Legal News

California Supreme Court Continues to Limit Liability of Product Manufacturers for Harm Caused by Another Manufacturer’s Products

On January 12, 2012, the California Supreme Court issued its long anticipated opinion in the case of O’Neil v. Crane Co. regarding the component parts defense. The case involved the claims of plaintiffs that Patrick O’Neil developed mesothelioma, which caused his death in 2005, as a result of exposure to asbestos while stationed aboard the aircraft carrier the USS Oriskany. Mr. O’Neil’s family claimed that manufacturers of pumps and valves used in the steam propulsion system were liable for Mr. O’Neil’s death because asbestos-containing gaskets and packing made and distributed by others were used in those pumps and valves and released respirable asbestos fibers when cut, installed, and removed. The O’Neils argued that the equipment manufacturers designed their equipment to be used with asbestos-containing products and that they therefore had a duty to warn about dangers associated with exposure to asbestos. The trial court granted summary judgment in favor of Crane Co. and Warren Pumps and the O’Neils appealed from those rulings. The Second District Court of Appeal found in favor of the O’Neils and the equipment manufacturers appealed that decision to the California Supreme Court.

The Supreme Court reiterated that the general rule is that a product manufacturer may not be held liable in negligence or strict liability for harm caused by another manufacturer’s product. The Court held that the only exceptions to the rule arise when the defendant bears some direct responsibility for the harm either because the defendant’s own product contributed substantially to the harm or because the defendant participated substantially in creating a harmful combined use of the products. Simply knowing that the product might be used with another potentially defective product that may cause harm does not rise to the level sufficient to impose strict liability. The Court further stated that a product manufacturer has no duty of care to prevent asbestos-related disease that might result from products supplied by others, even though they may be used with the manufacturer’s product, years after the product leaves the manufacturer’s control.

This question had been addressed by the First District Court of Appeal in Taylor v. Elliott Turbomachinery Co. (2009) 171 Cal.App.4th 564, which also held that manufacturers are not liable for harm caused by component parts manufactured or supplied by others. The Second District Court of Appeal’s decision in O’Neil had created a conflict between the jurisdictions and resulted in conflicting rulings at the trial court level. The Supreme Court’s decision resolves that conflict. The decision also certainly will result in much greater focus being placed upon premises owners, contractors, and manufacturers and suppliers of asbestos-containing products.