Background: Plaintiff experienced issues with his Daikin-brand HVAC system which was
designed, manufactured, sold and installed by corporate entities other than Daikin NA, which only sold
replacement parts to Plaintiff. Plaintiff asserted claims against defendants for breach of express warranty,
breach of the implied warranty of merchantability, intentional and negligent misrepresentation and violation
of M.G.L. c. 93A.
The Court also addressed other issues PLAC raised in its amicus brief, including that the district court
improperly held J&J responsible for harm allegedly caused by opioids sold by other companies. In
addition, the Court recognized a manufacturer lacks control over its product once sold, noting a “product
manufacturer’s responsibility is to put a lawful, non-defective product into the market. There is no common
law tort duty to monitor how a consumer uses or misuses a product after it is sold.”
Following motions for summary judgment, only Plaintiff's claims for breach of the implied warranty of
merchantability, misrepresentation, and violation of M.G.L. c. 93A were allowed to proceed to trial. The
jury held Daikin NA liable for $10 million even though plaintiff’s own expert testified defects elsewhere in
the HVAC system - for which Daikin NA was not responsible - caused the replacement parts (sold to Plaintiff
for less than $9,000) to fail prematurely.
Daikin NA filed a motion for judgment notwithstanding the verdict and a motion for a new trial or
remittitur. Both motions were denied and Daikin NA appealed.
Result: The SJC granted Daikin NA's application for direct appellate review, reversed the
trial court's decision, and remanded for reconsideration of damages on the tort claim. The SJC concluded
that given
the absence of evidence of any defect in the coils Daikin NA distributed, the component parts doctrine
precluded Plaintiff's breach of warranty claim against Daikin NA.
Significance: The SJC's decision extended tort-based component parts doctrine to UCC
merchantability claims for purely economic loss. It adopted the position PLAC urged that the component parts
doctrine applies to non-standalone components that have no functional capability unless integrated into
other products, to specialized components that are designed only for use in an integrated product, and to
both tort and warranty claims.
In its decision, the SJC acknowledged the amicus brief submitted by PLAC.
A copy of the SJC's decision and PLAC’s brief, authored by
James M. Campbell
and
Christopher R.
Howe (Campbell Conroy & O'Neil, PC), are available for download below.
View PLAC’s Brief
View the Court’s Opinion