Published July 23, 2026
Before the federal hair relaxer litigation became the sprawling multidistrict case it is today, a case winding through Georgia's state courts produced a ruling that's still shaping how these claims get evaluated. On October 15, 2025, the Georgia Supreme Court issued a unanimous decision in Burroughs v. Strength of Nature Global, LLC and L'Oreal USA, Inc., reviving a hair relaxer injury lawsuit that lower courts had thrown out — and rejecting a defense argument that could have shut the door on claims from many long-term relaxer users.
The plaintiff, Kiara Burroughs, said she began using Strength of Nature relaxers in 1995 and started using L'Oreal products in 2003, and was diagnosed with uterine fibroids in 2018. She filed suit in 2022. The manufacturers argued her claims were barred by Georgia's 10-year statute of repose for product liability — a law that cuts off lawsuits filed too long after a product was first sold, regardless of when an injury shows up.
Their position was that the repose period ran from Burroughs' earliest purchases in the 1990s, meaning her 2022 lawsuit came far too late. The Georgia Supreme Court disagreed, holding that the statute applies on a per-unit basis — each individual sale starts its own 10-year clock, rather than the entire decades-long relationship between a consumer and a product line being governed by the date of first purchase. That reading let Burroughs' claims proceed for any relaxer units she purchased within 10 years of filing suit, even though her earliest purchases fell outside that window.
Chemical hair relaxer use is often a decades-long habit that starts in childhood or adolescence, which is exactly the pattern that made the manufacturers' time-bar argument so consequential — if it had succeeded, it could have knocked out claims from many of the women with the longest exposure histories, who arguably have the strongest causal link to a later cancer or fibroid diagnosis. The Georgia ruling doesn't bind the federal MDL directly, since statutes of repose and limitations are set state by state, but it's a signal to manufacturers that "you waited too long" defenses tied to first purchase dates aren't a guaranteed win, even in states with strict repose laws.
If you're worried that decades of product use might put you outside your state's filing window, don't assume that rules you out — as this case shows, the analysis can be more favorable than it first appears, and it depends heavily on your specific state's law. See Atumio's hair relaxer case page for a free eligibility review, or start your case review directly.