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Court Denies Medtronic's Motion for Summary Judgement

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Defibrillator manufacturer Medtronic asked the US District Court of Minnesota to consider a motion for summary judgement. Their request was based on the claim that federal preemption barred the plaintiffs’ claims. The plaintiffs’ main complaint sites state law product liability claims sounding in negligence and strict liability. Other claims include violations of state Consumer Protection Statutes, violations of Minnesota false advertising and deceptive trade practices statutes, and misrepresentation by omission. The plaintiffs’ seek damages for personal injuries that resulted from their use of Medtronic devices.

The Supremacy Clause of the US Constitution establishes the premise for federal preemption. The clause indicates that any state law conflicting with a federal law or regulation is preempted. Any court considering a preemption challenge is not to pass judgement on the state policy’s reasoning, but rather must decide if the policy conflicts with or stands in the way of the purpose and execution of a the federal law.

After thoroughly investigating Minnesota state law, FDA approval requirements, evidence brought forth by the plaintiffs, and other preemption cases, the US District Court of Minnesota found Medtronic failed to show that the plaintiffs’ claims were preempted by federal law. Medtronic’s motion for summary judgement was denied on November 28, 2006.