Strict Products Liability of Component Manufacturers In California
A manufacturer of a component that is subsequently installed in or otherwise integrated as part of a larger product may be subject to strict products liability if that component was defective at the time it left the manufacturer's possession. (Wiler v. Firestone Tire & Rubber Co. (1979) 95 Cal. App. 3d 621, 629, 157 Cal. Rptr. 248; 20 Wilkinson & Barker, Cal. Practice (1991) Tort Law, 34.18, p. 78.)
The Restatement Third of Torts, Products Liability, section 5 states: "One engaged in the business of selling or otherwise distributing product components who sells or distributes a component is subject to liability for harm to persons or property caused by a product into which the component is integrated if:
(a) the component is defective in itself, as defined in this Chapter, and the defect causes the harm;
(b)(1) the seller or distributor of the component substantially participates in the integration of the component into the design of the product; and (2) the integration of the component causes the product to be defective, as defined in this Chapter; and (3) the defect in the product causes the harm."
A component therefore can be a product within another larger product and strict products liability can be imposed on the manufacturers and distributors of both products if the component product was defective when it left the component manufacturer's possession and the defect caused harm to a person or other property.
The Restatement Third, supra, section 19, comment b, page 268 states: "Component parts are products, whether sold or distributed separately or assembled with other component parts.
An assemblage of component parts is also, itself, a product." the Restatement's reporters noted:
"The courts are in agreement that component parts should be considered products for the purposes of strict products liability.
Thus, when a defective component is incorporated into something larger, the supplier or manufacturer of the component may be held strictly liable in tort for any damages proximately caused by the defect. " (Rest.3d, supra, 19, reporters' notes, p. 273.)
California courts have upheld, expressly and implicitly, the application of the doctrine of strict products liability to manufacturers of defective component products. (Barth v. B.F. Goodrich Tire Co. (1968) 265 Cal. App. 2d 228, 248, 71 Cal. Rptr. 306 upheld a jury verdict imposing strict products liability on the manufacturer of a defective tire when the tire failed and caused the car on which it was mounted to turn over, resulting in the death of the driver and personal injuries to the other occupants; Wright v. Stang Manufacturing Co., supra, 54 Cal. App. 4th at pp. 1229, 1233-1234 court rejected the manufacturer's contention that "as a component part manufacturer it is not liable for a failure to warn when the final product is subsequently packaged, labeled and marketed by another manufacturer"; Jenkins v. T&N PLC (1996) 45 Cal. App. 4th 1224, 1228-1229, 1231 court held:
"As a matter of law, a bulk supplier of raw asbestos fiber incorporated into a finished product can be subject to strict products liability to an individual suffering from a disease caused by exposure to the supplier's asbestos"; the component raw asbestos fibers that were incorporated into pipe insulation constituted a "product" for purposes of strict products liability; Arena v. Owens-Corning Fiberglas Corp. (1998) 63 Cal. App. 4th 1178, 1181-1191 court concluded suppliers of raw asbestos, a component in pipe insulation, were subject to strict products liability because the asbestos was defectively designed; Springmeyer v. Ford Motor Co. (1998) 60 Cal. App. 4th 1541, 1550-1555 court upheld the strict products liability of the manufacturer of a fan, which was a component of a truck, for personal injuries caused by the defectively designed fan; Southern Pac. Co. v. Unarco Industries, Inc. (1974) 42 Cal. App. 3d 142, 151, 116 Cal. Rptr. 847 court implicitly upheld the strict products liability of the supplier of a defective door that was a component of a railway freight car.)