Pamela Rheinfrank v. Abbott Laboratories

ROGERS, Circuit Judge.

This state-law product liability case arose from birth defects in the form of serious physical and cognitive disabilities suffered by plaintiff Rheinfrank’s child. The defects were allegedly caused by the antiepileptic drug Depakote, manufactured by defendant Abbott Laboratories, and taken by Rheinfrank while pregnant with the child. Rheinfrank contended that the labeling on the drug was not adequate. The district court held that Rheinfrank’s Ohio law failure-to-warn claim—to the extent that it was based on Abbott’s failure to warn of the risk of developmental delays—was…