Royer v. Catholic Medical Center

Brief Fact Summary.

After having his knee replaced with a defective prosthetic, Royer (Plaintiff) sued Catholic Medical Center (Defendant), claiming that Defendant was strictly liable as the seller of a defectively designed product.

Synopsis of Rule of Law.

A health care provider that supplies a prosthetic device to be implanted into a patient is not considered a seller of the prostheses under strict products liability law.

Facts.

Plaintiff underwent knee replacement surgery at Defendant hospital. The prosthetic knee was defective and had to be replaced in a second surgery. Plaintiff sued Defendant under a strict liability theory for selling a defectively designed product that was in an unreasonably dangerous condition. Defendant argued that it was not a seller of products for purposes of strict products liability. The district court granted Defendant’s motion to dismiss and Plaintiff appealed. 

Issue.

Is a health care provider that supplies a prosthetic device to be implanted into a patient considered a seller of the prostheses under strict products liability law?

Held.

(Brock, C.J.) No. A health care provider that supplies a prosthetic device to be implanted into a patient is not considered a seller of the prostheses under strict products liability law. Health care providers primarily render services and the provision of prosthetic devices is only incidental to the service being provided. Affirmed.

Discussion.

Most jurisdictions follow this approach. Patients do not go to the hospital to purchase prosthetics. They go to the hospital to receive many medical services, including the provision of prosthetics.