Stamps v. Collagen Corp

How later courts describe this case

• holding that existence of express preemption clause precludes reliance on implied preemption doctrine, without determining whether provision constituted a "reliable indicium of congressional intent"
• holding that the analysis used in Ferebee did not survive the Cipollone decision
• holding that the analysis used in Fer-ebee did not survive the Cipollone decision
• finding that the express preemption provision in the MDA precludes any discussion regarding implied preemption
• holding state law claims not preempted where FDA had established no specific requirements unique to the Class III medical device at issue
• finding that the PMA process constitutes a “specific requirement” applicable to a particular device
• “[W]e do not believe the [preemption] analysis [in Ferebee] can be said to have survived Cipollone-”
• claims of failure to warn and defective design preempted where manufacturer of Class III device underwent PMA