The district court granted judgment for Wyeth, holding that Section 22(b)(1) of the Vaccine Act expressly preempts all design defect claims arising from a vaccine-related injury.
Yesterday, the U. S. Supreme Court recognized that Congress meant what it said, holding that the Vaccine Act expressly preempts all state-law products liability suits challenging the design of widely administered childhood vaccines, which the Food and Drug Administration (FDA) has already determined to be safe and effective.