By Susan Engstrom
In a wrongful death action brought by the widow of an individual who was killed when his clothing became caught in a spinning universal joint on a dump truck, a Massachusetts appeals court determined that the manufacturers of the component parts that powered the U-joint did not have a duty to warn installers and end users of the dangers posed by the use of unguarded auxiliary drive shafts and U-joints. The potential dangers had arisen from the assembly of the component parts into the finished auxiliary power system, and it was undisputed that the components themselves were not defective. Therefore, the "component parts" doctrine relieved the manufacturers of a duty to warn about the risks presented by the completed system (Pantazis v. Mack Trucks, Inc., November 27, 2017, Milkey, J.).
Mark Fidrych, a former Major League Baseball pitcher for the Detroit Tigers, owned a dump truck that he used to haul soil on his farm. In April 2009, he was found dead underneath the vehicle, with his clothing caught up in a spinning U-joint that was part of the mechanical system used to tilt the "dump body" of the truck. The medical examiner determined that the cause of his death was accidental asphyxiation. His widow filed a wrongful death action against Mack Trucks, Inc., which had manufactured the original, stripped-down version of the truck, and Parker-Hannifin Corporation, which had acquired the assets of Dana Corporation, the manufacturer of a piece of equipment known as a "power take-off" (PTO). The PTO was another part of the system used to tilt the dump body of the truck. The manufacturers moved for summary judgment.
The dump truck. The owner had purchased the truck as an "incomplete vehicle," meaning that it lacked the essential components necessary to carry out its ultimate intended function. The truck subsequently was transformed into a dump truck, which involved installing a dump body as well as a mechanical system (auxiliary power system) for tilting that body. The auxiliary power system used the truck’s transmission as the source of its power, employing a series of components that connected the transmission to a hydraulic pump. The transmission that Mack Trucks provided in the incomplete vehicle was designed so that it could be connected to a PTO. In this case, a PTO manufactured by Dana was added. Once installed, a PTO is a fully enclosed piece of equipment except for a short metal post that extends from the PTO case. The post spins when the PTO is engaged, and the spinning post can be used to power different types of equipment. Here, the PTO was connected to an exposed auxiliary drive shaft, which, in turn, was connected to a U-joint (also exposed).
At the time the manufacturers sold the incomplete vehicle and the PTO, they each provided various warnings about the risks presented by the future use of a completed vehicle. For example, Mack Trucks’ owner’s manual included a warning about the use of PTOs and associated equipment, and Dana provided warnings about the dangers posed by exposed moving equipment attached to a PTO.
Duty to warn. The widow did not argue that the truck’s transmission or PTO contained any design defect. Rather, she contended that the manufacturers had a duty to warn installers and end users about the dangers posed by the use of unguarded auxiliary drive shafts and U-joints because those future uses were foreseeable. In support of her position, she asserted that the transmission of the truck was designed to accept a PTO, and PTOs could be operated to power an auxiliary drive shaft.
Under state supreme court precedent, a supplier of a component part containing no latent defect has no duty to warn the subsequent assembler or its customers of any danger that may arise after the components are assembled (Mitchell v. Sky Climber, Inc., 396 Mass. 629 (1986)). The high court also explained that a component part manufacturer has no duty to provide "a warning of a possible risk created solely by an act of another that would not be associated with a foreseeable use or misuse of the manufacturer’s own product." This rule has become known as the component parts doctrine. According to the appeals court, the current case was controlled by Mitchell. The potential dangers, as in the supreme court case, had arisen from the assembly of the component parts into the finished auxiliary power system. As the manufacturers of mere components that were not themselves defective, the defendants had no duty to warn assemblers or end users of the risks presented by such systems.
The widow contended that the risks were not created solely by the acts of another but, rather, were "associated with a foreseeable use or misuse of" the components that the manufacturers had provided. However, the court refused to interpret the language from Mitchellas creating a broad exception to the component parts doctrine whenever there was a dispute over the extent to which the relevant downstream harms could be foreseen. In other words, the rule does not turn on the factual unforeseeability of such harms. In the court’s view, Mitchell stood for the proposition that, as a general rule, the manufacturer of a nondefective component part has no underlying duty to warn of risks posed by the assembled product that arose out of the addition of other components and the decisions made, and actions taken, by downstream actors.
The court also determined that the manufacturers did not assume a duty to warn by virtue of their voluntary efforts to warn users of the downstream dangers. This conclusion was further supported by the Restatement (Third) of Torts: Products Liability §5 comment d. In discussing why a manufacturer of a component part has limited duties with respect to risks posed by the assembled end product, the comment to the Restatement uses as an example a manufacturer of truck chasses. Accordingly, the trial court’s ruling in favor of the manufacturers was affirmed.
The case is No. 16-P-1497.
Attorneys: Roger J. Brunelle (Sbrogna, Brunelle & Donius, LLP) for Ann E. Pantazis. William J. Dailey, III (Sloane and Walsh, LLP) for Mack Trucks, Inc. Richard L. Neumeier (Morrison Mahoney LLP) for Parker-Hannifin Corp.
Companies: Mack Trucks, Inc.; Parker-Hannifin Corp.
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