In an April 2015 Law360 article, "Generic Cases Still Face Tough Odds After High Court Snub," Partner Susan E. Burnett of the Austin office of Bowman and Brooke commented on plaintiffs dodging "the preemption bullet" after the U.S. Supreme Court's refusal to reconsider Iowa Supreme Court ruling in Pliva v. Huck, which had allowed generic-drug makers to face failure-to-update labeling claims.