O'NEIL v. Crane Co.
135 Cal. Rptr. 3d 288
| Cal. | 2012Background
- Crane Co. and Warren Pumps manufactured valves and pumps for Navy warships under strict military specifications that required asbestos-containing components.
- Asbestos insulation and asbestos-containing gaskets/packing were supplied by third parties and added to the pumps/valves post-sale; Crane/Warren did not manufacture or sell the asbestos-containing materials at issue.
- Plaintiffs allege that exposure to asbestos from these third-party components, installed or replaced long after initial sale, caused mesothelioma on an Oriskany crewman.
- The Navy’s specifications and integration of parts created a complex system; plaintiffs argue this makes Crane/Warren liable under strict liability or negligence.
- Trial court granted nonsuits; appellate court reversed, holding a broad theory of strict liability and warning duty beyond the defendant’s light, which this Court now reviews.
- The Supreme Court ultimately holds that manufacturers are generally not liable for injuries caused by other manufacturers’ products unless their own product contributed substantially to the harm or they substantially participated in creating a harmful combined use.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a pump/valve manufacturer can be strictly liable for injuries from asbestos in replacement parts from others | O'Neil argues liability extends to foreseeable use with other manufacturers’ asbestos parts | Crane/Warren contend no liability absent direct defect or contribution by their own product | No liability unless own product contributed substantially or was part of a harmful combination |
| Whether manufacturers have a duty to warn about hazards in replacement parts from other manufacturers | Plaintiffs claim duty to warn extends to risks from replacement parts not made by defendant | Duty to warn limited to risks arising from the defendant’s own product or its integration | No duty to warn about risks from other manufacturers’ products in this context |
| Whether the component parts doctrine or Taylor v. Elliott affects liability here | Taylor supports broader duty to warn for components used with other products | Taylor does not expand duty beyond the chain of distribution or where defendant’s own product creates the risk | Taylor does not extend liability; no duty unless defendant’s product causes or participates in the risk |
| Whether foreseeability alone supports expanding strict liability to cover injuries from other manufacturers’ products | Foreseeability of harm from replacement parts supports expansion | Foreseeability alone is insufficient; liability must be tied to defendant’s own product or conduct | Foreseeability is not sufficient to create liability absent direct contribution or participation by the defendant's product |
| Whether negligence claims create a broader duty to prevent injuries from another manufacturer’s product | Plaintiffs seek a duty to prevent injuries from third-party products used with defendant’s product | No duty to prevent harm from other manufacturers’ products when no direct connection | No duty of care; nonsuit proper |
Key Cases Cited
- Greenman v. Yuba Power Prods., Inc., 59 Cal.2d 57 (Cal. 1963) (established strict liability for defects in defendant’s product in the stream of commerce)
- Vandermark v. Ford Motor Co., 61 Cal.2d 256 (Cal. 1964) (expanded strict liability to retailers and others in the chain of distribution)
- Cronin v. J.B.E. Olson Corp., 8 Cal.3d 121 (Cal. 1972) (limits strict liability to defective product in the chain of distribution)
- Peterson v. Superior Court, 10 Cal.4th 1185 (Cal. 1995) (limiting strict liability outside the stream of commerce; focus on who put the product into commerce)
- Garman v. Magic Chef, Inc., 117 Cal.App.3d 634 (Cal. App. 1981) (duty to warn limited to risks arising from the manufacturer’s own product; not other products)