products liability doctrine in California

2015(See Soule v. General Motors Corp. (1994) 8 Cal.4th 548, 572-573 ; Doupnik v. General Motors Corp. (1990) 225 Cal.App.3d 849, 862-864 .) Beyond showing an “abstract ‘defect’” in the product, the plaintiff must demonstrate that the (Fn. continued on next page.) 21 Bettencourt, the allegations identified as sufficient to state a products liability claim included an allegation that the products to which the pertinent tool or machine was applied released no hazardous dust when the tool or machine was not operating.

2013However, to prove a risk was unforeseeable, a manufacturer must show that the intervening act “produce[d] harm of a kind and degree so far beyond the risk the original tortfeasor should have foreseen that the law deems it unfair to hold him [or her] responsible.” (Soule, supra, 8 Cal.4th at p. 573, fn. 9 .) This principle is illustrated by the cases on which Navistar relies in asserting that “[o]ther jurisdictions have had no hesitation in holding criminal acts to be superseding causes in actions for product liability.” Stahlecker v. Ford Motor Co. (2003) 266 Neb. 601 [ 667 N.W.2d 244 ] involv

2022It is true that Vandermark includes a citation to Dow and also states that Ford “cannot delegate its duty to have its cars delivered to the ultimate purchaser free from dangerous defects.” (Vandermark, supra, 61 Cal.2d at p. 261 .) But Vandermark is a products liability case, and the nondelegable duty doctrine at issue in Dow is not a products liability doctrine.

2021The Doctrine of Strict Products Liability in California Greenman v. Yuba Power Products, Inc. (1963) 59 Cal.2d 57, 62 (Greenman) established the doctrine of strict products liability when it held “[a] manufacturer is strictly liable in tort when an article he places on the market, knowing that it is to be used without inspection for defects, proves to have a defect that causes injury to a human being.” “The purpose of such liability is to insure that the costs of injuries resulting from defective products are borne by the manufacturers that put such products on the market rather than by the in

1995Becker relied upon this factor almost exclusively in distinguishing the rule, announced in Tauber-Arons and its progeny, that strict liability should not be imposed upon sellers of used *1207 merchandise: “The paramount policy of the strict products liability rule remains the spreading throughout society of the cost of compensating otherwise defenseless victims of manufacturing defects. [Citations.]” (Becker, supra, 38 Cal.3d at p. 466 .) But the court in Tauber-Arons, quoting a similar statement from this court’s decision in Price v. Shell Oil Co., supra, 2 Cal.3d 245, 251 , that loss spreadi

1995Becker relied upon this factor almost exclusively in distinguishing the rule, announced in Tauber-Arons and its progeny, that strict liability should not be imposed upon sellers of used *1207 merchandise: “The paramount policy of the strict products liability rule remains the spreading throughout society of the cost of compensating otherwise defenseless victims of manufacturing defects. [Citations.]” (Becker, supra, 38 Cal.3d at p. 466 .) But the court in Tauber-Arons, quoting a similar statement from this court’s decision in Price v. Shell Oil Co., supra, 2 Cal.3d 245, 251 , that loss spreadi

2007Olson Corp. (1972) 8 Cal.3d 121, 133 , 104 Cal.Rptr. 433 , 501 P.2d 1153 & Escola v. Coca-Cola Bottling Co., supra, 24 Cal.2d at pp. 461-462, 150 P.2d 436 ; accord, Barrett v. Superior Court (1990) 222 Cal.App.3d 1176, 1186 , 272 Cal.Rptr. 304 ; Vandermark v. Ford Motor Co., supra, 61 Cal.2d at pp. 262-263, 37 Cal.Rptr. 896 , 391 P.2d 168 .) Under the doctrine of strict products liability, the liability of all defendants in the chain of distribution "is joint and several." ( Kaminski v. Western MacArthur Co. (1985) 175 Cal.App.3d 445, 455-456 , 220 Cal.Rptr. 895 ; Wimberly, supra, 56 Cal.App.4

2007Olson Corp. (1972) 8 Cal.3d 121, 133 , 104 Cal.Rptr. 433 , 501 P.2d 1153 & Escola v. Coca-Cola Bottling Co., supra, 24 Cal.2d at pp. 461-462, 150 P.2d 436 ; accord, Barrett v. Superior Court (1990) 222 Cal.App.3d 1176, 1186 , 272 Cal.Rptr. 304 ; Vandermark v. Ford Motor Co., supra, 61 Cal.2d at pp. 262-263, 37 Cal.Rptr. 896 , 391 P.2d 168 .) Under the doctrine of strict products liability, the liability of all defendants in the chain of distribution "is joint and several." ( Kaminski v. Western MacArthur Co. (1985) 175 Cal.App.3d 445, 455-456 , 220 Cal.Rptr. 895 ; Wimberly, supra, 56 Cal.App.4

2021The Doctrine of Strict Products Liability in California Greenman v. Yuba Power Products, Inc. (1963) 59 Cal.2d 57, 62 (Greenman) established the doctrine of strict products liability when it held “[a] manufacturer is strictly liable in tort when an article he places on the market, knowing that it is to be used without inspection for defects, proves to have a defect that causes injury to a human being.” “The purpose of such liability is to insure that the costs of injuries resulting from defective products are borne by the manufacturers that put such products on the market rather than by the in

2011(Bostick, supra, 147 Cal.App.4th at p. 88 ; Greenman v. Yuba Power Products, Inc. (1963) 59 Cal.2d 57, 63 [ 27 Cal.Rptr. 697 , 377 P.2d 897 ] (Greenman); Vandermark v. Ford Motor Co. (1964) 61 Cal.2d 256, 262-263 [ 37 Cal.Rptr. 896 , 391 P.2d 168 ] (Vandermark).) The primary justification for creating the strict products liability doctrine was “ ‘to insure that the costs of injuries resulting from defective products are borne by the manufacturers that put such products on the market rather than by the injured persons who are powerless to protect themselves.’ [Citation.]” (Bostick, supra, 147 C

2015Generally, to establish a strict products liability claim, the plaintiff must prove that “there was a defect in the manufacture or design of the product and that such defect was a proximate cause of the injuries.” (Cronin, supra, 8 Cal.3d at p. 133 , italics added.) Although the evidence regarding those elements may overlap, they are distinct requirements.

2015Generally, to establish a strict products liability claim, the plaintiff must prove that “there was a defect in the manufacture or design of the product and that such defect was a proximate cause of the injuries.” (Cronin, supra, 8 Cal.3d at p. 133 , italics added.) Although the evidence regarding those elements may overlap, they are distinct requirements.

2018The doctrine of strict products liability "focusses not on the conduct of the manufacturer but on the product itself, and holds the manufacturer liable if the product was defective." ( Brown v. Superior Court (1988) 44 Cal.3d 1049 , 1056, 245 Cal.Rptr. 412 , 751 P.2d 470 .) The existence of a design defect may be established according to one of two alternative tests. ( Barker , supra , 20 Cal.3d at pp. 429-430, 143 Cal.Rptr. 225 , 573 P.2d 443 .) First, under the so-called consumer expectations test, a design is defective "if the plaintiff demonstrates that the product failed to perform as saf

2018The doctrine of strict products liability "focusses not on the conduct of the manufacturer but on the product itself, and holds the manufacturer liable if the product was defective." ( Brown v. Superior Court (1988) 44 Cal.3d 1049 , 1056, 245 Cal.Rptr. 412 , 751 P.2d 470 .) The existence of a design defect may be established according to one of two alternative tests. ( Barker , supra , 20 Cal.3d at pp. 429-430, 143 Cal.Rptr. 225 , 573 P.2d 443 .) First, under the so-called consumer expectations test, a design is defective "if the plaintiff demonstrates that the product failed to perform as saf

2007L.Rev. 779, 804.) The chief justification for creating the strict products liability doctrine was “to insure that the costs of injuries resulting from defective products are borne by the manufacturers that put such products on the market rather than by the injured persons who are powerless to protect themselves.” (Greenman, supra, 59 Cal.2d at p. 63 , citing Prosser, Strict Liability to the Consumer (1960) 69 Yale L.J. 1099 & Escola v. Coca Cola Bottling Co., supra, 24 Cal.2d at p. 461 (conc. opn. of Traynor, J.).) Vandermark v. Ford Motor Co., supra, 61 Cal.2d 256 , extended strict liability

2007L.Rev. 779, 804.) The chief justification for creating the strict products liability doctrine was "to insure that the costs of injuries resulting from defective products are borne by the manufacturers that put such products on the market rather than by the injured persons who are powerless to protect themselves." ( Greenman, supra, 59 Cal.2d at p. 63 , 27 Cal.Rptr. 697 , 377 P.2d 897 , citing Prosser, Strict Liability to the Consumer, 69 Yale L.J. 1099 & Escola v. Coca Cola Bottling Co., supra, 24 Cal.2d at p. 461 , 150 P.2d 436 (cone. opn. of Traynor, J.).) Vandermark v. Ford Motor Co., supra

2020Thus, the parties were ‘able to bear the cost of compensating for injuries’ [citation] and ‘play[ed] a substantial part in insuring that the product [was] safe or . . . [were] in a position to exert pressure on the manufacturer to that end.’ ” (Ibid.) “Beyond manufacturers, anyone identifiable as ‘an integral part of the overall producing and marketing enterprise’ is subject to strict liability.” (Arriaga v. CitiCapital Commercial Corp. (2008) 167 Cal.App.4th 1527, 1534 (Arriaga).) The doctrine of strict products liability, while broad, is not unlimited.

2016“In order to establish liability on a negligence theory, a plaintiff must prove duty, breach, causation, and damages.” (Conroy v. Regents of University of California (2009) 45 Cal.4th 1244, 1250 .) “Under the strict products liability doctrine, ‘[a] manufacturer is strictly liable in tort when an article [it] places on the market, knowing that [the article] is to be used without inspection for defects, proves to have a defect that 11 causes injury to a human being.’” (Arriaga v. CitiCapital Commercial Corp. (2008) 167 Cal.App.4th 1527, 1534 .) “Strict liability has been invoked for three types

2013Where, as here, "liability depends on the proof of a design defect, no practical difference exists between negligence and strict liability; the claims merge." (Lambert v. General Motors (1998) 67 Cal.App.4th 1179, 1185 (Lambert).) Thus, "[t]he jury could not have concluded that [GM] negligently designed the [Corvette] and at the same time conclude that it was not defective." (Id. at p. 1186.) The jury here, however, did just that: It found GM was negligent even though it also found the Corvette was not defective under the consumer expectation test, the only strict products liability test on wh

2013Where, as here, "liability depends on the proof of a design defect, no practical difference exists between negligence and strict liability; the claims merge." (Lambert v. General Motors (1998) 67 Cal.App.4th 1179, 1185 (Lambert).) Thus, "[t]he jury could not have concluded that [GM] negligently designed the [Corvette] and at the same time conclude that it was not defective." (Id. at p. 1186.) The jury here, however, did just that: It found GM was negligent even though it also found the Corvette was not defective under the consumer expectation test, the only strict products liability test on wh

1985(See, e.g., Escola, supra, 24 Cal.2d at p. 462 (conc. opn. of Traynor, J.) ["the risk of injury can be insured by the manufacturer and distributed among the public as a cost of doing business"]; Becker v. IRM Corporation, supra, 38 Cal.3d at p. 466 ["The paramount policy of the strict products liability rule remains the spreading throughout society of the cost of compensating otherwise defenseless victims of manufacturing defects"].) The same can be said of the claim that it would be unfair to impose strict liability on a retail druggist if the manufacturer is unavailable to answer in damages.

1985(See, e.g., Escola, supra, 24 Cal.2d at p. 462 (conc. opn. of Traynor, J.) ["the risk of injury can be insured by the manufacturer and distributed among the public as a cost of doing business"]; Becker v. IRM Corporation, supra, 38 Cal.3d at p. 466 ["The paramount policy of the strict products liability rule remains the spreading throughout society of the cost of compensating otherwise defenseless victims of manufacturing defects"].) The same can be said of the claim that it would be unfair to impose strict liability on a retail druggist if the manufacturer is unavailable to answer in damages.

2007Olson Corp. (1972) 8 Cal.3d 121, 133 [ 104 Cal.Rptr. 433 , 501 P.2d 1153 ] & Escola v. Coca Cola Bottling Co., supra, 24 Cal.2d at pp. 461-462; accord, Barrett v. Superior Court (1990) 222 Cal.App.3d 1176, 1186 [ 272 Cal.Rptr. 304 ]; Vandermark v. Ford Motor Co., supra, 61 Cal.2d at pp. 262-263.) Under the doctrine of strict products liability, the liability of all defendants in the chain of distribution “is joint and several.” (Kaminski v. Western MacArthur Co. (1985) 175 Cal.App.3d 445, 455-456 [ 220 Cal.Rptr. 895 ]; Wimberly, supra, 56 Cal.App.4th at p. 628 .) Accordingly, each of those def

2007Olson Corp. (1972) 8 Cal.3d 121, 133 [ 104 Cal.Rptr. 433 , 501 P.2d 1153 ] & Escola v. Coca Cola Bottling Co., supra, 24 Cal.2d at pp. 461-462; accord, Barrett v. Superior Court (1990) 222 Cal.App.3d 1176, 1186 [ 272 Cal.Rptr. 304 ]; Vandermark v. Ford Motor Co., supra, 61 Cal.2d at pp. 262-263.) Under the doctrine of strict products liability, the liability of all defendants in the chain of distribution “is joint and several.” (Kaminski v. Western MacArthur Co. (1985) 175 Cal.App.3d 445, 455-456 [ 220 Cal.Rptr. 895 ]; Wimberly, supra, 56 Cal.App.4th at p. 628 .) Accordingly, each of those def

2020(Anderson v. Owens-Corning Fiberglas Corp. (1991) 53 Cal.3d 987, 995 .) But regardless which type of defect the plaintiff alleges, he or she must first establish, as a threshold matter, "that the object or instrumentality claimed to be defective was in fact a 'product.' " (Brooks v. Eugene Burger Management Corp. (1985) 215 Cal.App.3d 1611, 1626 (Brooks).) This inquiry depends, in large part, on the policies underlying the strict products liability doctrine.

2016“In order to establish liability on a negligence theory, a plaintiff must prove duty, breach, causation, and damages.” (Conroy v. Regents of University of California (2009) 45 Cal.4th 1244, 1250 .) “Under the strict products liability doctrine, ‘[a] manufacturer is strictly liable in tort when an article [it] places on the market, knowing that [the article] is to be used without inspection for defects, proves to have a defect that 11 causes injury to a human being.’” (Arriaga v. CitiCapital Commercial Corp. (2008) 167 Cal.App.4th 1527, 1534 .) “Strict liability has been invoked for three types

2015(See Soule v. General Motors Corp. (1994) 8 Cal.4th 548, 572-573 [ 34 Cal.Rptr.2d 607 , 882 P.2d 298 ]; Doupnik v. General Motors Corp. (1990) 225 Cal.App.3d 849, 862-864 [ 275 Cal.Rptr. 715 ].) Beyond showing an “abstract ‘defect’ ” in the product, the plaintiff must demonstrate that the defect was appropriately causally related to the alleged injuries. ( Soule, supra, 8 Cal.4th at pp. 572-573.) Specifically, in an action based on injuries attributed to asbestos from potentially more than one source, to establish proximate causation regarding a manufacturer’s product, the plaintiff must show

2015(See Soule v. General Motors Corp. (1994) 8 Cal.4th 548, 572-573 ; Doupnik v. General Motors Corp. (1990) 225 Cal.App.3d 849, 862-864 .) Beyond showing an “abstract ‘defect’” in the product, the plaintiff must demonstrate that the (Fn. continued on next page.) 21 Bettencourt, the allegations identified as sufficient to state a products liability claim included an allegation that the products to which the pertinent tool or machine was applied released no hazardous dust when the tool or machine was not operating.

2015(Tellez-Cordova, supra, 129 Cal.App.4th at p. 585 ; Shields, supra, 205 Cal.App.4th at p. 797; Bettencourt, supra, 205 Cal.App.4th at p. 1117.) Hennessy argues that appellants cannot establish that fact because their first amended complaint alleges that the “sawing, chipping, hammering, scraping, sanding, breaking, removal, ‘rip-out’, and other manipulation” of asbestos-containing products “results] in the release of airborne asbestos fibers . . . .” However, although the complaint alleges that asbestos fibers generally may be released from products in many ways, it contains no specific allega

2015(Tellez-Cordova, supra, 129 Cal.App.4th at p. 585 ; Shields, supra, 205 Cal.App.4th at p. 797 ; Bettencourt, supra, 205 Cal.App.4th at p. 1117 .) Hennessy argues that petitioners cannot establish that fact, in view of their complaint and discovery responses.

2015(Tellez-Cordova, supra, 129 Cal.App.4th at p. 585 ; Shields, supra, 205 Cal.App.4th at p. 797; Bettencourt, supra, 205 Cal.App.4th at p. 1117.) Hennessy argues that appellants cannot establish that fact because their first amended complaint alleges that the “sawing, chipping, hammering, scraping, sanding, breaking, removal, ‘rip-out’, and other manipulation” of asbestos-containing products “results] in the release of airborne asbestos fibers . . . .” However, although the complaint alleges that asbestos fibers generally may be released from products in many ways, it contains no specific allega

2015(Tellez-Cordova, supra, 129 Cal.App.4th at p. 585 ; Shields, supra, 205 Cal.App.4th at p. 797 ; Bettencourt, supra, 205 Cal.App.4th at p. 1117 .) Hennessy argues that petitioners cannot establish that fact, in view of their complaint and discovery responses.

1974A leading case (Kriegler v. Eichler Homes, Inc., 269 Cal.App.2d 224 [ 74 Cal.Rptr. 749 ]), extended the products liability rule to a builder-developer of mass-produced homes for a defectively installed radiant heating system.

1974A leading case (Kriegler v. Eichler Homes, Inc., 269 Cal.App.2d 224 [ 74 Cal.Rptr. 749 ]), extended the products liability rule to a builder-developer of mass-produced homes for a defectively installed radiant heating system.

2022Corp. (1976) 55 Cal.App.3d 737, 748 , superseded by statute on another ground as stated in Barnett v. American-Cal Medical 32.

1981Corp. (1976) 55 Cal.App.3d 737, 748 [ 127 Cal.Rptr. 838 ].

2018The doctrine of strict products liability "focusses not on the conduct of the manufacturer but on the product itself, and holds the manufacturer liable if the product was defective." ( Brown v. Superior Court (1988) 44 Cal.3d 1049 , 1056, 245 Cal.Rptr. 412 , 751 P.2d 470 .) The existence of a design defect may be established according to one of two alternative tests. ( Barker , supra , 20 Cal.3d at pp. 429-430, 143 Cal.Rptr. 225 , 573 P.2d 443 .) First, under the so-called consumer expectations test, a design is defective "if the plaintiff demonstrates that the product failed to perform as saf

2018The doctrine of strict products liability "focusses not on the conduct of the manufacturer but on the product itself, and holds the manufacturer liable if the product was defective." ( Brown v. Superior Court (1988) 44 Cal.3d 1049 , 1056, 245 Cal.Rptr. 412 , 751 P.2d 470 .) The existence of a design defect may be established according to one of two alternative tests. ( Barker , supra , 20 Cal.3d at pp. 429-430, 143 Cal.Rptr. 225 , 573 P.2d 443 .) First, under the so-called consumer expectations test, a design is defective "if the plaintiff demonstrates that the product failed to perform as saf

2017In Campbell , supra , 32 Cal.3d 112 , 184 Cal.Rptr. 891 , 649 P.2d 224 , a passenger on a city bus was injured when the bus made a sharp turn and she was thrown to the floor. ( Id. at pp. 116-117, 184 Cal.Rptr. 891 , 649 P.2d 224 .) The injured passenger sued the bus manufacturer, alleging strict products liability due to a design defect based on the lack of a handrail or guardrail near her seat. ( Id. at p. 116, 184 Cal.Rptr. 891 , 649 P.2d 224 .) On appeal after the grant of a nonsuit, the Supreme Court reversed, in relevant part concluding that the passenger had presented sufficient evidenc

2017In Campbell , supra , 32 Cal.3d 112 , 184 Cal.Rptr. 891 , 649 P.2d 224 , a passenger on a city bus was injured when the bus made a sharp turn and she was thrown to the floor. ( Id. at pp. 116-117, 184 Cal.Rptr. 891 , 649 P.2d 224 .) The injured passenger sued the bus manufacturer, alleging strict products liability due to a design defect based on the lack of a handrail or guardrail near her seat. ( Id. at p. 116, 184 Cal.Rptr. 891 , 649 P.2d 224 .) On appeal after the grant of a nonsuit, the Supreme Court reversed, in relevant part concluding that the passenger had presented sufficient evidenc

2011(Bostick, supra, 147 Cal.App.4th at p. 88 ; Greenman v. Yuba Power Products, Inc. (1963) 59 Cal.2d 57, 63 [ 27 Cal.Rptr. 697 , 377 P.2d 897 ] (Greenman); Vandermark v. Ford Motor Co. (1964) 61 Cal.2d 256, 262-263 [ 37 Cal.Rptr. 896 , 391 P.2d 168 ] (Vandermark).) The primary justification for creating the strict products liability doctrine was “ ‘to insure that the costs of injuries resulting from defective products are borne by the manufacturers that put such products on the market rather than by the injured persons who are powerless to protect themselves.’ [Citation.]” (Bostick, supra, 147 C

2011(Bostick, supra, 147 Cal.App.4th at p. 88 ; Greenman v. Yuba Power Products, Inc. (1963) 59 Cal.2d 57, 63 [ 27 Cal.Rptr. 697 , 377 P.2d 897 ] (Greenman); Vandermark v. Ford Motor Co. (1964) 61 Cal.2d 256, 262-263 [ 37 Cal.Rptr. 896 , 391 P.2d 168 ] (Vandermark).) The primary justification for creating the strict products liability doctrine was “ ‘to insure that the costs of injuries resulting from defective products are borne by the manufacturers that put such products on the market rather than by the injured persons who are powerless to protect themselves.’ [Citation.]” (Bostick, supra, 147 C

2007Olson Corp. (1972) 8 Cal.3d 121, 133 [ 104 Cal.Rptr. 433 , 501 P.2d 1153 ] & Escola v. Coca Cola Bottling Co., supra, 24 Cal.2d at pp. 461-462; accord, Barrett v. Superior Court (1990) 222 Cal.App.3d 1176, 1186 [ 272 Cal.Rptr. 304 ]; Vandermark v. Ford Motor Co., supra, 61 Cal.2d at pp. 262-263.) Under the doctrine of strict products liability, the liability of all defendants in the chain of distribution “is joint and several.” (Kaminski v. Western MacArthur Co. (1985) 175 Cal.App.3d 445, 455-456 [ 220 Cal.Rptr. 895 ]; Wimberly, supra, 56 Cal.App.4th at p. 628 .) Accordingly, each of those def

2007Olson Corp. (1972) 8 Cal.3d 121, 133 [ 104 Cal.Rptr. 433 , 501 P.2d 1153 ] & Escola v. Coca Cola Bottling Co., supra, 24 Cal.2d at pp. 461-462; accord, Barrett v. Superior Court (1990) 222 Cal.App.3d 1176, 1186 [ 272 Cal.Rptr. 304 ]; Vandermark v. Ford Motor Co., supra, 61 Cal.2d at pp. 262-263.) Under the doctrine of strict products liability, the liability of all defendants in the chain of distribution “is joint and several.” (Kaminski v. Western MacArthur Co. (1985) 175 Cal.App.3d 445, 455-456 [ 220 Cal.Rptr. 895 ]; Wimberly, supra, 56 Cal.App.4th at p. 628 .) Accordingly, each of those def

2007L.Rev. 779, 804.) The chief justification for creating the strict products liability doctrine was “to insure that the costs of injuries resulting from defective products are borne by the manufacturers that put such products on the market rather than by the injured persons who are powerless to protect themselves.” (Greenman, supra, 59 Cal.2d at p. 63 , citing Prosser, Strict Liability to the Consumer (1960) 69 Yale L.J. 1099 & Escola v. Coca Cola Bottling Co., supra, 24 Cal.2d at p. 461 (conc. opn. of Traynor, J.).) Vandermark v. Ford Motor Co., supra, 61 Cal.2d 256 , extended strict liability

2007L.Rev. 779, 804.) The chief justification for creating the strict products liability doctrine was “to insure that the costs of injuries resulting from defective products are borne by the manufacturers that put such products on the market rather than by the injured persons who are powerless to protect themselves.” (Greenman, supra, 59 Cal.2d at p. 63 , citing Prosser, Strict Liability to the Consumer (1960) 69 Yale L.J. 1099 & Escola v. Coca Cola Bottling Co., supra, 24 Cal.2d at p. 461 (conc. opn. of Traynor, J.).) Vandermark v. Ford Motor Co., supra, 61 Cal.2d 256 , extended strict liability

2007Olson Corp. (1972) 8 Cal.3d 121, 133 [ 104 Cal.Rptr. 433 , 501 P.2d 1153 ] & Escola v. Coca Cola Bottling Co., supra, 24 Cal.2d at pp. 461-462; accord, Barrett v. Superior Court (1990) 222 Cal.App.3d 1176, 1186 [ 272 Cal.Rptr. 304 ]; Vandermark v. Ford Motor Co., supra, 61 Cal.2d at pp. 262-263.) Under the doctrine of strict products liability, the liability of all defendants in the chain of distribution “is joint and several.” (Kaminski v. Western MacArthur Co. (1985) 175 Cal.App.3d 445, 455-456 [ 220 Cal.Rptr. 895 ]; Wimberly, supra, 56 Cal.App.4th at p. 628 .) Accordingly, each of those def

2007(Wimberly, supra, 56 Cal.App.4th at p. 632; see also Barrett v. Superior Court, supra, 222 Cal.App.3d at p. 1189 .) That is, liability under the strict products liability doctrine—just as with vicarious liability—is imposed on a defendant irrespective of negligence, as a matter of social policy, not because of independent and culpable conduct.