Merck & Co., Inc. v. Garza

Respondents contend that Vioxx, a prescription drug, caused their decedent’s death. In Merrell Dow Pharmaceuticals, Inc. v. Havner, 1 we set requirements for determining whether epidemiological evidence is scientifically reliable to prove causation. The parties here dispute what those requirements are, whether they apply in this case, and whether they were satisfied. We hold that Havner 1 s requirements apply and were not met, and that the evidence was therefore legally insufficient to prove causation. Accordingly, we reverse the judgment of the court of appeals 2 and render judgment that…