court decided to reject the lawsuit attempt.
The Plaintiffs' Legal Committee represented plaintiffs who claimed injuries resulting from the use of bone screws on their spines.[1] They sued Buckman Company, alleging they made fraudulent representations to the FDA. They further argued that "but for" the false representations, the injuries would not have occurred.[1]
The District Court for the Eastern District of Pennsylvania heard these claims and decided to dismiss the "fraud-on-the-FDA" sections of the complaint on the ground that it was pre-empted by federal law.[2] A divided panel of the United States Court of Appeals for the Third Circuit reversed, arguing that there was no express pre-emption.[2]
Chief Justice William Rehnquist wrote the decision of the Supreme Court, reversing the Third Circuit. He concluded that there was express pre-emption because holding these claims under state law would "inevitably conflict" with the FDA's duty to police fraud.[3] Additionally, to allow such suits could potentially chill information provided to the FDA, a concern the Court thought would hamper the FDA's evaluation of applications.
Justice John Paul Stevens wrote a concurring opinion in the judgement of the Court, which Justice Clarence Thomas joined. Thus, they agreed with reversing the Third Circuit, but on different grounds. Stevens said the lawsuit could not proceed because the plaintiffs could not rebut the fact that the FDA did not remove the allegedly defective products from the market. Therefore, there was no "but for" causation in the first instance.[4]
Text of Buckman Co. v. Plaintiffs' Legal Committee, 531U.S. 341 (2001) is available from:CourtListenerFindlawGoogle ScholarJustiaOyez (oral argument audio)
October 27, 2023
buckman, plaintiffs, legal, committee, buckman, plaintiffs, legal, comm, 2001, united, states, supreme, court, case, decided, 2001, case, concerned, whether, fdca, food, drug, cosmetic, federal, statute, empted, state, fraud, claim, although, finding, differen. Buckman Co v Plaintiffs Legal Comm 531 U S 341 2001 was a United States Supreme Court case decided in 2001 The case concerned whether the FDCA Food Drug and Cosmetic Act a federal statute pre empted a state law fraud on the FDA claim Although finding it on different grounds the Court decided to reject the lawsuit attempt Buckman Co v Plaintiffs Legal Comm Supreme Court of the United StatesArgued December 4 2000Decided February 21 2001Full case nameBuckman Company Petitioners v Plaintiffs Legal CommitteeCitations531 U S 341 more 121 S Ct 1012 148 L Ed 2d 854Case historyPriorIn re Orthopedic Bone Screw Products Liability Litigation 159 F 3d 817 3d Cir 1998 reversed HoldingPlaintiffs claims are pre empted under the Federal Food Drug and Cosmetic Act Court membershipChief Justice William Rehnquist Associate Justices John P Stevens Sandra Day O ConnorAntonin Scalia Anthony KennedyDavid Souter Clarence ThomasRuth Bader Ginsburg Stephen BreyerCase opinionsMajorityRehnquist joined by O Connor Scalia Kennedy Souter Ginsburg BreyerConcurrenceStevens in judgment joined by ThomasLaws appliedFederal Food Drug and Cosmetic Act FDCA Contents 1 Background 2 Opinion of the Court 3 See also 4 References 5 External linksBackground editThe Plaintiffs Legal Committee represented plaintiffs who claimed injuries resulting from the use of bone screws on their spines 1 They sued Buckman Company alleging they made fraudulent representations to the FDA They further argued that but for the false representations the injuries would not have occurred 1 The District Court for the Eastern District of Pennsylvania heard these claims and decided to dismiss the fraud on the FDA sections of the complaint on the ground that it was pre empted by federal law 2 A divided panel of the United States Court of Appeals for the Third Circuit reversed arguing that there was no express pre emption 2 Buckman Company appealed to the Supreme Court which heard the case in December 2000 Opinion of the Court editChief Justice William Rehnquist wrote the decision of the Supreme Court reversing the Third Circuit He concluded that there was express pre emption because holding these claims under state law would inevitably conflict with the FDA s duty to police fraud 3 Additionally to allow such suits could potentially chill information provided to the FDA a concern the Court thought would hamper the FDA s evaluation of applications Justice John Paul Stevens wrote a concurring opinion in the judgement of the Court which Justice Clarence Thomas joined Thus they agreed with reversing the Third Circuit but on different grounds Stevens said the lawsuit could not proceed because the plaintiffs could not rebut the fact that the FDA did not remove the allegedly defective products from the market Therefore there was no but for causation in the first instance 4 See also editFood and Drug Administration FederalismReferences edit a b Buckman Co v Plaintiffs Legal Committee 531 U S 341 346 2001 a b 531 U S at 347 531 U S at 344 531 U S at 354 External links editText of Buckman Co v Plaintiffs Legal Committee 531 U S 341 2001 is available from CourtListener Findlaw Google Scholar Justia Oyez oral argument audio Retrieved from https en wikipedia org w index php title Buckman Co v Plaintiffs 27 Legal Committee amp oldid 1175139636, wikipedia, wiki, book, books, library,
