No Liability for Raw Materials Under the Component Parts Doctrine


The California Court of Appeal has reinforced a series of prior decisions, finding that a supplier of raw materials cannot be held liable under theories of negligence and strict product liability for injuries claimed to arise from the use of such raw materials in the manufacture of finished goods.

In Maxton v. Western States Metals, et al., No. B227000 (Cal. Ct. App., 2d Dist., 2/1/12), the plaintiff alleged personal injuries, resulting from his manufacturing work with raw metal products provided by the defendants. Specifically, the plaintiff alleged that he was exposed to "toxicologically significant amounts of toxic fumes and dust" in his work with the raw materials and that the defendants failed to warn of and fraudulently concealed this hazard. In ruling on demurrers and motions for judgment on the pleadings, the trial court found that these assertions failed to state facts sufficient to state a cause of action against such raw materials suppliers.

The Court of Appeal agreed, relying primarily on the Component Parts Doctrine, as expressed in Section 5 of the Restatement Third of Torts, Product Liability, and its analysis, as expressed in Artigilio v General Electric Company (1998) 61 Cal.App.4th 830.

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