Artiglio v. General Electric Co

In Artiglio v. General Electric Co. (1998) 61 Cal.App.4th 830, General Electric (GE) supplied bulk silicone to a manufacturer of breast implants. That manufacturer substantially processed the silicone in a manufacturing process over which GE had no control. The silicone was only dangerous when used in medical devices, and GE shipped the product with a disclaimer, disclaiming any responsibility for determining whether the material was suitable for medical applications. GE really had no ability to warn the ultimate user, because it in no way exercised any control over the design, testing or labeling of the implants. Thus, GE was a component parts supplier and was not liable to women who claimed to have been injured by the implants. The defendant manufactured silicone in accordance with "particular specifications as to the physical properties its customers wanted in the silicone." (Id. at p. 834.) Despite having manufactured a product to particular specifications, and thus arguably limiting its uses, the court held that the factors underlying the component parts doctrine relieved the defendant of liability as a matter of law. (Id. at pp. 837-841.) The Restatement Third of Torts, Products Liability agrees: "A component seller who simply designs a component to its buyer's specifications, and does not substantially participate in the integration of the component into the design of the product, is not liable within the meaning of Subsection (b)." (Rest.3d Torts, Products Liability, 5, com. e, p. 135.) The mere fact that respondents followed Navy specifications when producing their products does not preclude them from invoking the component parts doctrine. Restatement Third of Torts, Products Liability, section 5, subdivision (b) recognizes that liability may be imposed on the seller or distributor of a component part where the seller or distributor "substantially participates in the integration of the component into the design of the product," the integration causes the product to be defective, and the defect causes harm. (Rest.3d Torts, Products Liability, 5.)