On July 9, 2013, the Second Appellate District of California handed down an opinion curtailing the pursuits of plaintiffs attempting to inflate their claims by dragging in manufacturers of products used in conjunction with, or in proximity of, an injurious product manufactured by another company. In Sanchez v. Hitachi Koki, Co., Ltd., B245050, 2013 WL 3423091 (Cal. Ct. App. July 9, 2013), the California Appellate Court confirmed the application of, and refused to find an exception to, the Supreme Court precedent in O’Neil v. Crane Co., 53 Cal.4th 335 (2012), regarding the absence of liability for manufacturers when their products do not substantially contribute to an injury. Through its analysis, the court also reinforced the significance of a manufacturer’s warnings and anticipation of potential hazards that could result from misuse of a product.
In Sanchez, a husband and wife sought to recover damages from Hitachi under a product liability action after the husband was injured while using a saw blade manufactured by another company in conjunction with a Hitachi grinder in his efforts to cut a truck tire. Although the saw blade, not the Hitachi grinder, actually caused the plaintiff’s injury, and the grinder’s safety instructions and manual contained specific warnings that the grinder should not be used in conjunction with saw blades due to risk of serious injury, the plaintiffs sought to impose liability on Hitachi on the basis of their contention that the grinder’s lack of kickback prevention constituted a design defect. The plaintiffs also argued that the grinder’s ability to accommodate the most common circular saw blade and the lack of warnings on the grinder itself warranted an exception from O’Neil on the grounds that the grinder itself was defective.
Rejecting the plaintiffs’ contentions, the court referred to the precedent set in O’Neil v. Crane Co. that a manufacturer may not be held liable unless its own product substantially contributes to the harm. Reasoning that the saw blade and not the grinder had actually caused the injury here, the court refused to grant an exception to the O’Neil precedent and confirmed its holding that “California law does not impose a duty to warn about dangers arising entirely from another manufacturer’s product, even if it is foreseeable that the products will be used together.” Despite the court’s confirmation that Hitachi was not obligated to provide warnings about the use of its product with a saw blade, the court repeatedly emphasized Hitachi’s explicit written warnings in asserting its lack of liability in the matter. The court also clarified that a product substantially contributes to the harm suffered by a plaintiff only where the intended use of that product inevitably results in the harm.
Sanchez provides manufacturers with the reassurance that California courts will not easily accept plaintiffs’ attempts to draw in all potential defendants, particularly those that did not specifically manufacture the allegedly injurious product. The court’s refusal in Sanchez to conduct an analysis of whether the grinder was actually defective effectively indicates that manufacturers should not bear the burden of designing their products perfectly for every possible use that consumers may attempt.
Sanchez also provides a clear illustration of the influence that explicit warnings can have in protecting defendant manufacturers from incurring liability. Although the court in Sanchez never explicitly required these warnings, its repeated emphasis of Hitachi’s warnings demonstrates the effectiveness of manufacturer foresight and planning to include warnings for potential unintended uses of their products. Sanchez seems to suggest that it may be worthwhile for manufacturers to conduct an in-depth analysis of all possible uses of their products and include warnings about such uses, or to consider including a general disclaimer that the product is only designed for its stated intended use and is not recommended for any additional uses.