The New York Times reported on divergent liabilities by drug manufacturers. In comparing the Supreme Court decision in a case by Diana Levine, to a little known case brought by Debbie Schork, the liability factor stands in sharp contrast. Both were injected with the same drug (promethazine), both were injected in the arm, both developed gangrene from the drug (an unknown side effect), and both suffered amputations. While Ms. Levine's case proceeded, Ms. Schork's case was quietly dismissed. The only difference is the intrusion of another Supreme Court decision named PLIVA, Inc. v. Mensing which limits liability by generic manufacturers. So while Ms. Levine's injection was in the branded form of the drug (Phenergan), Ms. Schork received the generic form of the drug. The Supreme Court ruling affects potentially millions of people: nearly 80 percent of prescriptions in the United States are filled by a generic, and most states permit pharmacists to dispense a generic in place of a brand name.