The U.S. Fifth Circuit issued an en banc decision, holding that improper joinder of a non-diverse physician defendant for alleged malpractice with product liability claims against manufacturers of medical implant devices did not destroy diversity jurisdiction because plaintiff had not exhausted his administrative malpractice claims against the physician before joining him in the product liability suit. Mr. McReynolds filed an Amicus Curiae brief on behalf of the Products Liability Advisory Council, Inc . in support of diversity jurisdiction.

Kale Flagg v. Stryker Corporation, 819 F. 3d 132 (5^th Cir. 3/24/15).