§63.6 Component Parts Doctrine
The Case: Davis v. Komatsu America Industries Corp ., 42 S.W.3d 34 (Tenn. 2001).
The Basic Facts: Plaintiff, a worker on a "press line" in a microwave oven factory, brought a products liability action against the manufacturer of a machine on the line in the U.S. District Court for the Western District of Tennessee. On appeal of a granted motion for summary judgment, the U.S. Court of Appeals for the Sixth Circuit certified question for the Supreme Court of Tennessee.
The Bottom Line:
- "Does Tennessee products liability law include a 'component parts doctrine' as described by the district court, and if so, what are the precise contours of the doctrine?" 42 S.W.3d at 36.
- "As described by the District Court, the component parts doctrine provides that a manufacturer who supplies a non-defective and safe component part generally will not be held liable for a defective or unreasonably dangerous final product. However, when a component manufacturer participates in designing a defective or unreasonably dangerous final product, the component manufacturer may be held liable for injuries caused by the final product even though the component itself was not defective or unreasonably dangerous. See Davis, 46 F. Supp.2d at 753." Id. at 38.
- "Consistent with the overwhelming weight of authority, the drafters of the [Restatement (Third) of Torts: Products Liability (1997)] included a streamlined and simplified statement of the doctrine as follows:
§5. Liability of Commercial Seller or Distributor of Product Components for Harm Caused by Products into Which Components are IntegratedId . at 40-41.
One engaged in the business of selling or otherwise distributing product components who sells or distributes a component is subject to liability for harm to persons or property caused by a product into which the component is integrated if:
(a) the component is defective in itself . . .and the defect causes the harm; or
(b)(1)the seller or distributor of the component substantially participates in the integration of the component into the design of the product; and
(2) the integration of the component causes the product to be defective . . .; and
(3) the defect in the product causes the harm."
- "Echoing the judicial decisions discussing this issue, comment a explains the rationale for Section 5 as follows:
If the component is not itself defective, it would be unjust and inefficient to impose liability solely on the ground that the manufacturer of the integrated product utilizes the component in a manner that renders the integrated product defective. Imposing liability would require the component seller to scrutinize another's product which the component seller has no role in developing. This would require the component seller to develop sufficient sophistication to review the decisions of the business entity that is already charged with responsibility for the integrated product."Id . at 41.
- "Comment e clarifies the parameters of the liability described by Section 5(b):
When the component seller is substantially involved in the integration of the component into the design of the integrated product, the component seller is subject to liability when the integration results in a defective product and the defect causes harm to the plaintiff. Substantial participation can take various forms. The manufacturer or assembler of the integrated product may invite the component seller to design a component that will perform specifically as part of the integrated product or to assist in modifying the design of the integrated product to accept the seller's component. Or the component seller may play a substantial role in deciding which component best serves the requirements of the integrated product. When the component seller substantially participates in the design of the integrated product, it is fair and reasonable to hold the component seller responsible for harm caused by the defective, integrated product. A component seller who simply designs a component to its buyer's specifications, and does not substantially participate in the integration of the component into the design of the product, is not liable within the meaning of Subsection (b). Moreover, providing mechanical or technical services or advice concerning a component part does not, by itself, constitute substantial participation that would subject the component supplier to liability."Id .
- "While no Tennessee statutory provision speaks directly to the situation addressed by Subsection 5(b) of the [Restatement (Third) of Torts], we conclude that Tennessee law does support imposition of liability when a component manufacturer substantially participates in the integration of the non-defective component into the design of the final product, if the integration of the component causes the final product to be defective and if the resulting defect causes the harm." Id. at 42
- "We hereby adopt both Section 5(b) and comment e. We emphasize that '[a] component seller who simply designs a component to its buyer's specifications, and does not substantially participate in the integration of the component into the design of the product,' is not liable. [RESTATEMENT (SECOND) OF TORTS: Products Liability § 5b comment e (1997)] (emphasis added.) In addition, 'providing mechanical or technical services or advice concerning a component part does not, by itself, constitute substantial participation that would subject the component supplier to liability.'" Id. at 43.