On June 13, 2014, the California Court of Appeal (Second Appellate District, Division One) ruled in Uriate v. Scott Sales Co.
that the component parts doctrine did not bar a worker’s lawsuit against manufacturers of material that went into the finished products made by the worker’s employer.
California courts have accepted the component parts doctrine. The doctrine provides that a manufacturer of a component part is not liable for injuries caused by the finished product into which the component part has been incorporated unless the component itself was defective and caused harm.
Scott Sales Co. and J.R. Simplot Company supplied silica sand to Lubeco Inc. The silica sand was used in the process to produce Lubeco’s finished products.
Francisco Uriate was employed as a sandblaster by Lubeco. Uriate filed a lawsuit against Scott and Simplot alleging claims for negligence and strict liability for failure to warn. Uriate claimed that he developed pulmonary fibrosis caused by his exposure to the companies’ silica sand.
The trial court entered a judgment in favor of Scott and Simplot, relying on the Court of Appeal’s 2012 decision in Maxton v. Western States Metals which held that the component parts doctrine barred a lawsuit similar to the lawsuit filed by Uriate.
The Court of Appeal concluded that the trial court’s reliance on the component parts doctrine was a mistake. The court explained, “Here, Uriate does not allege that the silica sand supplied by Scott and Simplot was incorporated into finished products that caused him harm --- he does not allege that his injuries were caused by Lubeco’s finished products at all. Rather, he alleges that Scott’s and Simplot’s silica sand was used in the manner intended by Scott and Simplot, and that he was injured in the course of that process by that intended use of the silica sand. The component parts doctrine therefore does not apply.”
The court noted that its decision is consistent with the Court of Appeal’s decision in Ramos v. Brenntag, Inc. which was summarized in the March 28, 2014, ACIC Weekly Report. Both the Ramos and the Uriate rulings expressly reject the Maxton court’s position on the component parts doctrine.
A copy of the Court of Appeal’s opinion in the Uriate case is available at www.courts.ca.gov