California Supreme Court Substantially Limits Component Parts Doctrine In Recent Toxic Tort Decision

The component parts doctrine, articulated in Maxton v. Western States Metals and the Restatement 3rd of Torts – Products Liability has been an unsettled area of law over the past few years with conflicting opinions from the Court of Appeal. The component parts doctrine generally stands for the proposition that manufacturers and suppliers of component parts or raw materials integrated into an end product are shielded from liability for injuries sustained by a finished product. The California Supreme Court recently reviewed one of the conflicting opinions – Ramos v. Brenntag Specialties, Inc. – and held contrary to Maxton, that the component parts doctrine is not an applicable defense when a plaintiff claims that injury was caused by the component parts or raw materials when used in a manner intended by the defendants. This decision limits a defendant’s ability to dispose of cases by asserting the component parts doctrine as an affirmative defense to a narrow set of factual circumstances.

Plaintiff Flavio Ramos, a metal foundry worker, alleged that he developed interstitial pulmonary fibrosis due to exposure to molten metal, plaster, sand, limestone, and marble products supplied by defendants. After multiple challenges to the pleadings, the trial court sustained defendants’ demurrers without leave to amend, relying on Maxton. In Maxton, the Court of Appeals held that under the component parts doctrine, defendant suppliers could not be held liable for plaintiff’s injury which occurred from the use of the metal products cut, ground, sandblasted, welded, and brazed during the manufacturing process.

The California Supreme Court reviewing Ramos disagreed with the trial court decision, emphasizing that Ramos did not claim he suffered injuries from a defective end product into which defendants’ products had been integrated. Instead, Ramos claimed that his injuries resulted from the use of the parts themselves, as intended by defendants and in the course of the manufacturing process. As a result, the California Supreme Court, held that the component parts doctrine is not applicable to the facts as alleged by Ramos, and that the trial court erred in sustaining defendants’ demurrer.

This Supreme Court’s decision substantially limits the application of the component parts doctrine. Prior to this decision, defendants could rely on Maxton to support an affirmative defense based on the component parts doctrine when a plaintiff’s alleged injuries occurred during the manufacturing process. The Ramos decision prohibits the broad application of the component parts doctrine, and only allows for application of this defense in the narrow circumstances where a plaintiff specifically claims injury resulting from the finished defective product over which defendants had no control. So long as a plaintiff claims that the injuries were caused by the component parts themselves when used as intended during the manufacturing process, defendants will no longer be able to effectively assert the components parts doctrine as an affirmative defense.