Daily Blast March 21, 2014

New CA Court of Appeal Opinion Re: Component Parts Doctrine

The California Court of Appeal, Second Appellate District, Division Four (Los Angeles) issued an opinion in Ramos v. Brenntag Specialties, Inc. (Mar. 21, 2014, B248038) __ Cal.App.4th __, analyzing the components parts doctrine in a products liability action. The Court of Appeal held that “the components parts doctrine does not shield a product supplier from liability when a party alleges that he suffered direct injury from using the supplier’s product as the supplier specifically intended.” (Slip opn., p. 3.)

The case arose from injuries suffered by plaintiff Flavio Ramos (“Ramos”) during his employment as a mold maker, machine operator and laborer for Supreme Casting & Pattern, Inc. (“Supreme”). Supreme manufactured metal parts through “a foundry and fabrication process.” (Slip opn., pp. 3-4.) While employed by Supreme, Ramos worked “with and around” metals, plaster and minerals that defendants supplied to Supreme. Ramos sued defendants metal suppliers and mold material suppliers for negligence, negligence per se, strict liability based on failure to warn and design defects, fraudulent concealment, and breach of implied warranties. (Id. at p. 3.) Ramos alleged he developed interstitial pulmonary fibrosis as the result of his exposure to fumes from the molten metal and dust from the plaster, sand, limestone and marble supplied by the defendants. (Id. at p. 4.) Defendants demurred to the claims on the ground that they failed under the component parts doctrine as applied Maxton v. Western States Metals (2012) 203 Cal.App.4th 81 (“Maxton”). (Slip opn., pp. 3-5.) The trial court agreed and sustained defendants’ demurrers without leave to amend. (Id. at p. 5.)

The Court of Appeal reversed. The court held that “the component parts doctrine applies to harm caused by ‘finished [products]’ into which the supplier’s product has been incorporated.” (Slip opn., p. 20, citations omitted.) The doctrine “does not target claims by a party alleging that he suffered a direct injury from using a product as the supplier specifically intended.” (Id. at pp. 20-21.) The court explained that “[although] the doctrine may be invoked when a worker suffers injury while engaged in employment that incorporates or uses a supplier’s component part, its application has ordinarily been restricted to situations in which the injuries were attributable to an item over which the supplier lacked material control, such as the employer’s manufacturing system itself (viewed as the “finished product”), or to some other element of the system, rather than to the supplier’s component part.” (Id. at p. 21.) Here, Ramos alleged a direct injury from the intended use of the defendants’ products―not from any finished product, manufacturing system into which the products were integrated, or apparatus built to the employer’s specifications. (Ibid.) Thus, the component parts doctrine did not apply. The court disagreed with Maxton to extent it could be read to conclude that the component parts doctrine applied in this case. (Id. at p. 20.)

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