California Appeals Court Clarifies Reach of Products Liability Component Parts Doctrine
March 17, 2017
Last month, a California Appeals Court issued an updated opinion on the Component Parts Doctrine, a lesser discussed area of products liability law.Procedural History
In the case, Uriarte v. Scott Sales Co., Cal. Ct. App. (2nd App. Dist., 1st Div. 2017), the plaintiff sued Scott Sales Co. and J.R. Simplot Company, and other defendants. The plaintiff alleged that the silica sand procured from the defendants by his employer was used as a sandblasting material, which resulted in the production of airborne toxins that caused him to develop interstitial pulmonary fibrosis and other illnesses.
The defendants moved for judgment on the pleadings on the basis of the component parts doctrine. The component parts doctrine states that, “the manufacturer of a component part is not liable for injuries caused by the finished product into which the component has been incorporated unless the component itself was defective and caused harm.”
The motion for judgment on the pleadings was granted based upon the lower court’s interpretation of the decision in Maxton v. Western States Metals (2012) 203 Cal.App.4th 81 (Maxton), which extended the reach of the component parts doctrine. After the Maxton decision, however, another California Appeals court reached an inconsistent decision in a different case, Ramos v. Brenntag Specialties, Inc. (2016) 63 Cal.4th 500, 509 (Ramos).
Here, the Appeals Court’s initial ruling remanded the case for a reversal of the two judgments on the pleadings for the defendants based upon its agreement with Ramos. The case was then appealed to the California Supreme Court, where it was stayed pending the high court’s decision in the Ramos case. The Supreme Court ruled to affirm the Appeals Court in Ramos, thus disagreeing with Maxton. This case was then remanded to the Appeals Court for a decision in light of the Ramos decision.Claims
The plaintiff’s suit claimed that he worked as a sandblaster at Lubeco, Inc. for a period of four years, and that when he and coworkers used the silica sand provided by the defendants in the manner intended, it produced toxicologically significant amounts of airborne toxic fumes and dust, which he then inhaled and was exposed to, and that he claims directly and proximately led to his significant personal injuries, and will result in the need for medical treatment, hospitalization and potentially organ transplantation as his disease progresses.
The plaintiff’s suit claims alleged negligence, negligence per se, strict liability for failure to warn, strict liability for design defect, fraudulent concealment, and breach of implied warranties.The Component Parts Doctrine
In the relevant decision rendered in Ramos, the Supreme Court explained that the Component Parts Doctrine Applies when:
(1) a supplier provides a component or raw material that is not itself defective (by virtue of a manufacturing, design, or warning defect), (2) the component or raw material is changed or transformed when incorporated through the manufacturing process into a different finished or end product, and (3) an end user of the finished product is allegedly injured by a defect in the finished product.
When the doctrine applies, it protects the manufacturer(s) of the raw material from liability for harm caused by the later transformation of the component which causes the material to become defective or harmful.
The Court of Appeals engaged in an extensive discussion distinguishing the two prior inconsistent decisions that were ultimately decided definitively by the Supreme Court. Essentially, the Appeals Court, based upon the Supreme Court’s decision, held that if a component is used in a manner that is consistent with its intended use, which is thereby foreseeable by the manufacturer, and a harm is suffered as a result of that use, then the Component Parts Doctrine does not apply. The Court discussed the fact that it was the product being used in the manner intended and not in a transformed or integrated manner here that allegedly caused the harm. Therefore, because the potential harm was foreseeable by the manufacturers, it was incumbent upon them to determine the need to warn of the potential dangers that could result as a consequence of the proper use of the product.
The judgments were thus reversed, and the lower court was ordered to render new orders consistent with the ruling.
When someone is hurt as the direct result of a product, the manufacturer or other party involved in the distribution of the product can be held responsible. If you or a family member has been seriously injured by a defective product, contact the Rubinstein Law Group to schedule a free consultation with our defective product lawyer in San Marcos.