Partners Richard S. Diestel and Alison M. Crane and associate Errol C. Dauis obtained summary judgment in a wrongful death and products liability case in which plaintiffs pursued a multi-million dollar damages recovery.
Plaintiffs were the surviving wife and children of a man who sustained fatal injuries after falling from a chairlift at a ski resort. Plaintiffs’ complaint alleged wrongful death, strict products liability, and negligence against numerous defendants including the ski resort where the fatal incident took place and Bledsoe’s client, a component parts manufacturer of the chairlift from which the decedent fell. Subsequently, the ski resort filed a cross complaint for indemnity, contribution, and breach of warranty against the supplier.
In its motion, Bledsoe argued that as to plaintiffs’ complaint, summary judgment for the supplier was proper under the component parts defense. That defense states that a provider of a component part for a finished product is not liable for injury caused by the finished product if (1) the component part was itself not defective and (2) the component supplier did not participate in the integration of those parts into the finished product. Bledsoe showed that the supplier was not a manufacturer of industrial parts, and that there is no evidence that any part supplied for use in the chairlift malfunctioned or otherwise failed on the day of the incident. Bledsoe also showed that the supplier did not participate in the integration of the parts it supplied into chairlift. Thus, the supplier should be shielded from liability.
Further, as to the ski resort’s cross complaint, Bledsoe argued that the ski resort’s claim for breach of warranty against the supplier fails because it never communicated or otherwise made any representations to the ski resort regarding the suitability of the parts supplied that were used in the chairlift, resulting in a lack of privity of contract between the ski resort and supplier. Further, Bledsoe argued the supplier had no duty to warn the ski resort about the use of another defendant’s product in the chairlift.
After one year of briefing, hearings, and deliberation, the Court granted the supplier’s motion for summary judgment in full, finding that plaintiffs’ product liability claim failed as there was no evidence that the supplier has provided a defective product that caused the plaintiffs’ injuries. The Court found that the supplier was entitled to summary judgment based on an affirmative defense under the Component Parts Doctrine. As a result of the supplier prevailing on the merits, the Court also granted the supplier’s MSJ as to the ski resort’s cross complaint for indemnity and breach of warranty. The Court ruled that there cannot be indemnity without a finding of liability. Further, Bledsoe successfully showed that no privity existed between the supplier and the ski resort and therefore there can be no breach of warranty.