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Application of the Components Parts Doctrine in Hands of California Supreme Court

8/27/14 | Topic: Product Liability

The California Supreme Court recently granted review of Ramos v. Brenntag Specialties, Inc. (2014) 224 Cal.App.4th 1239, a case involving California’s Components Parts Doctrine.  The significance of the Supremes considering Ramos is that its decision will resolve a split of opinion on the doctrine’s application in the Second Appellate District.  The facts of Ramos are substantially similar to another Second Appellate District case, Maxton v. Western States Metals (2012) 203 Cal.App.4th 81, yet the Court’s decisions in the two cases are polar opposites. The Ramos court drew a distinction between products used in the manufacturing process versus end products sold to consumers.

By way of background, the Component Parts Doctrine is a compilation of several lines of cases that discuss the liability of component part manufacturers in various scenarios.  The cases, when taken together, “establish that component and raw material suppliers are not liable to ultimate consumers” if certain factors are in place.  (Artiglio v. General Electric (1998) 61 Cal.App.4th 830, 839.)  Namely, component part manufacturers “are not liable to ultimate consumers when the goods or material they supply are not inherently dangerous, they sell goods or material in bulk 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.”  (Artiglio, supra, 61 Cal.App.4th at 839.)  Essentially, the “doctrine provides 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 harmed.”  (Maxton, supra, 203 Cal.App.4th at 88 citing and quoting O’Neil v. Crane Co. (2012) 53 Cal.4th 335, 355.)

The reason behind the Doctrine is that imposing liability on a component part manufacturer, who has little to no input into the final product’s design and manufacture, would impose too great a burden on the component part manufacturer.  (Artiglio, supra, 61 Cal.App.4th at 837; see also Maxton, supra, 203 Cal.App.4th at 88.)

Maxton and Ramos were both workers in manufacturing plants.  Both sustained injuries allegedly as a result of being exposed to raw materials used at the plant to manufacture end products.  Both sued the raw material suppliers claiming their products caused their injuries.  Trial Courts in both cases entered judgment in favor of the raw material suppliers, relying upon the Components Parts Doctrine.  Both plaintiffs appealed.

The Second Appellate District, applying the Artiglio factors, affirmed judgment for the raw material suppliers in Maxton.  However, just two years later, the Second Appellate District reversed judgment in Ramos, holding that the Components Parts Doctrine applies to ultimate end-users, but it does not shield a component parts manufacturer from liability when the plaintiff alleges direct injury from their products during the manufacturing process.  (Ramos, supra, 224 Cal.App.4th at 1243.)

Those that practice in the products liability arena in California are wondering whether the Component Parts Doctrine survives or plunders, or whether its existence will be somewhere in between.  More to come for raw material/component parts manufacturers in the coming months.  Opening briefs are due in September 2014.