June 23, 2016

California Supreme Court’s narrow ruling on the component parts doctrine

By Deborah J. La Fetra Senior Attorney

Flavio Ramos worked as a mold maker, machine operator, and laborer for Supreme Casting & Pattern, Inc., which manufactured metal parts through “a foundry and fabrication process,” from 1972 to 2009. During this time, the industrial processing of raw materials created fumes from molten metal and dust from the plaster, sand, limestone, and marble. In 2010, he sued ten suppliers of all the raw materials to which he was exposed, alleging that his exposure caused his lung disease. The trial court rejected his claim on a demurrer, but the court of appeal reversed, holding that suppliers of raw materials or component parts owe a duty to workers in plaintiff’s position where it is foreseeable that the raw material will be used in processes that may pose health hazards, even where the raw material posed no health hazard when transferred from the supplier to the manufacturer. Today, the California Supreme Court unanimously decided Ramos v. Brenntag Specialties, Inc., affirming the appellate court’s holding that the component parts doctrine does not apply and remanding to the trial court.

This unusual result comes from author Chief Justice Cantil-Sakauye’s extremely narrow focus on whether the facts in Ramos’ complaint stated a claim that could be resolved by application of the component parts doctrine. He alleged that the raw materials were “inherently dangerous,” and the Court held that this fact alone means that the component parts doctrine cannot apply, because that doctrine applies only when a product is incorporated into a different finished or end product. The Court never mentions other allegations in the complaint—recounted by the Court of Appeal—that the danger to Ramos arose not from any inherent characteristic of the raw materials, but only “when [the materials] melted during the casting process.” Having brushed this aside, the Court remanded the case to the trial court for further proceedings, explicitly noting that its decision takes no position on the applicability or scope of other product liability doctrines that may apply. PLF filed an amicus brief in the case, arguing that Ramos should have submitted his claim for workers’ compensation (as is typical in industrial fume cases) and that his tort claims were further barred by the bulk supplier doctrine and the fact that any warnings should have been directed to Ramos’ employer, who then had a duty to educate the employees. These issues presumably will be addressed on remand.

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