On July 9, 2014, the California Supreme Court agreed to review Division Four of the Second Appellate District of the California Court of Appeal’s ruling in Ramos v. Brenntag Specialties, Inc., Case No. B248038 (CA Dist. 2 Ct. App., Mar. 21, 2014) involving the component part doctrine. The components parts doctrine shields raw material suppliers from liability for defects in the finished products sold by downstream manufacturers. Review of the Ramos decision could resolve some conflicting appellate court decisions from the same district. (See e.g. Maxton v. Western States Metals (2012) 203 Cal.App.4th 81)
In Maxton, plaintiff alleged that during the course of his and his co-workers use of metal products, in cutting, grinding, sandblasting, welding, brazing and other metal processes that he was exposed to and inhaled toxicologically significant amounts of toxic fumes and dusts that caused him to develop interstitial pulmonary fibrosis and other injuries.
Maxton sued and the defendants filed demurrers challenging plaintiff’s lawsuit on the grounds that his case was barred by the components parts doctrine. The trial court sustained the demurrers and granted the demurrers. Plaintiff appealed.
In upholding the lower court’s ruling, Division Three of the Second Appellate District of the California Court of Appeals applied the four factors articulated in Artiglio v. General Electric Co. (1998) 61 Cal.App.4th 830 to the Maxton case: “[C]omponent and raw material suppliers are not liable to ultimate consumers when the goods or material they supply are not inherently dangerous, they sell goods or material in bulk to a sophisticated buyer, the material is substantially changed during the manufacturing process and the supplier has a limited role in developing and designing the end product. When these factors exist, the social cost of imposing a duty to the ultimate consumers far exceeds any additional protection provided to consumers.”
The Court of Appeals determined that all of the factors were present and affirmed the lower court’s ruling.
Conversely, in Ramos, the Court of Appeals reached a different result under similar facts as Maxton. Plaintiff alleged that during the course of his and his co-workers use of metal, plaster and mineral products, fumes from the molten metal and dust from the plaster, sand, limestone and marble he developed interstitial pulmonary fibrosis. The defendants challenged plaintiff’s claims under the components parts doctrine as articulated by Maxton. The trial court sustained the defendants’ demurrers and plaintiff appealed.
The Court of Appeal reversed the trial court’s order sustaining demurrers. The Ramos court expressly disagreed with the Maxton decision and held: “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.”
Given the conflict of authority between Division Four (Ramos) and Division Three (Maxton) of the Second Appellate District of the California Court of Appeals it is no surprise that the Supreme Court agreed to review the Ramos decision. Review of the Ramos decision could clarify which situations the components parts doctrine can be asserted as a defense by raw material suppliers.