In DaFonte v. Up-Right, Inc. (1992) 2 Cal.4th 593, a ranch employee's arm was drawn into a mechanical grape harvester he was attempting to clean. The employee and his family sued the harvester's manufacturer on theories of negligence and product defect. In a special verdict, the jury found the employee 15 percent at fault, the employer 45 percent at fault and the manufacturer 40 percent at fault. (Id. at p. 596.) The parties agreed to reduce the total damage award by 15 percent and the trial court further reduced the amount of noneconomic damages by 45 percent, the portion attributed to the employer, under Civil Code section 1431.2 (several liability for noneconomic damages). (DaFonte, at p. 597.) On appeal, the Fifth District concluded that the trial court had erroneously precluded a full joint and several award of noneconomic damages against the manufacturer. (Ibid.) The Supreme Court reversed, holding that section 1431.2 limits the joint liability of every defendant to economic damages and shields every defendant from any share of noneconomic damages beyond that attributable to his own comparative fault. (DaFonte, at p. 602.)