negligent failure to warn claim (California) · Go Syfert
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negligent failure to warn claim in California

6 California opinions name it 3 courts 2017–2024 2 in the last five years

The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
Valentine v. Baxter Healthcare Corp.green
calctapp · 1999 · cited in 2 California opinions naming this issue, 2019–2019
2 sentences

2019Failure to warn A manufacturer has a duty to warn of facts which make a product dangerous or likely to be dangerous. "[A] product 'likely' to be dangerous will 'in all probability' or 'probably' be dangerous." ( Valentine v. Baxter Healthcare Corp. (1999) 68 Cal.App.4th 1467 , 1483, 81 Cal.Rptr.2d 252 ( Valentine ).) To establish a negligent failure to warn claim, the plaintiff must prove " 'that a manufacturer or distributor did not warn of a particular risk for reasons which fell below the acceptable standard of care, i.e., what a reasonably prudent manufacturer would have known and warned a

2019Failure to warn A manufacturer has a duty to warn of facts which make a product dangerous or likely to be dangerous. "[A] product 'likely' to be dangerous will 'in all probability' or 'probably' be dangerous." ( Valentine v. Baxter Healthcare Corp. (1999) 68 Cal.App.4th 1467 , 1483, 81 Cal.Rptr.2d 252 ( Valentine ).) To establish a negligent failure to warn claim, the plaintiff must prove " 'that a manufacturer or distributor did not warn of a particular risk for reasons which fell below the acceptable standard of care, i.e., what a reasonably prudent manufacturer would have known and warned a

22
Carlin v. Superior Courtgreen
cal · 1996 · cited in 5 California opinions naming this issue, 2017–2024
2 sentences

2019Failure to warn A manufacturer has a duty to warn of facts which make a product dangerous or likely to be dangerous. "[A] product 'likely' to be dangerous will 'in all probability' or 'probably' be dangerous." ( Valentine v. Baxter Healthcare Corp. (1999) 68 Cal.App.4th 1467 , 1483, 81 Cal.Rptr.2d 252 ( Valentine ).) To establish a negligent failure to warn claim, the plaintiff must prove " 'that a manufacturer or distributor did not warn of a particular risk for reasons which fell below the acceptable standard of care, i.e., what a reasonably prudent manufacturer would have known and warned a

2019Failure to warn A manufacturer has a duty to warn of facts which make a product dangerous or likely to be dangerous. "[A] product 'likely' to be dangerous will 'in all probability' or 'probably' be dangerous." ( Valentine v. Baxter Healthcare Corp. (1999) 68 Cal.App.4th 1467 , 1483, 81 Cal.Rptr.2d 252 ( Valentine ).) To establish a negligent failure to warn claim, the plaintiff must prove " 'that a manufacturer or distributor did not warn of a particular risk for reasons which fell below the acceptable standard of care, i.e., what a reasonably prudent manufacturer would have known and warned a

15
T.H. v. Novartis Pharmaceuticals Corporationgreen
cal · 2017 · cited in 2 California opinions naming this issue, 2019–2019
2 sentences

2019Failure to warn A manufacturer has a duty to warn of facts which make a product dangerous or likely to be dangerous. "[A] product 'likely' to be dangerous will 'in all probability' or 'probably' be dangerous." ( Valentine v. Baxter Healthcare Corp. (1999) 68 Cal.App.4th 1467 , 1483, 81 Cal.Rptr.2d 252 ( Valentine ).) To establish a negligent failure to warn claim, the plaintiff must prove " 'that a manufacturer or distributor did not warn of a particular risk for reasons which fell below the acceptable standard of care, i.e., what a reasonably prudent manufacturer would have known and warned a

2019Failure to warn A manufacturer has a duty to warn of facts which make a product dangerous or likely to be dangerous. "[A] product 'likely' to be dangerous will 'in all probability' or 'probably' be dangerous." ( Valentine v. Baxter Healthcare Corp. (1999) 68 Cal.App.4th 1467 , 1483, 81 Cal.Rptr.2d 252 ( Valentine ).) To establish a negligent failure to warn claim, the plaintiff must prove " 'that a manufacturer or distributor did not warn of a particular risk for reasons which fell below the acceptable standard of care, i.e., what a reasonably prudent manufacturer would have known and warned a

12
O'NEIL v. Crane Co.green
cal · 2012 · cited in 2 California opinions naming this issue, 2019–2019
2 sentences

2019Failure to warn A manufacturer has a duty to warn of facts which make a product dangerous or likely to be dangerous. "[A] product 'likely' to be dangerous will 'in all probability' or 'probably' be dangerous." ( Valentine v. Baxter Healthcare Corp. (1999) 68 Cal.App.4th 1467 , 1483, 81 Cal.Rptr.2d 252 ( Valentine ).) To establish a negligent failure to warn claim, the plaintiff must prove " 'that a manufacturer or distributor did not warn of a particular risk for reasons which fell below the acceptable standard of care, i.e., what a reasonably prudent manufacturer would have known and warned a

2019Failure to warn A manufacturer has a duty to warn of facts which make a product dangerous or likely to be dangerous. "[A] product 'likely' to be dangerous will 'in all probability' or 'probably' be dangerous." ( Valentine v. Baxter Healthcare Corp. (1999) 68 Cal.App.4th 1467 , 1483, 81 Cal.Rptr.2d 252 ( Valentine ).) To establish a negligent failure to warn claim, the plaintiff must prove " 'that a manufacturer or distributor did not warn of a particular risk for reasons which fell below the acceptable standard of care, i.e., what a reasonably prudent manufacturer would have known and warned a

12
Merrill v. Navegar, Inc.green
cal · 2001 · cited in 1 California opinions naming this issue, 2024–2024
1 sentence

2024(Carlin, supra, 13 Cal.4th at p. 1112 .) To succeed on a strict liability failure-to-warn claim, the plaintiff need only prove that the manufacturer “did not adequately warn of a particular risk that was known or knowable in light of the generally recognized and prevailing best scientific and medical knowledge available at the time of manufacture and distribution.” (Ibid.) Whether asserting a negligent or a strict liability failure-to-warn claim, the plaintiff must also establish that the manufacturer’s failure to warn “[was] a substantial factor in causing [the plaintiff’s] injury.” (Stevens

11
Stevens v. Parke, Davis & Co.green
cal · 1973 · cited in 1 California opinions naming this issue, 2024–2024
1 sentence

2024(Carlin, supra, 13 Cal.4th at p. 1112 .) To succeed on a strict liability failure-to-warn claim, the plaintiff need only prove that the manufacturer “did not adequately warn of a particular risk that was known or knowable in light of the generally recognized and prevailing best scientific and medical knowledge available at the time of manufacture and distribution.” (Ibid.) Whether asserting a negligent or a strict liability failure-to-warn claim, the plaintiff must also establish that the manufacturer’s failure to warn “[was] a substantial factor in causing [the plaintiff’s] injury.” (Stevens

11
Brown v. Superior Courtgreen
cal · 1988 · cited in 1 California opinions naming this issue, 2024–2024
1 sentence

2024(See Brown, supra, 44 Cal.3d at p. 1069, fn. 12 ; accord, Dobbs on Torts, § 466, p. 959.) To succeed on a negligent failure-to-warn claim, the plaintiff has the burden to prove that “a reasonably prudent manufacturer would have known and warned about” the risk. 7 HIMES v. SOMATICS, LLC Opinion of the Court by Groban, J.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in California. Read the followed side critically anyway.

Also cited on this issue (3)

CaseCitedYears
Taylor v. Elliott Turbomachinery Co. Inc. green
calctapp · 2009
2 sentences

2019Failure to warn A manufacturer has a duty to warn of facts which make a product dangerous or likely to be dangerous. "[A] product 'likely' to be dangerous will 'in all probability' or 'probably' be dangerous." ( Valentine v. Baxter Healthcare Corp. (1999) 68 Cal.App.4th 1467 , 1483, 81 Cal.Rptr.2d 252 ( Valentine ).) To establish a negligent failure to warn claim, the plaintiff must prove " 'that a manufacturer or distributor did not warn of a particular risk for reasons which fell below the acceptable standard of care, i.e., what a reasonably prudent manufacturer would have known and warned a

2019Failure to warn A manufacturer has a duty to warn of facts which make a product dangerous or likely to be dangerous. "[A] product 'likely' to be dangerous will 'in all probability' or 'probably' be dangerous." ( Valentine v. Baxter Healthcare Corp. (1999) 68 Cal.App.4th 1467 , 1483, 81 Cal.Rptr.2d 252 ( Valentine ).) To establish a negligent failure to warn claim, the plaintiff must prove " 'that a manufacturer or distributor did not warn of a particular risk for reasons which fell below the acceptable standard of care, i.e., what a reasonably prudent manufacturer would have known and warned a

22019–2019
Myers Building Industries, Ltd. v. Interface Technology, Inc. green
calctapp · 1993
1 sentence

2022(Id. at pp. 326–327.) In Trejo v. Johnson & Johnson (2017) 13 Cal.App.5th 110 , error was found on appeal where the trial court failed to include a special verdict question that would have “resolve[d] a necessary element of a negligent failure to warn claim.” (Id. at p. 137.) In Myers Building Industries, Ltd. v. Interface Technology, Inc. (1993) 13 Cal.App.4th 949 , the appellate court struck a punitive damages award where the jury, in returning a special verdict for breach of contract, determined the defendants 14 had acted with oppression, fraud or malice, but did not determine whether a to

12022–2022
Trejo v. Johnson green
calctapp5d · 2017
1 sentence

2022(Id. at pp. 326–327.) In Trejo v. Johnson & Johnson (2017) 13 Cal.App.5th 110 , error was found on appeal where the trial court failed to include a special verdict question that would have “resolve[d] a necessary element of a negligent failure to warn claim.” (Id. at p. 137.) In Myers Building Industries, Ltd. v. Interface Technology, Inc. (1993) 13 Cal.App.4th 949 , the appellate court struck a punitive damages award where the jury, in returning a special verdict for breach of contract, determined the defendants 14 had acted with oppression, fraud or malice, but did not determine whether a to

12022–2022

Where else courts name it

CA 6 (2017–2024) TX 4 (2022–2024) MO 4 (2006–2025) GA 3 (2019–2026) IL 3 (1991–2017) MD 2 (2011–2026) NY 2 (2017–2017) PA 2 (2005–2015) WI 2 (2000–2008) AL 2 (1998–2005)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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