Products Liability Alert: Maxton v. Western States Metals
California Holds the Line on The Component Parts Doctrine: Raw materials suppliers are not liable for negligence or strict liability for injuries sustained when working non-defective raw materials into finished product.
Raw material suppliers and component manufacturers should take comfort in California's reaffirmation of the Component Part Doctrine. California's Second Appellate District applied the Component Part Doctrine in holding that absent extraordinary circumstances, a plaintiff cannot maintain an action in negligence or strict liability against a defendant who supplied plaintiff's employer with raw materials that are capable of being used in "innumerable ways." Maxton v. Western States Metals, No. B227000, 2012 WL 286798 (Cal. Ct. App. Feb. 1, 2012).
Plaintiff in Maxton claimed to have suffered injuries from breathing "toxic airborne fumes and dusts" as a result of working with metals supplied by defendants. Plaintiff claimed that the metals were "inherently dangerous products" when used as intended and that defendants "fraudulently concealed the toxic hazards of their products." Plaintiff asserted causes of action for negligence as well as strict liability.
The Court denied liability citing the Component Parts Doctrine. The Component Parts Doctrine states that a component manufacturer cannot be held liable for injuries caused by a finished product that incorporates its component unless the component itself is somehow defective and caused harm. O'Neil v. Crane Co.(2012) 53 Cal.4th 335, __ ; Restatement Third of Torts, Product Liability § 5.
The Component Parts Doctrine is most easily recognizable where injury results from the failure of a non-defective component part as a result of its having been improperly incorporated into a finished product. In re TMJ Implants Products Liability Litigation (8th Cir. 1996) 97 F.3d 1050. In In re TMJ the supplier of otherwise non-defective Teflon was not liable for the defective design of artificial joints that improperly incorporated the Teflon even though the ultimate use was foreseeable. Id. at 1058
Maxton looked to equity and the doctrine's underlying public policy, holding that it is unreasonable and unnecessary to hold a component manufacturer liable for the range of known and unknown uses its customers may make of its products. To do so would require the manufacturer to become or hire an expert in all those possible uses. Maxton, supra, 2012 WL 286798 at *3. The court reasoned that where the Component Parts Doctrine applies, there can be no negligence because there is no duty and public policy neither requires nor permits application of strict liability.
In determining whether the Component Parts Doctrine applies, the Maxton Court looked for the presence of four factors laid out in Artiglio v. Gen. Elec. Co., 61 Cal. App. 4th 830, 840, (1998): (1) is the raw material inherently dangerous; (2) is the user of the raw material a sophisticated buyer, aware of the possible hazards of using the material; (3) were the materials substantially processed by the buyer; and (4) was the supplier involved in designing and developing the buyer's product that incorporated the raw material.
Maxton applied a narrow definition of inherently dangerous, noting that in this context the only raw material California case law has recognized as inherently dangerous is asbestos. Maxton, supra, 2012 WL 286798 at *1. The Court distinguished the raw [metal] in this case from inherently dangerous materials, reasoning that the injury was not caused "simply by handling the [metal] material." Maxton, supra, 2012 WL 286798 at *6. The Court determined that plaintiff was injured as a result of the manufacturing process not from the metal itself. "The metal products in this case were not dangerous when they left defendants' control. They only became dangerous because of the manufacturing process controlled by Maxton's employer." Id.
The Court also found that the buyer, plaintiff's employer, was a "sophisticated industrial enterprise" that had been purchasing "hundreds of different kinds of metal" for over 30 years. Id. The metals had clearly been substantially processed by the buyer – it was melted, cut, ground, polished, sanded, machined and soldered – and the supplier had no role in developing or designing the buyer's end products.
Having met the Artiglio factors, Maxton further noted that manufacturers can still be liable when their products are defective. Id. at *7. The Court, however, dismissed plaintiff's claim that the metal was defective. It held that metal is more akin to raw materials than finished components, and "[r]aw materials generally cannot by themselves be defective unless they are contaminated." Plaintiff did not allege the metal was contaminated. Maxton, supra 2012 WL 2867898 at *7.
Maxton is consistent with earlier precedent that hold a raw materials supplier can only be liable for injuries where it has some control over the instrumentality that caused the injury. Either the component was inherently dangerous, the component was defective and caused the injury, or the supplier was somehow involved in designing the subsequent product or process that used the component and that product or process resulted in injury.