Master Complaint (MDL)

Master Complaint (MDL)

Master Complaint (MDL)

A master complaint consolidates the common factual and legal allegations, with individual plaintiffs adopting it through a short form complaint identifying case-specific details such as product use and injury.

It is an administrative device rather than a superseding pleading in most proceedings.

Alternative Names:

Consolidated Complaint, Master Pleading

Why it Matters?

The master and short form structure allows common motion practice against the pleading without litigating thousands of individual complaints, which is its principal efficiency. Whether the master complaint supersedes individual pleadings or merely supplements them is contested and affects what survives remand. Courts differ, and the pretrial order establishing the structure should address it because the answer determines the operative pleading after the MDL concludes.

Frequently Confused with

Related terms

Frequently asked questions

How do individual plaintiffs adopt the master complaint?

How do individual plaintiffs adopt the master complaint?

Through a short form complaint identifying case-specific details such as product use, exposure period, injury, and defendants.

Does it supersede individual complaints?

Does it supersede individual complaints?

Contested. Courts differ, and the answer determines the operative pleading after remand, which the pretrial order should address explicitly.