Spence v. Miles Laboratories, Inc.
1992 U.S. Dist. LEXIS 20664, 810 F.Supp. 952, 1992 WL 414710 (1992)
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Rule of Law:
A state's product liability statute of repose, which establishes an absolute time limit for filing a lawsuit based on a product's expiration date, can bar a claim even if the injury was not discovered until after the time limit expired. Such a statute does not violate the Equal Protection Clause by creating an exception for one type of latent injury (e.g., from asbestos) but not another (e.g., from AIDS), so long as a rational basis exists for the legislative distinction.
Facts:
- Wynne Spence, who was born with hemophilia, required treatment with blood-clotting factor concentrates.
- Between October 1984 and March 1985, Miles Laboratories, Inc. ('Miles') collected plasma from donors who had not been screened for the AIDS virus.
- Miles used this plasma to manufacture KONYNE-HT Lot No. 20P010, which was released for distribution on July 16, 1985, with an expiration date of June 5, 1987.
- In July and August of 1986, Wynne Spence was treated with KONYNE-HT from this specific lot.
- On March 22, 1990, Spence was diagnosed with AIDS for the first time.
- Spence died from AIDS-related complications on March 24, 1992.
Procedural Posture:
- On March 20, 1991, Wynne and Jennifer Spence filed suit against Miles Laboratories, Inc. in the Circuit Court of Hamilton County, Tennessee, a state trial court.
- Miles removed the case to the United States District Court for the Eastern District of Tennessee, a federal trial court.
- After Wynne Spence's death, his spouse, Jennifer Spence, continued the lawsuit as the plaintiff.
- Miles filed an initial motion for summary judgment, which the court denied.
- Miles subsequently filed a motion for the court to reconsider its denial of summary judgment.
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Issue:
Does Tennessee's product liability statute of repose, which requires a suit to be filed within one year of a product's expiration date, bar a claim for an AIDS infection contracted from a blood product when the plaintiff did not discover the infection until after the statutory period had expired?
Opinions:
Majority - Edgar, District Judge
Yes. The claim is barred because Tennessee's product liability statute of repose establishes an absolute deadline for filing suit that is not extended by a 'discovery rule.' The plaintiff's claims, regardless of their legal theory, fall under Tennessee's broad definition of a 'product liability action' and are therefore governed by the statute of repose, Tenn. Code Ann. § 29-28-103(a). This statute required the suit to be filed within one year of the product's expiration date, meaning the deadline was June 5, 1988. Because the suit was filed in 1991, it is time-barred. The statute's exemption for asbestos claims does not violate equal protection because the legislature had a rational basis to distinguish between asbestos-related injuries, which have an extremely long latency and no early diagnostic test, and HIV infection, for which a screening test became available in 1985. Furthermore, the defendant's mere failure to warn about using untested plasma does not constitute fraudulent concealment sufficient to toll the statute.
Analysis:
This decision illustrates the harsh and inflexible nature of a statute of repose, which is legislatively designed to provide finality to potential defendants by cutting off liability after a fixed period, regardless of when an injury is discovered. It strongly affirms the distinction between a statute of limitations, which is subject to equitable tolling like the discovery rule, and a statute of repose, which sets an absolute bar. The ruling also reinforces the significant deference courts grant to legislative classifications under the rational basis standard of equal protection review, making it very difficult to challenge laws that distinguish between different groups of victims unless a suspect class or fundamental right is involved.
