In O’Neil v. Crane Co., 266 P.3d 987 (Cal. 2012), the California Supreme Court rejected an argument by plaintiff that a defendant manufacturer of valves and pumps used on a ship should be held strictly liable because it was foreseeable that the products would be used with replacement parts manufactured by others that incorporated asbestos.  The court held that a product manufacturer may not be held liable in strict liability or negligence for harm caused by another manufacturer’s product unless the defendants’ own product contributed substantially to the harm or the defendant participated substantially in creating a harmful combined use of the products.  The court further held that, if adopted, plaintiff’s claims would expand strict products liability in an unprecedented fashion.  As a practical matter, this holding limits the ability of plaintiffs to extend liability for asbestos-related disease caused by the products of now-bankrupt manufacturers of asbestos-related products to manufacturers whose products were used in conjunction with bankrupt manufacturer’s products.