Appellate Reports and Shorter Takes

Ramos v. Brenntag Specialties, Inc. narrows components parts doctrine

2016 August

Ramos v. Brenntag Specialties, Inc. (2016)

__ Cal.4th __ (Cal. Supreme)

Who needs to know about this case? Lawyers litigating product-liability cases

Why it’s important: Narrows the availability of the component parts doctrine, finding that the defense does not apply when the product supplied has not been incorporated into a different finished or end product, but has instead caused injury when used in the manner intended by the supplier. Disapproves Maxton v. Western States Metals (2012) 203 Cal.App.4th 81 (Maxton).

Synopsis: Plaintiff Ramos worked as mold maker and machine operator for Supreme Castings, which manufactured metal parts through a foundry and fabrication process. His complaint alleged that Ramos worked “with and around” metals, plaster, and minerals supplied to Supreme Castings by various suppliers, which were named as defendants. One group of defendants (the metal suppliers) supplied metal products that were melted in furnaces to form metal castings. Another group of defendants (mold material suppliers) supplied plaster, sand, and stone products used for making molds for the casting process. Ramos alleged that he developed interstitial pulmonary fibrosis as the result of his exposure to, among other factors, fumes from the molten metal and dust from the plaster, sand, limestone, and marble.

Relying on Maxton, the trial court sustained the defendants’ demurrer without leave to amend, finding that Ramos’s claims were barred by the component parts doctrine. The Court of Appeal reversed, disagreeing with Maxton. The Supreme Court affirmed.

The component parts doctrine applies (1) when a supplier provides a component or raw material that is not itself defective (by virtue of a manufacturing, design, or warning defect), (2) the component or raw material is changed or transformed when incorporated through the manufacturing process into a different finished or end product, and (3) an end user of the finished product is allegedly injured by a defect in the finished product. Under these circumstances, the component parts doctrine provides protection to the supplier of the component or raw material, subjecting that entity to liability for harm caused by a product into which the component has been integrated only if the supplier (1) substantially participates in the integration of the component into the design of the product; and (2) the integration of the component causes the product to be defective; and (3) the defect in the product causes the harm.

The rationale for the component parts doctrine, as articulated in the Restatement Third of Torts, section 5, is that, “it would be unjust and inefficient to impose liability solely on the ground that the manufacturer of the integrated product utilizes the component in a manner that renders the integrated product defective. Imposing liability would require the component seller to scrutinize another’s product which the component seller has no role in developing. This would require the component seller to develop sufficient sophistication to review the decisions of the business entity that is already charged with responsibility for the integrated product.”

The component parts doctrine is not applicable in the circumstances alleged by Ramos. Here, Ramos’s injury was not caused by a finished product into which the materials supplied by defendants had been transformed and integrated, and thus the explanation and considerations set forth in comment a to section 5 of the Restatement Third of Torts are not applicable. Instead, the injury was allegedly caused directly by the materials themselves when used in a manner intended by the suppliers.