Georgia Pacific, LLC v. Farrar, 69 A.3d 1028

Plaintiff Jocelyn Farrar lived with her grandfather, John Hentgen, who worked with asbestos-laden materials; she routinely laundered and shook his dusty work clothes during the 1950s–1960s and developed mesothelioma in 2008.
A portion of alleged exposure arose from a 1968–69 project where Georgia Pacific Ready-Mix joint compound (then containing asbestos) was sanded near Hentgen; dust contaminated his clothing and person.
Farrar sued many defendants; by trial only strict liability and negligence claims against Georgia Pacific remained. Jury returned a multi-million dollar verdict; Georgia Pacific appealed.
Georgia Pacific argued it owed no duty to warn Farrar (a household-by-stander who never used or directly encountered the product) and that evidence was insufficient to show Ready-Mix substantially contributed to her disease.
Maryland Court of Special Appeals affirmed; the Maryland Court of Appeals granted certiorari and reversed, holding no duty to warn Farrar for events in 1968–69 because manufacturers then lacked knowledge and feasible means to warn household members effectively.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a product manufacturer owed a duty to warn a household member (a "bystander of a bystander") who never used or encountered the product	Farrar: duty extends to anyone in the foreseeable zone of danger from the product (including household members exposed by workers’ contaminated clothes); manufacturer should have warned	Georgia Pacific: no relationship to Farrar, product user was not Farrar, foreseeability alone insufficient, no feasible way to identify or warn household members	Held: No duty as of 1968–69. Manufacturer lacked the then-available knowledge and practical means to warn household members effectively; court reversed jury verdict
Temporal/scope element of duty — what knowledge/timeframe controls whether a duty existed	Farrar: prior decisions recognizing duty to bystanders in product cases support extending duty earlier	Georgia Pacific: duty must be assessed based on what defendant knew or reasonably should have known when warning should have been given; foreseeability after-the-fact is insufficient	Held: Duty (if any) depends on what was known or knowable at the time; evidence shows household exposure risk was not generally recognized nor regulatively addressed until later (OSHA rules in 1972), so no duty in 1968–69

Gourdine v. Crews, 405 Md. 722 (2008) (discusses duty as policy question, foreseeability, and limits on duty in negligence contexts)
Doe v. Pharmacia, 388 Md. 407 (2005) (articulates negligence elements and duty factors including foreseeability and relationship)
Dehn v. Edgecombe, 384 Md. 606 (2005) (same; frames duty analysis in negligence suits)
Moran v. Faberge, 273 Md. 538 (1975) (product‑manufacturer duty to provide warnings and instructions)
Eagle‑Picher v. Balbos, 326 Md. 179 (1992) (manufacturer duty to warn immediate bystanders in product cases)
Anchor Packing Co. v. Grimshaw, 115 Md. App. 134 (1997) (Court of Special Appeals held manufacturer could foresee household exposure from worker’s clothes)
100 Investment v. Columbia Town Ctr. Title, 430 Md. 197 (2013) (confirms foreseeability and relationship as guideposts in duty analysis)
ACandS v. Asner, 344 Md. 155 (1996) (discusses state‑of‑the‑art knowledge as of a given time)
Lohrmann v. Pittsburgh Corning Corp., 782 F.2d 1156 (4th Cir.) (addresses state‑of‑the‑art and manufacturer knowledge limits)