Product liability limited to injury caused by defendant's own product or loss directly caused by that product's use
The California Supreme Court is widely credited as the originator of strict product liability as a means of tort recovery for its pronouncement in Greenman v Yuba Power Products, Inc. (1963) 59 Cal.2d 57, 62: "A manufacturer is strictly liable in tort when an article he places into the market, knowing that it is to be used without inspection for defects, proves to have a defect that caused injury to a human being." Soon thereafter the theory was expanded such that strict liability encompassed even those injuries traceable to a defective component part that was supplied by someone other than the defendant manufacturer of the finished product. (Vandermark v. Ford Motor Co. (1964) 61 Cal.2d 256, 262.)
In O'Neil v. Crane Co.(filed January 12, 2012) 2012 DJDAR 464, the current state high court was asked to extend liability for the harm caused by replacement parts, made by someone other than the defendant manufacturer, that were used in conjunction with (rather than as component parts of) defendant's product. In a unanimous decision, the Supreme Court decided to limit a manufacturer's duty to foresee such harm unless the defendant's own product contributed substantial harm or the defendant participated substantially in creating a harmful combined use of the products.
Defendants Crane and Warren (Warren Pumps, LLC) made valves and pumps respectively that were used in US Navy warships according to government specifications. Gaskets and packaging materials were used as sealants for defendant's products; based on Navy specifications, these sealant materials were made of asbestos and replaced during routine maintenance. Patrick O'Neil served on a ship that contained these products from 1965 to 1967. While supervising enlisted men repairing ship equipment, he was exposed to airborne asbestos fibers that were released during the repair of valves and pumps manufactured by defendants. However, none of the asbestos dust came from defendant's products. In 2004, O'Neil developed mesothelioma, causing his death about one year later. Family of O'Neil filed this wrongful death action raising strict liability and negligence claims.