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Products Liability for Manufacturers of Auxiliary Products: New Case Law

Massachusetts law allows for recovery for damages suffered as a result of defective products. Plaintiffs may recover under three theories, generally, for products liability. The first theory claims that there was a defect in the design of a product line, and that an alternative, safer design could have prevented the harm suffered by the plaintiff. The second theory claims that a defect occurred during the manufacturing of the particular product which ended up in the hands of the plaintiff, causing injuries. The third theory claims that there are certain inherent, foreseeable dangers to using the product of which the manufacturer should have warned consumers—because it failed to do so, the plaintiff was injured by the product.

The recent Massachusetts Appeals Court case of of Pantazis v. Mack Trucks, Inc. involved a wrongful death suit. The decedent had bought a dump truck that he used to haul soil. At the time of purchase, the truck was an “incomplete vehicle”: it had a chassis, cab, and engine, but it lacked essential components (and associated equipment) necessary to carry out the truck's ultimate intended function. After the purchase, the decedent outfitted the truck to function as a dump truck by adding an auxiliary power system, connected to a power take-off instrument. The decedent was working on his truck one day. While under the truck, his clothing caught in part of the auxiliary power system, causing his asphyxiation and death.

The estate of the decedent filed suit against the manufacturer of the original, stripped-down version of the truck, as well as the manufacturer of the power take-off instrument. The plaintiff did not file a claim based on a design or manufacturing defect. Rather, the plaintiff alleged that the defendants failed to warn consumers of foreseeable risks which may occur upon use of the defendants’ respective products.

In discussing the facts of the case and their application to a duty to warn, the Court discussed the “component parts doctrine,” set by the Supreme Judicial Court in the 1986 case of Mitchell v. Sky Climber, Inc. In that case, the decedent was electrocuted while he was working on what he thought was a loose connection between electrical power cords of motors used to lift scaffolding. Improper rigging of the scaffolding had cut the insulation of a wire, which came into contact with an ungrounded junction box that the decedent touched.

The Court in Mitchell held that a component part manufacturer has no duty to provide "a warning of a possible risk created solely by an act of another that would not be associated with a foreseeable use or misuse of the manufacturer's own product."

The Court in the Pantazis noted that the Mitchell case was the controlling authority in this situation. It explained that the dangers in the case arose from the assembly of the component parts into the finished auxiliary power system. Like in Mitchell, the manufacturers had no duty to warn assemblers or end users of the risks presented by such systems.

“Viewing the component parts doctrine in this context, we interpret the court's suggestion that the risks presented there were not "reasonably foreseeable" not as a conclusion of fact, but as a declaration that such risks would not be deemed "reasonably foreseeable" as a matter of law,” the Court stated. “[A]s a general rule, the manufacturer of a nondefective 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.”

Moreover, the Court rejected the plaintiff’s argument that the defendants voluntarily assumed a duty to warn in this case by providing warning labels subsequent to the plaintiff’s purchase. “[T]his is not a case where the voluntary warnings that were given could give rise to a claim that the harm was caused by the decedent's reliance on negligent warnings,” the Court explained. “For example, nothing in the warnings that Mack Trucks and Dana provided suggests that it was safe for someone to be under a truck with an exposed auxiliary drive shaft while a PTO was engaged. Nor is this a case where the particular relationship between the decedent and the defendants made it necessary for the defendants to provide the decedent with a complete and comprehensive list of dangers arising out the functioning of their products.”

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