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Component Parts Doctrine Defense Continues to Solidify

2010 | Topic: Product Liability

Recent California appellate court decisions have affirmed that component parts manufacturers cannot be successfully sued in this state for strict products liability simply because a finished product incorporates their component.

For example, in Walton v. William Powell Company, 183 Cal.App. 4th 1470 (April 22, 2010), the Second District Court of Appeal held that a manufacturer of valves used in a Navy carrier's propulsion system could not be held strictly liable for failure to warn or design defect caused by asbestos-containing parts used in the propulsion system where the injury-producing components of the system were not linked in the stream of commerce with the defendant component part manufacturer. The Court reasoned that a non-defective component part in an injury-causing shipboard propulsion or heating system was not, by itself, sufficient to trigger a duty to warn. Instead, the plaintiff must show that the component part manufacturer participated in the integration of the component into the design of the system. “[F]oreseeability alone does not warrant imposition of strict liability when … the upshot of the imposition would be to require the component manufacturer to retain ‘an expert in every finished product manufacturer’s line of business and second-guess the finished product manufacturer whenever any of its employees received any information about any potential problem,” the court said.

In Flores v. Kaman Industrial Technologies Corp., 2010 Cal.App. Unpub. LEXIS 3454 (May 12, 2010), the Fifth District Court of Appeal issued an unpublished decision, affirming summary judgment in favor of a defendant component part manufacturer that had been sued for injuries sustained by a plaintiff using a conveyor belt system. Kaman supplied the motor and gearbox for the system, but plaintiff’s hand was not caught in either of those components. Kaman did not participate in the design or assembly of the conveyor belt system. Further, there was no showing that Kaman’s component part was defective. The court found that plaintiff failed to successfully counter Kaman’s showing that plaintiff could not establish essential elements of his causes of action.