CA: The Learned Intermediary Doctrine and Causation

The California Supreme Court recently clarified causation in the context of the learned intermediary doctrine:

Himes v. Somatics, LLC, 16 Cal. 5th 209, 219, 235-236, 322 Cal. Rptr. 3d 1, 6, 20, 549 P.3d 916, 921, 933 (2024) (holding that “[i]f a prescription drug or medical device manufacturer has breached its duty under the learned intermediary doctrine to provide an adequate warning . . . to the physician, . . . [a] plaintiff is not required to show that a stronger warning would have altered the physician's decision to prescribe the product to establish causation. A plaintiff may instead establish causation by showing that the physician would have communicated the stronger warning to the patient and an objectively prudent person in the patient's position would have thereafter declined the treatment  notwithstanding the physician's continued recommendation of the treatment.”).