Mealey's (March 1, 2017, 12:23 PM EST) -- LAKELAND, Fla. — A Florida appeals court on Feb. 15 affirmed summary judgment against a couple’s claim of spoliation of an explanted medical device by a hospital, saying that even if the couple had the device, their claim against the device manufacturer is preempted by federal law (Linda Wolicki-Gables, et al. v. Doctors Same Day Surgery Center, Ltd., et al., No. 2D15-2495, Fla. App., 2nd Dist., 2017 Fla. App. LEXIS 1952)....