Clifton A. Little Ii Et Ano, V. Hardie-tynes Co. Inc.

CourtCourt of Appeals of Washington
DecidedAugust 25, 2025
Docket86318-5
StatusPublished

This text of Clifton A. Little Ii Et Ano, V. Hardie-tynes Co. Inc. (Clifton A. Little Ii Et Ano, V. Hardie-tynes Co. Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Clifton A. Little Ii Et Ano, V. Hardie-tynes Co. Inc., (Wash. Ct. App. 2025).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

CLIFTON A. LITTLE, II and FANNIE M. LITTLE, husband and wife, No. 86318-5-I

Respondents, DIVISION ONE

v. PUBLISHED OPINION

HARDIE-TYNES CO., INC.,

Appellant.

AIR & LIQUID SYSTEMS CORPORATION, as successor-by- merger to BUFFALO PUMPS, INC.; A.W. CHESTERTON COMPANY; BW/IP, INC., f/k/a BORG-WARNER INDUSTRAIL PRODUCTS, successor- in-interest to BYRON JACKSON PUMPS; COPES-VULCAN, INC.; FOSTER WHEELER LLC; FRASER’S BOILER SERIVCE, INC.; GENERAL ELECTRIC COMPANY; IMO INDUSTRIES, INC., individually and as successor-in-interest to DE LAVAL TURBINE, INC.; ITT CORPORATION, as successor-in-interest to FOSTER VALVES; METROPOLITAN LIFE INSURANCE COMPANY; NORTH COAST ELECTRIC COMPANY; PFIZER, INC.; P-G INDUSTRIES, INC., as successor-in-interest to PRYOR GIGGEY CO., INC.; UNION CARBIDE CORPORATION; VELAN VALVE CORPORATION; VIACOMCBS, INC.; WARREN PUMPS, LLC, individually and as successor-in-interest to QUIMBY PUMP COMPANY; CARRIER CORPORATION; FLOWSERVE US No. 86318-5-I/2

INC., solely as successor-in-interest to EDWARD VALVES, INC.; TATE ANDALE, LLC; THE WM. POWELL COPANY; WEIR VALVE & CONTROLS USA INC., individually and as successor-in-interest to ATWOOD & MORRILL CO., INC.; and THE NASH ENGINEERING COMPANY,

Defendants.

BIRK, J. — Under the product line doctrine, a successor corporation may, in

certain circumstances, be held liable for its predecessor’s liability for product

liability claims. In this appeal, we first affirm the superior court’s ruling after a bench

trial that a corporate acquisition that left the predecessor with assets, but only for

the purpose of liquidation, rendered the predecessor a mere corporate shell.

However, we further hold that where there is no evidence that the successor

corporation continued a product line with the product defect for which the law

imposes liability, specifically here, where there is no evidence that the successor

manufactured or sold asbestos containing products, the evidence does not allow

the conclusion that the successor continued the same product line. As a result,

we must reverse the superior court’s judgment for plaintiffs, and remand for entry

of judgment in favor of the defendant.

I

Clifton Little suffers from mesothelioma caused by exposure to asbestos.

Little served in the United States Navy from 1970 to 1974, and he worked at the

Puget Sound Naval Shipyard from 1974 to 1979. Dr. Carl Brodkin wrote that Little’s

“bystander occupational exposure” while serving in the Navy, and while working at

2 No. 86318-5-I/3

the Puget Sound Naval Shipyard, were causes of his mesothelioma. Brodkin

identified forced draft blowers on the USS Kitty Hawk and USS Ranger, as well as

“pumps” on the USS Constellation, as causes of Little’s asbestos exposure. Navy

records showed that forced draft blowers for the USS Kitty Hawk and USS Ranger

and “boiler feed pumps” for the USS Constellation had been supplied to the Navy

by Hardie-Tynes Manufacturing Company (Old H-T). The available evidence

implied that those components were manufactured before 1960.

In 1997, Old H-T entered into an Asset Purchase Agreement (APA) to sell

certain assets to HT Acquisition Inc., later re-named Hardie-Tynes Co., Inc. (New

H-T). Old H-T retained certain other assets and obligations to New H-T, and the

APA contemplated that after the sale Old H-T would merge into Hardie-Tynes LLC.

In July 2020, Little and his wife, Fannie Little, filed an action against New H-

T and others seeking damages related to Little’s mesothelioma diagnosis. New H-

T did not answer. In 2021, the superior court entered findings and a default

judgment against New H-T for $5,500,892.12, an amount determined after

offsetting amounts Little had recovered from other defendants. In 2022, New H-T

appeared and moved to set aside the default order and vacate the default

judgment. The superior court granted New H-T’s motion in part, vacating the

default order as to liability but not as to causation or damages. The sole question

left for determination was whether New H-T had successor liability for Old H-T’s

asbestos containing products under Washington’s product line doctrine.1

1 Little argued that New H-T was liable under a de facto merger theory, but

this theory was rejected at summary judgment.

3 No. 86318-5-I/4

The parties both filed motions for summary judgment, both arguing they

were entitled to summary judgment under the product line doctrine. The superior

court granted summary judgment to the Littles on two of the three elements of the

product line doctrine, the “same product line” and “goodwill” elements. The

superior court denied New H-T’s motion for summary judgment. The superior court

held a one day bench trial to determine the final element, whether New H-T

acquired substantially all of Old H-T’s assets, leaving it a “mere corporate shell.”

The superior court decided in the Littles’ favor, finding New H-T liable.

On appeal, New H-T challenges the trial evidence supporting the superior

court’s finding that it acquired substantially all of Old H-T’s assets, leaving it a mere

corporate shell, and the superior court’s denial of its motion for summary judgment

on the same product line element.

II

“The general rule in Washington is that a corporation purchasing the assets

of another corporation does not, by reason of the purchase of assets, become

liable for the debts and liabilities of the selling corporation.” Hall v. Armstrong Cork,

Inc., 103 Wn.2d 258, 261-62, 692 P.2d 787 (1984). One exception to this general

rule is the “product line doctrine.” Leren v. Kaiser Gypsum Co., 9 Wn. App. 2d 55,

62, 442 P.3d 273 (2019). Under the product line doctrine, “successor liability

arises where one corporation benefits from another’s goodwill after acquiring its

product line.” Id. Application of the doctrine requires the court

(1) to determine whether the transferee has acquired substantially all the transferor’s assets, leaving no more than a mere corporate shell; (2) to determine whether the transferee is holding itself out to the

4 No. 86318-5-I/5

general public as a continuation of the transferor by producing the same product line under a similar name; and (3) to determine whether the transferee is benefitting from the goodwill of the transferor.

Martin v. Abbott Labs., 102 Wn.2d 581, 614, 689 P.2d 368 (1984). This “narrowly

drawn rule” applies to product liability claims and “strikes a fair balance among the

competing considerations of products liability and corporate acquisitions.” Id. at

616. Three justifications underlie the rationale for the product line doctrine:

First, the plaintiff would have no other recovery than that against the successor corporation. Secondly, the successor corporation has a greater ability to spread the risk among future consumers of the same product. Thirdly, the successor corporation benefits from the assumption of the old corporation’s goodwill and therefore should shoulder the burdens associated with those products.

George v. Parke-Davis, 107 Wn.2d 584, 589-90, 733 P.2d 507 (1987).

A

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