Academic journal article The University of Memphis Law Review

Torts-Davis V. Komatsu America Industries Corp.: The Restatement Third's Effect on the Liability of Component Part Manufacturers

Academic journal article The University of Memphis Law Review

Torts-Davis V. Komatsu America Industries Corp.: The Restatement Third's Effect on the Liability of Component Part Manufacturers

Article excerpt

On September 22, 1996, McArthur Davis (Davis) was working on an automated press line at a Sharp plant in Memphis, Tennessee.1 The press line as a whole was designed by an engineering firm according to Sharp's specifications and each individual Komatsu press was installed by a Komatsu service technician.2 Each press on the line had a safety device called a light curtain that sent an infrared beam of light from one post to another, preventing the press's operation when the beam was broken.3 Sharp, however, deactivated the light curtain for press number four because it could not operate with the light beam intact.4 That evening, Davis shut down the line to remove a piece of metal from press number four.5 Another employee restarted the line from the master control panel, causing the press to crush Davis's hand.6

Davis brought a products liability suit against Komatsu America Industries Corp. ("Komatsu"), claiming that Komatsu defectively designed the press and that it was unreasonably dangerous.7 Subsequently, Komatsu filed a motion for summary judgment.8 Granting the motion, the district court held: (1) the press was not unreasonably dangerous when it left Komatsu's control; (2) the press was not the proximate cause of Davis's injury because Sharp installed and deactivated the light curtain; (3) Komatsu, as a matter of law, was not liable for the entire press line unless the individual press was defective; and (4) Komatsu did not fail to adequately warn of the press's dangers.9

The Sixth Circuit Court of Appeals affirmed the district court's ruling on the failure to warn issue and certified the following question to the Tennessee Supreme Court: does Tennessee products liability law contain a component parts doctrine?10 The Tennessee Supreme Court held, answered.11 Tennessee products liability law includes a component parts doctrine as outlined by section 5 of the Restatement (Third) of Torts: Products Liability:

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.12

The court also held that the term "manufacturer," as articulated in section 29-28-102(4) of the Tennessee Code,13 includes component part manufacturers, and a component manufacturer is liable for injuries caused by its component if the component itself is defective14 or unreasonably dangerous15 at the time it left the manufacturer's control.16 Davis v. Komatsu, 42 S.W.3d 34, 43 (Tenn. 2001).

The absence of privity17 between the consumer and the manufacturer barred strict liability claims against a manufacturer well into the twentieth century.18 Courts did not begin to abolish the privity requirement until the early 1960s.19 It remained difficult, however, for plaintiffs to convince courts to recognize the theory of strict liability.20 As such, many plaintiffs sued manufacturers under the theories of breach of express21 or implied warranty.22

In the 1960s, many states began to adopt a tort action for strict liability. There were three main rationales for adopting this theory. First, it is socially desirable to hold manufacturers, rather than individuals, liable for the injuries caused by the defective product because manufacturers are in a better position to bear the loss.24 Specifically, the manufacturer more easily bears the loss by spreading the cost among the population through increased prices.25 second, manufacturers have an inducement to make their products safer if they are subject to liability. …

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