Division Four of the Second Appellate District of the California Court of Appeal recently ruled that product manufacturers could be held liable for injuries to a customer’s employee allegedly caused by their raw materials. In Ramos v. Brenntag Specialties, Inc., Cal.Ct.App.4th Div., No. B248038, the court made a distinction that the “component parts doctrine” does not shield product manufacturers from liability when the defendant’s raw materials were used as intended. Just two years ago, in Maxton v. Western States Metals, 203 Cal.App.4th 81 (2012), Division Three of the same District Court of Appeal held that a defendant who simply supplies raw materials for use in its customer’s manufacturing processes may not be sued by the customer’s employee for injuries allegedly sustained as a result of exposure to the defendant’s raw materials during the manufacturing process. This split of authority potentially weakens the component parts doctrine.
The underlying facts of Ramos and Maxton are fairly similar, amplifying the resulting conflict of authority on the component parts doctrine. Both the plaintiffs, Flavio Ramos and John Maxton, allegedly suffered from interstitial pulmonary fibrosis as a result of their respective employment. Ramos worked as a mold maker, machine operator and laborer for Supreme Casting & Pattern, Inc. Ramos was allegedly exposed to dust from the defendants’ raw materials, such as marble, sand, limestone, plaster and metal, when the materials were used in the process of molding and casting metal parts. Ramos was also allegedly exposed to fumes from molten metal. Similarly, Maxton alleged that he was exposed to fumes and metallic dusts from the “melting, cutting, grinding, polishing, sanding, sandblasting, machining and soldering” of the defendants’ stainless steel bars and other raw materials he worked with as a laborer for LeFiell Manufacturing.
The defendants in both Ramos and Maxton filed demurrers to the respective complaints based on the component parts doctrine. In Maxton, the trial court sustained the demurrers and the appellate court affirmed, holding that "[i]mposing liability on suppliers of product components would force them to scrutinize the buyer-manufacturer's manufacturing process and end products in order to reduce their exposure to lawsuits." The panel further ruled that "[t]his would require many suppliers to retain experts in a huge variety of areas, especially if the product components are versatile raw materials. Courts generally do not impose this onerous burden on suppliers of product components because the buyer-manufacturers are in a better position to guarantee the safety of the manufacturing process and the end product." Maxton, 203 Cal.App.4th at 89.
While the trial court sustained the defendants’ demurrers under Maxton in Ramos, the appellate court disagreed with the Maxton interpretation of the component parts doctrine. In a departure from the court’s ruling in Maxton, which predominantly relied on portions of the Restatement Third of Torts: Products Liability § 5 and on Artiglio v. General Electric Co., 61 Cal.App.4th 830 (1998), the Ramos court cited to cases that declined to apply the component parts doctrine, including a number of cases from other jurisdictions, such as Texas, Ohio, New York, New Jersey, Louisiana, Pennsylvania, and the Fourth and Sixth Circuit Courts of Appeals.
Distinguishing the Ramos complaint as alleging a direct injury from the intended use of the defendants’ products as opposed to “any finished product, manufacturing system into which the products were integrated, or apparatus built to the employer’s specifications,” the panel held that “the component parts doctrine does not shield a product supplier from liability when a party alleges that he suffered direct injury from using the supplier’s product as the supplier specifically intended.”
The Ramos decision is a stark departure from the holding of Maxton and results in a palpable conflict of authority between the two divisions of the same district of the Court of Appeal on the “components parts doctrine.” It remains to be seen what the lasting impact of this split of authority will be. Ultimately, the California Supreme Court will likely have to weigh in to resolve the conflict and clarify the extent to which product manufacturers can successfully assert the component parts doctrine as a defense to liability.