Products Liability Law Daily Judgment favoring lathe parts manufacturer based on component parts doctrine overturned
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Thursday, July 9, 2020

Judgment favoring lathe parts manufacturer based on component parts doctrine overturned

By Georgia D. Koutouzos, J.D.

Parts maker failed to establish that the parts it had supplied were not themselves defective.

A lathe parts manufacturer failed to establish a key element of its component parts doctrine-based defense against products liability claims by a man who had been seriously injured while operating a lathe made by his employer using certain components provided by the manufacturer, a California state appellate panel ruled in a decision designated as not for publication. Reversing and remanding the trial court’s grant of summary judgment favoring the parts maker, the panel held that the company neither asserted that the components it had supplied were not themselves defectively designed nor supported that assertion with evidence, both of which were necessary to establish the component parts defense (Ruiz v. Omniturn, July 7, 2020, Poochigian, C.).

An individual who lost three fingers while operating a lathe to thread PVC pipe designed and built by his employer using a controller and operator’s control station manufactured by NC Electronic Services, Inc. (wrongly identified in the complaint as Omniturn) filed suit against the parts maker alleging causes of action for products liability and negligence. The parts manufacturer’s answer included a general denial as well as several affirmative defenses, including the so-called component parts doctrine, which asserts that an unnamed third party altered or otherwise used non-defective component parts and that the third party’s alteration or use of the component parts—and not any act or omission of the manufacturer—was the sole cause of the employee’s injury.

The parts maker moved for summary judgment, arguing that the injured man’s claims failed under the component parts doctrine. The trial court granted the motion on the grounds that the doctrine provided an absolute defense, after which the injured man appealed the trial court’s decision.

Component parts doctrine. Under relevant California case precedent, the component parts doctrine applies as a defense to product supplier liability when: (1) a supplier provides a component or raw material that is not itself defective (by virtue of a manufacturing, design, or warning defect); (2) the component or raw material is changed or transformed when incorporated through the manufacturing process into a different finished or end product; and (3) an end user of the finished product is allegedly injured by a defect in the finished product. Under these circumstances, the component supplier is not subject to liability for the injury unless the supplier substantially participated in the integration of the component into the design of the product; the integration of the component causes the product to be defective; and the defect in the product causes the harm. Thus, by its own terms, the doctrine does not apply when the component itself causes injury when used in the manner intended by the product supplier.

Summary judgment burden. In the case at bar, the parts maker bore the initial burden to establish evidentiary facts of every element necessary to entitle it to judgment. However, the company did not assert that the controller it had supplied to the injured man’s employer was not itself defectively designed. The absence of design defects (as well as manufacturing or labeling defects) clearly was a "material fact" necessary to invoke the component parts doctrine. As a result, the parts maker had to assert in its separate statement that the controller (and other components it had supplied) had not themselves been defectively designed, and then had to support that assertion with evidence. The company’s failure to have done so was a fatal flaw for a summary-judgment motion predicated on the component parts doctrine, the panel said.

Evidence of design defect. The parts maker argued that by asserting the component parts defense, it "automatically implicated" that the at-issue controller was not defective. A moving defendant can satisfy its initial summary judgment burden by "identifying" the lack of evidence contrary to its position, the company contended, adding that the lack of a defect "was initially argued by negation in that no evidence existed of a design defect." However, the company had to present evidence to carry its initial burden on summary judgment. It could not simply point out that the plaintiff did not possess and could reasonably obtain the necessary evidence, the appellate panel instructed. Thus, the parts maker’s argument that the injured man had no evidence of a design defect was insufficient.

Furthermore, the declaration of the injured man’s expert that there was nothing wrong with the design of the control station in and of itself did not change the fact that the parts maker had failed to carry its own initial burden—a necessary prerequisite before the court could look to the evidence of the party opposing the motion. Because the parts maker had failed to carry its initial burden, the burden never shifted to the injured man to show a dispute of material fact; therefore, any issues related thereto could not be considered. Accordingly, the trial court’s judgment was reversed and remanded.

The case is No. F077571.

Attorneys: Thomas A. Brill (Young Wooldridge, LLP) for Luis Ruiz. Michael L. O’Dell (Clifford and Brown PC) for Omniturn/NC Electronic Services, Inc.

Companies: Omniturn; NC Electronic Services, Inc.

MainStory: TopStory DefensesLiabilityNews DesignManufacturingNews IndustrialCommercialEquipNews CaliforniaNews

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