Williams v. Mast Biosurgery USA, Inc.

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Plaintiff brought this diversity action in district court against defendant, a medical device manufacturer, alleging that the SurgiWrap, a product designed and produced by defendant, used in her surgical procedure had a manufacturing defect that caused it to perform in a manner other than as intended, and seeking relief under Georgia products liability law. At issue was whether the district court erred in limiting the testimony of her physicians and in granting summary judgment for defendant. The court held that the district court did not abuse its discretion in limiting the testimony of her treating physicians in light of Federal Rule of Evidence 702 and the strictures of Daubert. The court also held that plaintiff failed to produce evidence, expert or otherwise, from which a reasonable jury could conclude that the SurgiWrap implanted in her abdomen contained a manufacturing defect. Accordingly, the district court correctly entered summary judgment for defendant.