Johnson v. U.S. Steel Corp.Annotate this Case
Johnson filed a products liability action, claiming that chronic exposure as an auto mechanic to benzene-containing products led him to develop acute myeloid leukemia. Defendants included U.S. Steel, which supplied a fabricator with a benzene-containing coal residue, “raffinate,” once the principal ingredient in Liquid Wrench, a solvent for loosening rusted bolts and machine parts. The court granted U.S. Steel, summary judgment, finding insufficient evidence to support claims for negligence and strict products liability under a design defect theory, citing the “component parts doctrine” (“bulk supplier defense”), under which the manufacturer of a component is not liable for injuries caused by the finished product into which the component was incorporated unless the component itself was defective and caused harm. Distinguishing cases that have held raw asbestos to be inherently defective and to contain a design defect under the consumer expectations test, the court held that raffinate is not inherently defective. The court of appeal agreed that the supplier of a raw material used in the manufacture of another product can be held liable for a design defect under the consumer expectations test only if the raw material is itself inherently defective, but held that summary judgment was inappropriate because the record did not contain evidence under that test negating the existence of a design defect in U.S. Steel coal raffinate.