Air & Liquid Systems Corp. v. DeVries

139 S.Ct. 986, 203 L.Ed.2d 373 (2019)

Quick Summary

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Kenneth McAfee and John DeVries (plaintiffs), Navy veterans exposed to asbestos on ships, filed suit against Air & Liquid Systems Corp. and other equipment manufacturers (defendants) for failing to warn of asbestos dangers in their products.

The dispute centered on whether manufacturers had a duty to warn about dangers from parts they did not themselves provide but knew would be used with their products. The Supreme Court held that in maritime tort cases, manufacturers do have such a duty to warn, leading to a requirement for the District Court to revisit earlier summary judgments in favor of the defendants.

Facts of the Case

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Kenneth McAfee and John DeVries (plaintiffs) were Navy veterans who died from cancer after being exposed to asbestos on U.S. Navy ships. The plaintiffs’ estates sued Air & Liquid Systems Corp., along with other manufacturers (defendants), for not warning about the dangers of asbestos in products like pumps, blowers, and turbines used on the ships.

These products, delivered “bare-metal,” required additional asbestos parts or insulation to function properly, which were added by the Navy after installation.

The manufacturers argued they had no duty to warn about the dangers of asbestos parts they did not provide. The plaintiffs countered that the manufacturers should have warned about the asbestos dangers because they knew their products would need these dangerous parts to operate as intended.

Procedural History

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  1. The plaintiffs filed a products-liability lawsuit in state court against the equipment manufacturers.
  2. The defendants removed the cases to federal court on the basis of federal maritime jurisdiction.
  3. The District Court granted summary judgment in favor of the manufacturers, applying the “bare-metal defense”—the idea that manufacturers are not liable for harm caused by parts (like asbestos) that they did not themselves make or distribute.
  4. The Third Circuit Court of Appeals reversed the decision, challenging the “bare-metal defense” and remanded the case.
  5. The manufacturers appealed to the United States Supreme Court.

I.R.A.C. Format

Issue

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Whether product manufacturers have a duty to warn when their product requires incorporation of a dangerous part that the manufacturer knows is likely to make the integrated product dangerous for its intended uses.

Rule of Law

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In maritime tort cases, product manufacturers have a duty to warn when:

  • Their product requires incorporation of a part.
  • They know or have reason to know that the integrated product is likely to be dangerous for its intended uses.
  • They have no reason to believe that users will realize that danger.

Reasoning and Analysis

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The Supreme Court concluded that foreseeability alone does not create a duty to warn. However, when a product requires incorporation of a part that the manufacturer knows will likely be dangerous, a duty to warn arises. This duty exists even if the manufacturer did not incorporate the dangerous part itself.

The Court found this approach to be appropriate in maritime law due to its special concern for the safety of those at sea, including Navy veterans like McAfee and DeVries.

Additionally, the Court reasoned that product manufacturers are often in a better position than parts manufacturers to understand and warn about risks associated with an integrated product. The burden of warning is generally minimal compared to the potential harm from not warning users of known dangers.

Conclusion

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The Supreme Court affirmed the judgment of the Third Circuit, requiring the District Court to reconsider its prior grants of summary judgment to the defendant manufacturers based on the newly established maritime tort rule.

Dissenting Opinions

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Justices Gorsuch, Thomas, and Alito dissented, arguing that traditional tort principles do not impose a duty on manufacturers to warn about dangers arising from products they did not design, make, or sell. They also expressed concern about retroactively imposing new duties on manufacturers, which could lead to unfair results and uncertainty in tort law outside of the maritime context.

Key Takeaways

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  1. Product manufacturers have a duty to warn of dangers from parts they know will be used with their products in maritime law.
  2. The traditional “bare-metal defense” was rejected as too broad for maritime tort cases.
  3. The Supreme Court’s decision specifically applies to maritime law and does not necessarily extend beyond this context.

Relevant FAQs of this case

What determines a manufacturer's duty to warn about product dangers?

A manufacturer’s duty to warn is established by the foreseeability of harm, the likelihood that their product will be used with dangerous parts, and an understanding that users may not recognize the risks. Additionally, the duty is reinforced when manufacturers are in a superior position to know about the dangers of the integrated product.

  • For example: A lawnmower manufacturer who designs a model that requires a specific type of blade should warn consumers if the blades, even if produced by a third party, pose a risk of injury beyond normal use.

How does maritime law differ from general tort law regarding product liability?

Maritime law extends a manufacturer’s duty to warn to incorporate foreseeable risks related to the products’ use in marine environments, emphasizing safety due to the hazardous nature and isolation inherent in seafaring activities.

  • For example: A maker of marine engines must provide warnings about potential hazards such as carbon monoxide poisoning from engine exhaust, even when specific components causing such hazards are added by another party.

What legal challenges arise from imposing new duties retroactively on manufacturers?

The retroactive imposition of new duties can lead to legal uncertainty, disrupt settled expectations, and result in unfairness as manufacturers might be held liable for actions taken before they knew, or could have known, about the duties under the law.

  • For example: If a vehicle manufacturer were suddenly required to warn against risks associated with using non-original tires, prior accidents involving such tires could spur litigation against them, although they had no warning obligations at those times.
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