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Air & Liquid Systems Corp. v. DeVries
139 S. Ct. 986
| SCOTUS | 2019
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Background

  • Equipment manufacturers (pumps, blowers, turbines) sold “bare-metal” components to the U.S. Navy; asbestos insulation or asbestos parts were later added (by Navy or third parties) and released fibers during use.
  • Two Navy veterans (McAfee and DeVries) developed fatal cancers allegedly from shipboard asbestos exposure; their families sued the equipment manufacturers for negligent failure to warn.
  • Plaintiffs could not recover from asbestos-part manufacturers (bankrupt) or the Navy (likely immune under Feres), so they sued equipment makers.
  • District Court granted summary judgment for equipment manufacturers based on the "bare-metal" defense (no duty to warn about third-party parts).
  • Third Circuit vacated and remanded applying a foreseeability standard; the Supreme Court granted certiorari to resolve the split and to define manufacturers’ duty to warn in maritime torts.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether a product manufacturer owes a duty to warn when its product requires later incorporation of a dangerous part Manufacturers must warn when their product requires a part that they know (or should know) will make the integrated product dangerous No duty to warn for harms caused by third‑party parts that manufacturer did not make, sell, or install (bare‑metal defense) In maritime torts, a manufacturer has a duty to warn when (1) the product requires incorporation of a part, (2) the manufacturer knows or has reason to know the integrated product is likely dangerous for its intended uses, and (3) the manufacturer has no reason to believe users will realize the danger.

Key Cases Cited

  • United States v. Detroit Timber & Lumber Co., 200 U.S. 321 (syllabus preparation cited) (procedural note on syllabi)
  • Exxon Shipping Co. v. Baker, 554 U.S. 471 (2008) (federal courts act as common‑law courts in maritime cases; scope of maritime tort law)
  • East River S. S. Corp. v. Transamerica Delaval Inc., 476 U.S. 858 (1986) (products‑liability principles in maritime law)
  • Norfolk Shipbuilding & Drydock Corp. v. Garris, 532 U.S. 811 (2001) (recognition of maritime negligence tort)
  • Miles v. Apex Marine Corp., 498 U.S. 19 (1990) (federal maritime law development)
  • American Export Lines, Inc. v. Alvez, 446 U.S. 274 (1980) (maritime law’s solicitude for seamen)
  • Moragne v. States Marine Lines, Inc., 398 U.S. 375 (1970) (maritime remedies and policy)
  • Saratoga Fishing Co. v. J. M. Martinac & Co., 520 U.S. 875 (1997) (distinction between components added before sale and items added later)
Read the full case

Case Details

Case Name: Air & Liquid Systems Corp. v. DeVries
Court Name: Supreme Court of the United States
Date Published: Mar 19, 2019
Citation: 139 S. Ct. 986
Docket Number: 17-1104
Court Abbreviation: SCOTUS