RSSJohnson v. American Standard, Inc. (2008) 43 Cal.4th 56, 74 Cal.Rptr.3d 108
An EPA certified HVAC (heating, ventilation and air conditioning) technician who worked on commercial air conditioning systems, filed a products liability action against a number of manufacturers of air conditioning equipment, chemical manufacturers and chemical suppliers. The plaintiff alleged he was injured by exposure to phosgene gas during maintenance and repair of commercial air conditioning systems, and that the defendants should have warned him that the gas, which can cause a potentially fatal lung disease, is created during the process of brazing, or welding, refrigerant lines containing R-22 refrigerant.
The manufacturer moved for summary judgment, arguing that under the sophisticated user doctrine, it had no duty to warn because the risk was within the professional knowledge of HVAC installers and repairers. The trial court granted summary judgment and the court of appeal affirmed, holding that California law recognizes the sophisticated user doctrine, and that the undisputed evidence showed that HVAC technicians could reasonably be expected to know the hazard of brazing refrigerant lines.
The California Supreme Court affirmed, adopting the sophisticated user doctrine to negate a manufacturer’s duty to warn of a products potential danger when the plaintiff has or should have advanced knowledge of the product’s inherent hazards:
Los Angeles