Friday, September 7, 2007

Component Manufacturer's Defense Not Established for Summary Judgment

The Component Manufacturer's Defense Bars a Strict Products Liability Claim, But the Manufacturer Had Not Met the Standard for Summary Judgment

Gonzalez v. Autoliv Asp, Inc. (Aug. 27, 2007, B188829, Second Appellate District, Division Eight)
15 page opinion

Summary judgment for an airbag manufacturer of a strict products liability cause of action was reversed because the manufacturer had not established through undisputed facts that it was entitled to the component manufacturer's defense as a matter of law. A component manufacturer who had no role in designing the finished product and who supplied a nondefective component is not liable for a defective product. If there is no defect in the component when it leaves the component manufacturer's factory, the component manufacturer is not strictly liable for a defect that arises in the integrated product.
Presiding Justice Cooper wrote the opinion. Justices Rubin and Boland concurred.

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