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The Component Parts Doctrine as Molded by the California Supreme Court

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The component parts doctrine still remains a valid defense in California. In Ramos v. Brenntag Specialities, Inc. (June 23, 2016, S218176) __ Cal.4th __(Ramos), the California Supreme Court held that the doctrine applies in cases involving injuries allegedly caused by the finished product as opposed to during the manufacturing process. However, the Court held the doctrine does not shield suppliers of component parts or raw materials if the plaintiffs allege that the parts or raw materials themselves caused injury when used in the manner intended by the suppliers.

Ramos involved the personal injury claims of a metal foundry worker, who alleged he developed interstitial pulmonary fibrosis as a result of working with and/or around metal, plaster, and mineral products used during the foundry's manufacturing process. The defendants challenged the pleading based on the component parts doctrine as set forth inMaxton v. Western States Metals (2012) 203 Cal.App.4th 81 (Maxton), which the trial court granted. On appeal, the trial court's ruling was reversed. The California Supreme Court granted review to resolve the conflict between Ramosand Maxton.

In its opinion, the Supreme Court was careful to limit its holding to the case, i.e., "that the trial court erred in sustaining defendants' demurrer in reliance on Maxton, supra, 203 Cal.App.4th 81, and that decision's reliance on the component parts doctrine." The Supreme Court noted that the plaintiff still bore the burden of establishing either that the defendants' products were defective in design and that the defect caused his injury or that the defendants breached a duty to provide adequate warnings.

Accordingly, as it now stands, the component parts doctrine will shield suppliers of component parts or raw materials from liability in cases where the injury is allegedly caused by the finished product and not an injury allegedly caused during the manufacturing process when used in the manner intended by the suppliers.

The Ramos decision will not have a radical impact on toxic tort litigation in California. As stated several times inRamos, the Supreme Court was reviewing a decision based on a challenge to the complaint and therefore, the Court was limited to only those facts alleged within the four corners of the complaint. The clarification on the applicability of the component parts doctrine does not lessen the plaintiffs' burden in proving their claims against the defendants in toxic tort cases. The component parts doctrine is still a valid defense in California – it has just been reshaped.

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