Daily Blast June 23, 2016

The California Supreme Court this morning filed its opinion in Ramos v. Brenntag Specialties, Inc. (June 23, 2016, S218176) __ Cal.4th __, addressing the following issue: Are negligence and strict liability causes of action by an employee of a processing company against a supplier of raw materials for injuries allegedly suffered in the course of processing those materials barred by the component parts doctrine? The court held that “the protection afforded to defendants by the component parts doctrine does not apply when the product supplied has not been incorporated into a different finished or end product but instead, . . . , itself allegedly causes injury when used in the manner intended by the product supplier.” (Slip opn., p. 2.)

Plaintiffs, Ramos, a metal foundry worker, and his wife, sued defendants, suppliers of metals, plaster, and minerals that were used in the foundry’s manufacturing process, for negligence, negligence per se, strict liability, and loss of consortium. Plaintiffs alleged that exposure to the suppliers’ products, when used in their intended fashion, produced harmful fumes and dust that caused Ramos’s pulmonary fibrosis. (Slip opn., p. 1.) The trial court sustained the suppliers’ demurrer without leave to amend based upon the component parts doctrine and Maxton v. Western States Metals (2012) 203 Cal.App.4th 81 (“Maxton”), which held that suppliers of non-defective raw materials are not liable for injuries caused by the manufacturing process of that raw material. The Court of Appeal reversed, holding that the components parts doctrine did not apply because the injury was not caused by a finished product into which the supplied product had been incorporated, but instead by the supplied product itself when used in an intended fashion. The Supreme Court granted review. (Slip opn., p. 2.)

The Court held that the component parts doctrine did not apply: “Here, Ramos’s injury was not caused by a finished product into which the materials supplied by defendants had been transformed and integrated, and thus the explanation and considerations set forth in comment a to section 5 of the Restatement Third of Torts are not applicable. Instead, the injury was allegedly caused directly by the materials themselves when used in a manner intended by the suppliers. According to the allegations of the complaint, defendants did not have to guess or speculate about the type of use to which their materials would be put, but rather defendants were aware of and intended that the materials they supplied would be used in the manner in which the materials were actually used. The component parts doctrine (and the protection it affords to suppliers) is not addressed to such circumstances, . . . .” (Slip opn., pp. 8-9.) The court disapproved of Maxton to the extent it was inconsistent with the court’s opinion. (Id. at p. 9.)

The court emphasized the “limited scope” of its decision. (Slip opn., p. 9.) The court did not address the applicability or scope of products liability doctrines other than the component parts doctrine. The court explained that to prevail on their strict products liability cause of action, plaintiffs must establish either: (1) the products supplied by defendants were defective by virtue of a design defect and that the defect caused plaintiffs’ injury or (2) defendants breached a duty to provide adequate warnings of the dangers posed by the materials defendants supplied to Supreme Castings and that such failure to warn caused plaintiffs’ injury. (Ibid.) Additionally, as to the duty to warn, defendants could rely upon the employer to adequately warn its employees of the dangers posed by the products. These issues would have to be decided upon remand. (Id. at p. 10.)