This month, the California Court of Appeal, Second Appellate Division, yet again, reversed a Santa Clarita trial court's order based on the component parts doctrine, which granted defendants' motion for judgment on the pleading and ultimately dismissed defendant in a toxic tort case filed by a plaintiff alleging occupational exposure to silica sand and other airborne toxins.
In Uriarte v. Scott Sales Co., et al. (Cal. Ct. App., 1st Div., No. B244257) , plaintiff, Francisco Uriarte, alleged he developed interstitial pulmonary fibrosis, a respiratory illness, as a result of occupational exposure to silica sand and other airborne toxins during his four-year employment as a sandblaster. Defendants, J.R. Simplot Company and Scott Sales Co., who plaintiff alleged supplied silica sand to his employer, successfully moved for judgment on the pleadings on the basis of the component parts doctrine, arguing that manufacturers of a component part are not liable for injuries caused by the finished product which the component has been incorporated unless the component itself is defective and caused the harm. (O'Neil v. Crane Co. (2012) 53 Cal.4th 355, 355.)
On appeal, the appellate court reversed the trial court's ruling that the component parts doctrine did not apply to the facts of Mr. Uriarte's case. The appellate court concluded that plaintiff's injuries were caused by the use of silica sand during the manufacturing process, not by the finished product that was produced by the process. Accordingly, the component parts doctrine did not apply.
In reversing the decision, the appellate court also indicated that they join in the decision in Ramos v. Brenntag Specialties, Inc. (Cal. Ct. App., 4th Div., No. B248038) ("Ramos), which disagreed with the interpretation and application of the component parts doctrine articulated in
Maxton v. Western States Metals (2012) 203 Cal. App. 4th 81. In
Ramos, the appellate court ruled that suppliers of component parts and raw materials may be held liable if those materials caused injury to a worker when used as intended in his employer's manufacturing process.
Ramos was contrary to
Maxton, which states that a worker injured as a result of his employer's manufacturing process could not sue the suppliers of the raw materials used in that process, so long as certain factors were satisfied. The rationale for this decision was that the employer, not the raw materials supplier, is in the best position to determine how raw materials will be safely used in its manufacturing processes.
While this is the second decision within the last few months to disagree with the interpretation of the component parts doctrine set forth in Maxton,
Maxton has yet to be overruled. Based on the appellate court decisions, it appears that decisions based on the component parts doctrine will come down to the facts of each case.