Walls v. Ford Motor Company
389, 2016
| Del. | Apr 21, 2017Background
- Plaintiffs Donna and Collin Walls sued Ford after their husband/father, John W. Walls, Jr., died of mesothelioma allegedly from occupational exposure while servicing brakes on Ford and other vehicles.
- Plaintiffs alleged Ford was negligent for failing to warn Mr. Walls about dangers of removing/replacing asbestos-containing brake parts (original and replacement).
- Ford moved for summary judgment arguing (a) it had no duty to warn about third‑party replacement parts and (b) Plaintiffs lacked evidence Mr. Walls was exposed to Ford-made asbestos parts; the Superior Court granted partial summary judgment on the third‑party parts duty issue and denied the remainder.
- Trial was limited to negligence claims about Ford’s original and replacement asbestos brake parts; the jury returned a defense verdict, finding Ford not negligent for failing to warn regarding Ford original or replacement asbestos parts.
- Plaintiffs appealed only the Superior Court’s partial summary judgment that Ford had no duty to warn about third‑party replacement brake parts.
- The Supreme Court affirmed on harmless‑error grounds: because the jury found Ford not negligent as to its own parts, any error in eliminating a duty as to third‑party parts could not have affected the outcome.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Ford had a duty to warn about hazards from third‑party replacement asbestos brake parts used in Ford vehicles | Ford designed vehicles to use asbestos parts, knew replacements would be asbestos, and knew the hazard; thus Ford had knowledge of the product’s hazards and a duty to warn | The "bare metal" defense: a manufacturer has no duty to warn about parts it did not make or distribute — component makers should warn | Court did not decide the merits; issue resolved as harmless because jury found Ford not negligent for failing to warn about Ford’s own parts |
| Whether summary judgment on third‑party parts was reversible error | Adding evidence of third‑party parts exposure could have aided causation and the jury’s assessment of harm | Any error is harmless because duty finding for Ford’s own parts was resolved adversely to Plaintiffs at trial | Error (if any) was harmless; judgment affirmed |
| Whether evidence of exposure to third‑party parts is necessary to prove causation | Plaintiffs: third‑party exposure would increase proof of causation | Ford: causation requires proof of exposure to defendant’s specific asbestos‑containing product | Court: causation is separate; jury never reached causation because it found no duty to warn for Ford’s own parts |
| Whether a manufacturer’s duty to warn extends beyond the immediate purchaser (sophisticated purchaser defense) | Plaintiffs implied broader duty to warn downstream users | Ford invoked sophisticated purchaser defense and that widely known risks or purchaser knowledge can negate duty | Jury was instructed on duty to warn and sophisticated purchaser defense; jury found no negligence by Ford |
Key Cases Cited
- Bantum v. New Castle Cty. Vo‑Tech Educ. Ass’n, 21 A.3d 44 (Del. 2011) (standard of review for summary judgment in Delaware)
- In re Asbestos Litig. (Colgain), 799 A.2d 1151 (Del. 2002) (manufacturer’s duty to warn depends on knowledge of hazards)
- Nicolet, Inc. v. Nutt, 525 A.2d 146 (Del. 1987) (discussing manufacturer knowledge and duty to warn)
- Czech v. State, 945 A.2d 1088 (Del. 2008) (harmless‑error standard)
- Whittaker v. Houston, 888 A.2d 219 (Del. 2005) (harmless‑error principles)