Air & Liquid Systems Corp. v. Devries

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Tort Law
  • Date Filed: March 19, 2019
  • Case #: 17-1104
  • Judge(s)/Court Below: KAVANAUGH, J., delivered the opinion of the Court, in which ROBERTS, C. J., and GINSBURG, BREYER, SOTOMAYOR, and KAGAN, JJ., joined. GORSUCH, J., filed a dissenting opinion, in which THOMAS and ALITO, JJ., joined.
  • Full Text Opinion

In maritime tort context, product manufacturers have a duty to warn when a product requires incorporation of a part, the manufacturer knows or has reason to know that the integrated product is likely to be dangerous for its intended uses, and the manufacturer has no reason to believe that danger is realizable by users.

Petitioner manufactured equipment for Navy ships that was later affixed with asbestos insulation. The equipment released asbestos fibers into the air when used on the ships. Families of two decedent Navy veterans brought suit against Petitioner, claiming negligence in their failure to warn them about the asbestos resulted in the death of . Respondents argue that that because the Navy, and not Petitioner, added asbestos to the product after it was already on the ships, that they had no duty to warn. The District Court granted summary judgment for Petitioner. The Third Circuit vacated, reasoning that the foreseeability of potential risk required the manufacturers to warn users. The Supreme Court affirmed, holding that in maritime tort context, product manufacturers have a duty to warn when a product requires incorporation of a part, the manufacturer knows or has reason to know that the integrated product is likely to be dangerous for its intended uses, and the manufacturer has no reason to believe that the product users will realize that danger. The Court reasoned that under common law, a manufacturer has a duty to warn when it produces an inherently dangerous product. Therefore, products requiring incorporation of part which the manufacturer reasonably expects to be dangerous also impose the duty to warn, as manufacturers are in a better position than the product user to make this determination. The Court found no reason to distinguish in regard to a maritime tort context. AFFIRMED. 

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