A federal judge in the Middle District of Pennsylvania has joined a counterpart in the Eastern District in opening a window for plaintiffs to make a claim for strict liability against prescription drugmakers on a manufacturing defect theory.

Despite developing case law in the opposite direction, U.S. District Judge Malachy Mannion of the Middle District of Pennsylvania ruled that Ryan Bergstresser could bring a strict liability manufacturing-defect claim against Bristol-Myers Squibb over its antipsychotic drug, Abilify.