Where to File in California
MDL 2545 — In re: Testosterone Replacement Therapy Products Liability Litigation — is consolidated in the Northern District of Illinois before Judge Matthew Kennelly in Chicago. California cases filed in federal court are typically transferred to N.D. Illinois for coordinated pretrial proceedings under 28 U.S.C. § 1407. The MDL is largely resolved after global settlement agreements with AbbVie (AndroGel), Endo Pharmaceuticals, and Auxilium, but new meritorious claims filed by California plaintiffs continue to be accepted and may be remanded for individual trial following MDL bellwether proceedings.
California's statute of limitations for personal injury and products liability is two years under Code of Civil Procedure § 335.1. The discovery rule tolls the limitations period until the plaintiff knew or reasonably should have known that a TRT product caused the cardiovascular injury — including heart attack, stroke, deep vein thrombosis, or pulmonary embolism. Given the FDA's 2015 black-box cardiovascular warning, courts often scrutinize when a California plaintiff had constructive notice of causation. Prompt case evaluation is critical.
California leads the nation in TRT prescriptions, with particularly high rates in Los Angeles, San Diego, the Bay Area, and Sacramento. Cardiologists and endocrinologists throughout the state treated a significant volume of men prescribed AndroGel and Axiron between 2010 and 2015 before the FDA cardiovascular warning was widely communicated. California's large male population aged 40–65 and the state's active concierge medicine and men's health clinic market contributed to elevated TRT exposure rates.
California plaintiffs may also assert claims under California consumer protection statutes including the Consumers Legal Remedies Act and Unfair Competition Law in addition to standard products liability and negligence theories. Cases filed in California state court are subject to removal to federal court and subsequent transfer to MDL 2545, though some plaintiffs have successfully litigated in California Superior Court where remand from the MDL is not anticipated.