Vaccine Maker Granted Summary Judgement Due to Implied Preemption

By Sean K. Burke and Gabrielle Pelura

On March 11, 2025, Judge Kenneth Bell in the Western District of North Carolina granted summary judgment in favor of Merck & Co. Inc. and Merck Sharp Dohme LLC against the “bellwether plaintiffs” in a multidistrict litigation who were vaccinated with Gardasil at various dates from 2012 to January 2021. Merck’s summary judgment motion required the court to decide whether plaintiffs’ state law claims were preempted by federal law. The court found that Merck met this standard, and plaintiffs did not successfully rebut its claims. 

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