Maxton v. Western States Metals
Feb. 1, 2012
Cal. Court of Appeal (Second Dist., Div. Three)
2012 DJDAR 1320
The Court of Appeal affirmed the trial court ruling that a worker, who claimed to have suffered pulmonary fibrosis as a result of exposure to toxic fumes and dust during a manufacturing process, could not sue suppliers of steel, aluminum, and other raw materials.
The Court reviewed the Component Parts Doctrine as set forth in the Restatement Third of Torts. The doctrine allows liability of a supplier which provides a defective component, or substantially participates in the integration of the component into the design of the product, which causes the product to be defective, and causes harm.
The Court then reviewed the 1998 Artiglio case factors in which that California Court of Appeal described circumstances where a supplier would not be liable to the ultimate consumer (the Restatement Third was just in draft form then): the component is not inherently defective, the materials are sold to a sophisticated buyer, the material is substantially changed during the manufacturing process, and the supplier has a limited role in developing and designing the end product.
The Court then distinguished the present case from those which subjected suppliers of asbestos to liability because asbestos is inherently dangerous, both before and after integration into the product. The Court found this case more like those where kerosene, sulphuric acid, silicone, and the like, were used, and where no liability was found because the supplier was in no position to oversee how its product was used or what it might be compounded with. Also, those components were not inherently defective.
As a matter of public policy, it would be overly burdensome and inequitable for a supplier to have to assemble a team of experts to assess how its components would be handled by a manufacturer which could result in many different end-products. The manufacturer is in the best position to do so.
The Component Parts Doctrine applies to negligence as well as strict liability. The result here was that the suppliers owed no duty to the worker, and the case was dismissed.