California Appellate Court Limits Application of Sophisticated User Doctrine


Stepping back from broad application of the sophisticated user doctrine in product liability and toxic tort litigation, the Second District of the California Court of Appeal, recently affirmed a jury’s $21 million verdict for a Navy seaman against a manufacturer of asbestos-containing gaskets and packing, rejecting the defendant’s effort to assert the sophisticated knowledge of the plaintiff’s employer as a defense to the plaintiff’s claim. In Pfeifer v. John Crane, Inc., 2013 WL 5815509 (2nd. Dist. 2013), the defendant, John Crane, Inc. (JCI), sought to have the jury instructed that, because the Navy knew or should have known of the hazards of asbestos, the defendant had no duty to warn the plaintiff-employee of the hazards of working with the defendant’s products. The trial court denied the proposed instruction and entered a directed verdict on the sophisticated user defense against the defendant. After surveying the law in California and other jurisdictions, the Court of Appeal affirmed the trial court’s decision, signaling a potential restriction of the sophisticated user doctrine.

This article briefly summarizes Pfeifer, explains the California decision in the context of other courts’ application of the sophisticated user doctrine, and suggests potential implications for manufacturers and suppliers defending product liability and toxic tort claims.

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