New Appellate Decision May Weaken the Application of the Component Parts Doctrine


There are now conflicting appellate court opinions as to whether or not, under the component parts doctrine, a defendant who merely supplies raw materials for use in its customer's manufacturing processes may be sued by the customer's employee for injuries allegedly sustained as a result of exposure to the raw materials during those manufacturing processes. In 2012 Division Three of the Second District Court of Appeal answered this question in the negative, in Maxton v. Western States Metals (2012) 203 Cal.App.4th 81. However, last month Division Four of the same court reached the opposite result in Ramos v. Brenntag Specialties, Inc. (Cal. Ct. App. 4th, Div., No. B248038). The resulting conflict may weaken the application of the component parts doctrine.

In Maxton, the trial court had sustained demurrers to the complaint based on its reading of the component parts doctrine. The appellate court affirmed the trial court's order, holding that a worker injured as a result of his employer's manufacturing process could not sue the suppliers of the raw materials used in those processes, so long as certain factors were present. The rationale for this decision was that, where certain factors are present, the employer, not the raw materials supplier, is in the best position, as a matter of public policy, to determine how raw materials will be purchased and safely used in its manufacturing processes.

In Ramos, the appellate court reversed the trial court's order sustaining similar demurrers that also were based on the component parts doctrine under Maxton. The Ramos court flatly disagreed with the Maxton decision, and refused to apply its holding. Instead, the Ramos court held that suppliers of raw materials may be held liable if those materials cause injury to a worker when used as intended in the manufacturer's manufacturing processes.

The facts of these two cases are very similar. John Maxton and Flavio Ramos both suffered from interstitial pulmonary fibrosis. Mr. Maxton worked for his employer as a laborer, a job in which he allegedly was exposed to metallic dusts and fumes arising from the "melting, cutting, grinding, polishing, sanding, sandblasting, machining and soldering" of the defendants' stainless steel bars and other raw materials. Mr. Ramos worked for his employer as a mold maker, machine operator and laborer, jobs which allegedly exposed him to fumes from molten metal, and to dust from the defendants' raw materials (in this case, metal, plaster, sand, limestone, and marble), when they were used in the process of molding and casting metal parts. In both cases, the defendants' raw materials were sold to commercial buyers. In both cases, the raw materials were significantly altered by the employer's manufacturing processes. In both cases, the plaintiffs alleged that the defendants' raw materials were used as intended, and that when so used they caused the plaintiffs' injuries. However, in neither case did the defendants have any control over the employer's manufacturing processes.

However similar the facts of these two cases were, the resulting decisions could not have been more different. The Maxton court carefully analyzed the origin and underlying case law of the component parts doctrine, focusing particular attention on the provisions and comments of Restatement Third of Torts: Products Liability § 5, and on the factors discussed in Artiglio v. General Electric Co (1998) 61 Cal.App.4th 830, to wit: (1) the raw materials were not inherently dangerous when they left the defendants' control, (2) the raw materials were sold to a sophisticated buyer, (3) the raw materials were substantially changed during the employer's manufacturing process, and (4) the defendants did not exercise any significant control over the manufacturing process. In Maxton, the appellate court found that all four of the Artiglio factors were satisfied by the allegations of the complaint, and affirmed the trial court's order of dismissal.

By contrast, the analysis of Ramos court began, somewhat dogmatically, with the general principle that manufacturers have a duty to warn consumers about the hazards inherent in their products. The court acknowledged the existence of the component parts doctrine, and of the analyses in both Artiglio and Maxton, but it focused most of its attention on cases, including out-of-state cases, in which courts declined to apply the component parts doctrine to cases involving injured workers such as Mr. Maxton and Mr. Ramos. The Ramos court seems to have gone out of its way to follow those cases, and to avoid following Maxton. Its discussion of the Artiglio factors was cursory at best, and it never discussed the public policy reasons behind the Maxton decision.

It is clear that the Ramos court disliked the result in Maxton. The two decisions, by different divisions within the same appellate district, cannot be harmonized. The Ramos decision is not yet final, and it remains to be seen whether the California Supreme Court will be asked to resolve the conflict. However, until the conflict is resolved, the application of the component parts doctrine is likely to be weakened at every level, from pleading challenges,, to dispositive motions, to jury instructions at trial.

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