Davis House Secures Summary Judgment for Materials Supplier in Product Liability Case

Davis House secured summary judgment for a construction-materials supplier in a product-liability lawsuit arising from a catastrophic gas-grill explosion at an apartment complex, thus preventing the materials supplier from being pulled into liability for a product it did not manufacture or sell. This ruling marked the first successful application in Mississippi of the “component parts doctrine” outside the pharmaceutical context.

The case arose from an explosion of a gas grill located in an apartment complex’s outdoor kitchen. The plaintiff sustained serious injuries and filed suit against multiple defendants, asserting claims for negligence and violations of the Mississippi Products Liability Act (“MPLA”).

Although the plaintiff alleged that our client designed, engineered, manufactured, and sold a prefabricated grill enclosure, the facts and undisputed evidence showed otherwise. Our client did not manufacture a finished enclosure at all. Instead, it sold raw construction materials and component parts that a third-party contractor later incorporated into a custom-built structure. The supplier did not design the enclosure, did not assemble it, and had no role in how it was ultimately constructed or installed.

The MPLA provides the exclusive remedy to any action for damages caused by a product. This includes theories of strict liability or negligence stemming from manufacturing defects, defective warnings or instructions, design defects, or where a product breached an express warranty. See Miss. Code Ann. § § 11-1-63(a)(i)(1)-(4).

Mr. House moved for summary judgment based on the “component parts doctrine,” which protects manufacturers and suppliers who provide non-defective components that are later incorporated into another party’s final product. As explained by the Fifth Circuit, “if the component-part manufacturer does not participate in the integration of the component into the finished product, it is not liable for defects in the final product if the component itself is not defective.” Smith v. Robin Am., Inc., 484 F. App’x 908, 914 (5th Cir. 2012). Mr. House further argued that the MPLA reflects the same principle: a manufacturer is responsible only for the product it actually makes, not for a product that comes into existence through the independent actions of a third party.

The court agreed and found that our client merely supplied component materials and played no role in designing or constructing the grill enclosure, which was the finished product alleged to be defective. The court specifically applied the component parts doctrine and held that the components supplied by our client were not defective and that our client did not substantially participate in their integration into the final product. Because no genuine issue of material fact existed as to whether our client was liable for any defect in the grill enclosure or any hazardous design of the enclosure itself, the claims against our client were dismissed in full.

This ruling removed our client from the case entirely, sparing it the cost, risk, and reputational exposure of a jury trial over a product it did not create. It also represents an important development in Mississippi product-liability law, confirming that suppliers and manufacturers cannot be held responsible for the design or safety of products built by others using their materials.

This result underscores ACB’s ability to protect manufacturers, suppliers, and their insurers from being swept into high-exposure product-liability litigation — and to end those cases early, before unnecessary expense and risk ever reach a jury.

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