Ohio has tightened the noose around the neck of plaintiff lawyers who have targeted suppliers when the original equipment manufacturer is unavailable. In Zager v. Johnson Controls, Inc. the Twelfth District (Ohio) Court of Appeals issued a ruling exonerating a seat manufacturer who met the design specifications of the manufacturer. This opinion offers protection to component manufacturers who are merely cogs in the wheel of the overall design.
Zager involved a claim of inadequate cargo retention in the design of a rear seat. During a frontal accident, a 50 pound cooler allegedly came through the backseat and struck an occupant. The design allowed for the seat to be folded down to provide extra room for large objects located in the trunk. The claim asserted that the fold down system should have had greater retention strength. The trial court granted summary judgment in favor of JCI. The Plaintiff appealed.
Ohio recognizes the Component Parts Doctrine which stands for the proposition that a company that manufactures component parts may not be successfully sued under the theory of strict liability for a finished product that incorporates its component. Crafty plaintiff lawyers have tried to bypass the doctrine by arguing that it was abrogated by the 2005 amendments to R.C. 2307.71; that the doctrine does not apply because the component itself is defective; or that the component supplier substantially participated in the design. Each of those arguments failed in Zager.
The claim that the Component Parts Doctrine did not survive the statutory revision was dismissed out of hand. “We find no merit to this argument” gives us great guidance as to how well that argument was received. The opinion went on to note that nothing in the legislation supported the claim that common law defenses being nullified.
More interesting is the analysis related to the design of the component. The plaintiff’s attorney attempted to sidestep the Component Parts Doctrine by claiming that the rear seatback, standing alone, was defective. The Court was not fooled. The holding correctly notes that the claimed defective product, a rear seatback which has inadequate cargo retention, relates to the operation of the final assembled vehicle. The Twelfth District noted that the core argument was that the component “caused harm upon its integration into the end product or system”.
This decision is a huge win for Ohio manufactures of component parts. To read the decision, click here.