Court Holds Component Parts Doctrine Not Applicable to Lawsuit Against Suppliers of Materials

Publish Date:Mar 31, 2014
Summary:
In its March 21, 2014 decision in Ramos v. Brenntag, Inc., the California Court of Appeal (Second Appellate Disctrict, Division Four) reversed a trial court ruling that rejected a lawsuit brought by a foundry worker against companies that supplied metals and materials to the worker’s employer who operated the foundry.

In its March 21, 2014 decision in Ramos v. Brenntag, Inc., the California Court of Appeal (Second Appellate Disctrict, Division Four) reversed a trial court ruling that rejected a lawsuit brought by a foundry worker against companies that supplied metals and materials to the worker’s employer who operated the foundry. The Court of Appeal held that the component parts doctrine, which shields a product supplier from liability, was not applicable to the worker’s complaint.

Flavio Ramos was employed at a foundry. He worked with metals and minerals supplied by a number of companies.  Ramos developed interstitial pulmonary fibrosis.  He filed a lawsuit against the suppliers of the metal and minerals. Ramos’s complaint claimed the material suppliers failed to provide warnings of the dangers of the materials.    

The trial court dismissed Ramos’s complaint, relying on the Court of Appeal’s (Second Appellate District, Division Three) 2012 decision in Maxton v. Western States Metal.  The court in Maxton dismissed a complaint based on the component parts doctrine which generally shields suppliers of component parts that are integrated into an end product from liability for defects in the end product.

Ramos appealed the trial court’s dismissal of his complaint. The Court of Appeal reversed the trial court’s dismissal.

Ramos’s complaint pleaded that the suppliers knew, or should have known, of the hazards of their products when used as intended in the metal casting process and that users like Ramos were unlikely to discover those hazards on their own. The Court of Appeal concluded that this pleading was adequate for a defective warning claim and should not have been dismissed.

In addition, the court ruled that the component parts doctrine did not apply to Ramos’s complaint. The court’s opinion states that “insofar as Maxton determined that the component parts doctrine is applicable to claims of the type alleged in [Ramos’s complaint], we respectfully disagree.”

A copy of the Court of Appeal’s opinion is available at www.courts.ca.gov        


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