Component Parts Doctrine at Risk of Melting Away in California


The California Supreme Court is scheduled to hear oral arguments inRamos v. Brenntag Specialties, Inc. (2014) 224 Cal.App.4th 1239, review granted July 9, 2014 (Ramos) after granting review in a case involving the component parts doctrine. In Ramos, the Supreme Court granted the defendants' petitions for review of the Court of Appeal's decision reversing the trial court's order sustaining their demurrer without leave to amend.

Ramos alleged that Mr. Ramos developed interstitial pulmonary fibrosis as the result of his exposure to fumes from the molten metal and dust from the plaster, sand, limestone and marble while working at Supreme Casting & Pattern Inc., a manufacturer of aluminum castings, between 1981 and 2009.

The trial court sustained the demurrer brought by several defendants based on Maxton v. Western States Metals(2012) 203 Cal.App.4th 81 (Maxton), which established the component parts doctrine in California that shielded suppliers of raw materials other than inherently dangerous substances such as asbestos from liability in cases brought by workers alleging personal injury while using the raw materials during the manufacturing process.

On appeal, the Ramos Court reversed the trial court's order by disagreeing with Maxton. The Court specifically held that "the component parts doctrine does not shield a product supplier from liability when a party alleges that he suffered direct injury from using the supplier's product as the supplier specifically intended." (Ramos, 224 Cal.App.4th at p. 1243.) The Court found that the injuries alleged in the operative complaint fell outside the doctrine's rationale because he alleged he was injured from using the products as opposed to from a defective "integrative product" that included the defendants' products.

The various petitions for review filed by the defendants sought review given the intra-district split regarding the scope of the component parts doctrine. Maxton was decided by Division Three of the Second Appellate District while Ramoswas decided by Division Four of the same district. Subsequently, the opening briefs filed by the defendants expounded on this argument, noting among other things, that the Ramos decision was in direct conflict to prior California decisions including Maxton as well as courts around the country who have implemented various versions of the component parts doctrine based on the Restatement Third of Torts, Products Liability.

Poole Shaffery successfully represented Western States Metals, the lead defendant in Maxton, throughout the course of litigation including defending the trial court's order sustaining Western States Metals' demurrer at both the Court of Appeal and Supreme Court.

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