MDL 3194: Abbott Spinal Cord Stimulator Cases Are Now Centralized in Illinois

On October 2, 2026, the Judicial Panel on Multidistrict Litigation granted a motion to centralize the federal Abbott spinal cord stimulator cases. They are now MDL No. 3194, before Judge Lindsay C. Jenkins in the Northern District of Illinois. Abbott opposed centralization and lost.

What the Panel decided

Plaintiffs in two actions moved under 28 U.S.C. § 1407 to centralize the litigation in the Central District of California. At the time of the order the litigation consisted of fifteen actions pending in six districts, with the parties having notified the Panel of eleven related actions pending in ten districts.

The Panel found the actions share questions of fact arising from allegations that Abbott failed to comply with regulatory requirements for Class III devices by misusing the premarket approval (PMA) supplement process — introducing successive new stimulator models under supplements with significant modifications, rather than through the clinical evaluation a new PMA application would require. The actions also share factual questions about whether Abbott failed to warn of known risks, and whether Abbott sales representatives engaged in the unlicensed practice of medicine by programming and reprogramming patients’ devices.

The order states that centralization will eliminate duplicative discovery, streamline briefing and prevent inconsistent pretrial rulings — “particularly concerning Abbott’s preemption defenses” — and conserve the resources of the parties, their counsel and the judiciary.

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A few quick questions about your spinal cord stimulator, the problems you experienced, and any revision or removal surgery. This is the initial intake screening, not a full case review. Most people finish in about two minutes.

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For the devices, the recall history and the claims themselves, see the Abbott spinal cord stimulator lawsuit page. The wider litigation across all four manufacturers is covered on the spinal cord stimulator lawsuit page.

What Abbott argued, and what the Panel said

• That injuries vary too widely and there is no common defect. The Panel agreed plaintiffs do not allege a common mechanism of defect, and centralized anyway, noting it has “rejected the argument that products liability actions must allege identical injuries to warrant centralization.”
• That the cases could be transferred under § 1404 or informally coordinated. The Panel disagreed, counting 26 actions pending in thirteen districts brought by at least four different plaintiffs’ law firms, and finding that getting every party to agree to transfer was not a reasonable prospect.
• That plaintiffs were trying to delay rulings on motions to dismiss, seven of which were fully briefed. The Panel acknowledged centralization may cause a brief delay, and found it will streamline motion-to-dismiss briefing across all actions because the preemption issues overlap.
• That three actions carry unique defect allegations. The Panel declined to exclude them, noting the transferee judge can suggest remand after close scrutiny if any action turns out not to benefit from centralized proceedings.

Abbott’s counsel stated at oral argument that if the Panel granted centralization, Abbott preferred the Central District of California.

Why it did not go to the Boston Scientific judge

Several parties asked the Panel to assign this litigation to the same judge already presiding over MDL 3181, the Boston Scientific stimulator MDL in the Central District of California. The Panel refused, in a sentence it used in both orders issued that day:

“Little efficiency will be gained by placing SCS device MDLs against multiple manufacturers before one judge.”

It chose the Northern District of Illinois because ten of the actions were already pending there and Abbott is headquartered in the district, and assigned the litigation to Judge Lindsay C. Jenkins, describing her as an able jurist who has not yet had the opportunity to preside over an MDL.

Where the FDA fits

Plaintiffs in ten of the actions and potential tag-along actions bring claims against the U.S. Food and Drug Administration, contending it failed to meaningfully review Abbott’s PMA supplements. The FDA took no position on centralization and stated that the claims against it should be dismissed. The parallel Administrative Procedure Act track inside the Boston Scientific MDL is covered separately on the APA claims against the FDA.

What this means if you have an Abbott stimulator

Centralization is a pretrial procedure. It does not decide liability, it does not create a settlement, and it does not change who can bring a claim or what that claim has to prove. State filing deadlines run on their own schedule and are not paused by anything on this page.

What it does change is where a federal Abbott case is heard before trial. Seven actions were transferred into the Northern District of Illinois by the order; the rest were already there.

Correct scope, which is frequently reported wrong

There are now three separate spinal cord stimulator MDLs, not one. MDL 3181 covers Boston Scientific only, in the Central District of California. MDL 3194 covers Abbott, in the Northern District of Illinois. MDL 3195 covers Nevro, in the Northern District of California. The Panel has now declined three times to create a single industry-wide MDL. Medtronic is the subject of none of them.

Sources

• Transfer Order, In re: Abbott Laboratories Spinal Cord Stimulator Products Liability Litigation, MDL No. 3194, Dkt. 54 (J.P.M.L. Oct. 2, 2026), signed by Karen K. Caldwell, Chair. Judge M. Casey Rodgers took no part in the decision.
• Transfer Order, In re: Abbott Labs. & Boston Scientific Corp. Spinal Cord Stimulator Prods. Liab. Litig., MDL No. 3181 (J.P.M.L. June 5, 2026) — hosted on this site.

Questions about an Abbott spinal cord stimulator injury: call (888) 348-2735. No fee unless there is a recovery.

See if you qualify

A few quick questions about your spinal cord stimulator, the problems you experienced, and any revision or removal surgery. This is the initial intake screening, not a full case review. Most people finish in about two minutes.

• 🔒 Confidential
• No obligation
• ⏱ ~2 minutes

Get started

Marin & Murphy Law Firm · Free & confidential · Stop messages anytime