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Massachusetts Appeals Court Affirms Summary Judgment Based on Component Parts Doctrine in Product Liability Case

dump truckA Cape Cod product liability lawsuit can arise from something small and simple or from something large and complex. If the product in question is of the more complex variety, it is possible that there may be multiple defendants involved, especially if the product was made of many different pieces. In cases involving multiple component parts, the issue of who had a duty to warn of the end product’s propensity for harm can be very complex.

Facts of the Case

In a case recently considered by the Appeals Court of Massachusetts, the plaintiff was the executrix of a man who was found dead underneath a dump truck. The decedent’s clothing was allegedly caught up in a spinning joint on the truck, and his cause of death was reportedly accidental asphyxiation. The plaintiff filed a wrongful death lawsuit against the defendants, the manufacturer of the original version of the truck (which the court described as “stripped down”), and the maker of a part of the system used to tilt the dump body of the truck, asserting product liability claims sounding in negligence and failure to warn. The trial court granted summary judgment to the defendants.

The Massachusetts Appeals Court’s Decision

The appellate court affirmed. First, the court noted that the issue of whether the defendants owed a legal duty was an issue of law, rather than of fact; this was true because such questions are resolved based on public policy factors. With regard to the  “component parts doctrine,” the court found that, generally, the manufacturer of a non-defective component part has no duty to warn of risks posed by a product that was assembled after other components were added. While a particular defendant might be said to have taken on a voluntary effort to warn people of the downstream dangers, this was not the case here.

Thus, the court concluded that, insofar as the components made by the defendants included no design defects, and the risks posed by the assembled product arose out of the addition of other components and decisions made by downstream actors, the defendants had no duty to warn of those dangers. Thus, the court affirmed the lower tribunal’s decision granting summary judgment to the defendants. In so holding, the court pointed out that there could be circumstances that would create an exception to the component parts doctrine but found that no such special circumstances applied in the current case.

Experienced Cape Cod Product Liability Attorney Reviewing Cases

When a product is poorly designed, is improperly constructed, or has insufficient safety warnings, serious injuries or a wrongful death can result. The knowledgeable Cape Cod product liability attorneys at the Law Offices of John C. Manoog, III, are here to discuss your concerns about a particular product that has caused harm to you or death to a loved one. Call us at 888-262-6664 to schedule an obligation-free, complimentary case evaluation at our Hyannis or Plymouth offices.

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