California Supreme Court Limits Liability Of Manufacturers.

Defendant manufactured pumps and valves, and was sued for wrongful death caused by asbestos manufactured by third parties and added to the pumps after defendant sold them.  The California Supreme Court held that “a product manufacturer may not be held liable in strict liability or negligence for harm caused by another manufacturer’s product unless the defendant’s own product contributed substantially to the harm, or the defendant participated substantially in creating a harmful combined use of the product.”  O’Neil v. Crane Co.  (Sup. Ct.;  January 12, 2012) 53 Cal.4th 335, [266 P.3d 987, 135 Cal.Rptr.3d 288].