EAST ST. LOUIS – The U.S. District Court for the Southern District of Illinois on Sept. 19 granted summary judgment to a pharmaceuticals company, disagreeing that a drug it manufactured caused an Illinois man to suffer heart complications.
“Because one event occurred after another event, the earlier must have caused the latter; courts have long rejected such fallacious reasoning unless there is additional evidence of causation,” Senior District Judge Phil Gilbert ruled.
Plaintiff Leonard Hadley filed suit in May 2018 against AstraZeneca PLC, a British-based multinational manufacturer of chemical drugs used to treat gastrointestinal, cardiac and vascular disorders.
The suit also identified AstraZeneca Pharmaceuticals PLC and the U.S. Food & Drug Administration (FDA) as co-defendants.
Hadley claimed that when he took Seroquel, a psychotropic drug from 2002 to 2008, it caused him to suffer Phase 1 Brugada Syndrome, a disruption of the heart’s normal rhythm.
He was diagnosed with the heart condition in 2008 and as a result had to have a pacemaker inserted into his chest, allegedly suffering extreme pain and risking death.
Hadley alleged in his suit that AstraZeneca did not adequately warn about the cardiac risks from taking the medication.
He asked the Court for summary judgment against the defendant contending that prior lawsuits AstraZeneca had settled with the U.S. Department of Justice in 2010 and a number of states in 2011 for inadequate labeling of Seroquel - entitled him to a similar judgment.
AstraZeneca filed a motion to dismiss the case which the Court took as a request for summary judgment. The motion claimed that a two-year statute of limitations for personal injury actions according to Illinois law had run out and that AstraZenica Pharmaceuticals PLC should be dismissed because there was no such entity.
Attorneys for AstraZeneca contended an earlier confidential settlement agreement Hadley received in a different case involving the company and its drug Seroquel in 2011 rendered this lawsuit “res judicata;” it couldn’t be re-litigated because the issue had already been decided.
Hadley denied he ever executed any prior settlement agreement and release of AstraZeneca defendants. He also disputed that a two-year statute of limitations had run out. He maintained the term limit would be put on hold from the time he had become disabled in 1976.
AstraZeneca disputed Haley’s claim to be legally disabled.
Hadley filed a motion to strike AstraZeneca’s filings suggesting that he settled a previous lawsuit with the company making the current lawsuit irrelevant.
Gilbert rejected Hadley’s motion to strike deciding he had not proven an insufficient defense on the part of the defendant, but had merely disagreed with their argument.
On his motion for a summary judgment, Gilbert declared Hadley had not proven the defendant knew its drug product was dangerous and that adequate warning would have prevented his taking the drug.
“The Court finds Hadley failed to carry his initial burden on the issue of causation,” the brief stated.
On the issue of statute of limitations, Gilbert found Hadley was diagnosed with Brugada Syndrome in 2008 requiring him to file a lawsuit by 2010. Even allowing for a state “discovery rule,” allowing an extension of time, he would have been required to file by 2012. The first delivery of the Seroquel drug to him occurred in 2002. He filed six years too late.
Gilbert also rejected Hadley’s claim to be legally disabled from 1976 on due to a gunshot wound, thus voiding the statute of limits.
“There is no evidence Hadley has ever been under a legal disability for limitations purposes,” the ruling states.
The case was dismissed without trial.