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A Separate and Compelling Plaintiff Class
Among the women harmed by Allergan's BIOCELL recall, those who received textured implants as part of breast cancer reconstruction after mastectomy represent a uniquely compelling plaintiff class. These women underwent breast surgery to fight cancer — a deeply traumatic experience — and then received BIOCELL tissue expanders or implants (including the Natrelle 410 and Natrelle 133 tissue expander) as part of their reconstruction. They trusted that the medical devices used in their cancer recovery were safe. The recall forced many of these women to confront the prospect of additional surgery to remove the implants they received during their cancer treatment, compounding physical and emotional trauma. Women who subsequently developed BIA-ALCL after post-mastectomy reconstruction faced a second cancer diagnosis — with distinctive, powerful damages narratives.
BIOCELL Tissue Expanders — A Key Reconstruction Product
Allergan's Natrelle 133 BIOCELL tissue expanders were commonly used in two-stage breast reconstruction. In the first stage, after mastectomy, surgeons place a tissue expander under the chest muscle to gradually stretch the skin and muscle in preparation for a permanent implant. The Natrelle 133 uses the same BIOCELL macro-textured surface as Allergan's breast implants and was included in the July 2019 recall. Women who had BIOCELL tissue expanders placed — even if they were subsequently exchanged for smooth permanent implants — may have a claim based on the period of BIOCELL exposure during the expansion phase. This is a less frequently pursued claim that deserves attorney evaluation for women with a documented BIOCELL tissue expander history.
Insurance, Coverage, and Reconstruction Complications After the Recall
Reconstruction patients face compounded complexities when Allergan BIOCELL implants are recalled. Post-mastectomy explantation involves surgical risks that differ from cosmetic explant surgery, including risk to tissue expander pockets, chest wall reconstruction, and the potential need for re-reconstruction with autologous tissue (such as TRAM flap or DIEP flap procedures) for women who cannot or choose not to replace with new implants. Insurance coverage for recall-driven explantation is inconsistent — some insurers cover it as medically necessary, others do not. The costs of explantation, re-reconstruction, and related surgeries are recoverable as economic damages in MDL 2921 claims. Women in this category who developed BIA-ALCL face the full spectrum of cancer-related damages on top of reconstruction complications.
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