In what circumstances will a court impose strict liability on a manufacturer of prescription drugs?

In Kearl, the court recited the several dangers from imposing strict liability upon manufacturers of prescription drugs: "... the enhanced prospect of liability posed by strict liability analysis might, in some cases, substantially affect a product's availability. In addition to the problem of delayed release (or nonrelease) mentioned above, we can easily conceive of situations in which a manufacturer's cost of insuring against strict liability for injuries resulting from product design would 'place the cost of research development and eventual marketing of new [products] beyond that which manufacturers, especially smaller manufacturers, are willing to risk....' [Citations.] Nor is it difficult to imagine a situation in which insurers would be unwilling to underwrite such risks, or do so at a practical cost.... Furthermore, we believe it likely that the increased cost of product production--resulting from increased insurance costs--might 'place the price of necessary [products] outside the reach of those who most need them' [citation], or that the prospect of strict liability might cause manufacturers to remove some products from the market, or decline to develop them. [Citations.]" (Kearl v. Lederle Laboratories, supra, 172 Cal.App.3d at pp. 823-824, 218 Cal.Rptr. 453.)