Carolyn Coffman v. Armstrong International, Inc., 615 S.W.3d 888

Plaintiff Donald Coffman (and spouse) developed mesothelioma after decades working as an equipment mechanic at Tennessee Eastman, allegedly from occupational asbestos exposure.
Coffman routinely repaired and replaced industrial valves, pumps, steam traps, gaskets, packing, and worked near insulation; some replacement/insulation materials used later allegedly contained asbestos and were manufactured/sold by third parties.
Appellees sued nearly thirty defendants, including several equipment manufacturers ("Equipment Defendants"), alleging TPLA claims that equipment makers failed to warn of asbestos risks associated with post-sale integration of asbestos-containing parts sold by others.
The trial court granted summary judgment to the Equipment Defendants, finding no duty to warn for products the defendants neither made nor sold; the Court of Appeals reversed, applying a foreseeability-based duty analysis.
The Tennessee Supreme Court granted review limited to whether Equipment Defendants had a duty to warn about post-sale integration of asbestos-containing materials manufactured and sold by others.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Duty to warn for post‑sale integration of asbestos parts manufactured/sold by others	Coffman: Equipment was designed/used with asbestos; foreseeability of repair/integration imposed duty to warn about asbestos risks	Equipment Defs: TPLA requires product be defective or unreasonably dangerous when it left defendant's control; they neither made nor sold the asbestos parts	Court: Under the TPLA, no duty to warn for injuries caused by products not made/sold by the defendant; summary judgment affirmed in part (reversing Court of Appeals)
Whether common‑law foreseeability (Satterfield) or DeVries maritime analysis controls over the TPLA	Coffman: Foreseeability and severity of harm justify imposing duty to warn despite statutory language; Court of Appeals properly applied Satterfield/DeVries	Equipment Defs: The TPLA and precedents like Goode govern; statutory text limits liability to defects present when product left defendant's control	Court: Satterfield balancing is inapplicable where statute governs; DeVries is a maritime common‑law decision and does not displace the TPLA; statute controls

Whitehead v. Toyota Motor Corp., 897 S.W.2d 684 (Tenn. 1995) (identifies §29-28-105(a) as key TPLA provision requiring defect/unreasonable danger when product left defendant's control)
Goode v. Tamko Asphalt Prods., Inc., 783 S.W.2d 184 (Tenn. 1989) (no duty to warn where product was not unreasonably dangerous when it left manufacturer's control)
Satterfield v. Breeding Insulation Co., 266 S.W.3d 347 (Tenn. 2008) (articulated foreseeability balancing test for duty where statutes/common law do not already establish rules)
Air & Liquid Sys. Corp. v. DeVries, 139 S. Ct. 986 (2019) (U.S. Supreme Court maritime decision adopting a "bare‑metal" approach; distinguished by Tennessee Supreme Court as maritime and non‑controlling)
Bain v. Wells, 936 S.W.2d 618 (Tenn. 1997) (standard of review for summary judgment)
McClay v. Airport Mgmt. Servs., LLC, 596 S.W.3d 686 (Tenn. 2020) (acknowledges legislature's role in setting public policy and tort limits)