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November 29, 2017

Legal Update
Andrew R. Levin, Kenneth N. Thayer

Component parts manufacturers held immune from suit for failure to warn of dangers in finished products, even where risks are deemed foreseeable

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Manufacturers of component parts have no duty to warn customers of dangers that may exist in the finished products in which their components are used—even when those dangers are foreseeable to the component part manufacturer—according to a recent Massachusetts Appeals Court decision.  In Pantazis v. Mack Trucks, Inc., the Appeals Court affirmed summary judgment dismissing claims for negligent failure to warn brought by the widow of a man who was killed by the rotating mechanical apparatus of his dump truck against the manufacturer of the original, unfinished truck and the manufacturer of another truck component that connected to the rotating apparatus.  At issue in the case was whether these manufacturers could be held liable for the alleged unreasonable dangerousness of the rotating apparatus, which they did not make or sell, by virtue of the fact that they knew such an apparatus could pose a danger when incorporated with their components into a finished product and had issued certain allegedly inadequate warnings about that danger in their product manuals.

Arguing that these component manufacturers should bear liability for the finished dump truck based on their failure to provide adequate warnings, the plaintiff claimed that the risks posed by the potential incorporation of a rotating apparatus were foreseeable and, therefore, the manufacturers had a duty to effectively warn customers about those risks.  Indeed, the plaintiff argued that the component manufacturers had essentially admitted the foreseeability of the risk by issuing warnings about the dangers of the rotating apparatus in their respective user manuals (although plaintiff claimed that those warnings were inadequate).  The plaintiff further argued that, even if the manufacturers otherwise had no duty to warn about the risks of a product they did not make or sell, they had voluntarily assumed such a duty when they addressed the dangerousness of an incorporated rotating apparatus in their manuals.

Both manufacturers moved for summary judgment, claiming that, as manufacturers of non-defective components, they had no duty to warn of dangers raised by the finished product.  The trial court granted their motions, and the plaintiff appealed.  Relying on the Supreme Judicial Court’s decision in Mitchell v. Sky Climber, Inc., 396 Mass. 629 (1986), the Appeals Court invoked the “component parts doctrine” to affirm the lower court’s dismissal of the case.  The court explained that Mitchell stood for the proposition that manufacturers of mere components have no duty to warn customers or other end-users about the dangers presented by finished products or systems.  The court specifically rejected the plaintiff’s argument that Mitchell applied only to those situations where the component manufacturers could not reasonably foresee the finished products’ dangerousness and clarified that the “component parts doctrine” immunizes manufacturers of non-defective components from liability for harm that results from allegedly defective finished products regardless of whether the component manufacturers could have reasonably foreseen the danger posed by those finished products.   As the court stated: “the manufacturer of a non-defective component part has no underlying duty to warn of risks posed by the assembled product that arose out of the addition of other components and the decisions made, and actions taken, by downstream actors.”   This is true, the court held, even in cases where the component manufacturers have voluntarily issued warnings about the potential risks posed by the finished products.

Notably, the Pantazis decision recognizes the possibility of exceptions to the “component parts doctrine” in appropriate circumstances and left several questions unresolved, including (1) whether manufacturers could face liability for issuing “negligent warnings” that created risks and on which a customer relies to his detriment, and (2) whether manufacturers’ particular relationships with certain customers could give rise to more comprehensive duties to warn.   Nonetheless, Pantazis  is significant because it expands and clarifies the component parts doctrine that was articulated by the SJC in Mitchell, offering greater protections for manufacturers of component parts in Massachusetts from lawsuits arising from alleged defects in finished products that utilize their components.

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