Willis v. Raymark Industries, Inc.

905 F.2d 793
CourtCourt of Appeals for the Fourth Circuit
DecidedJune 15, 1990
DocketNos. 89-1704 to 89-1706
StatusPublished
Cited by9 cases

This text of 905 F.2d 793 (Willis v. Raymark Industries, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Willis v. Raymark Industries, Inc., 905 F.2d 793 (4th Cir. 1990).

Opinion

K.K. HALL, Circuit Judge:

The Celotex Corporation appeals from judgments entered after a jury trial in favor of four former insulation workers and their wives 1 on their claims for asbestos-related injuries. Two other plaintiffs, Roy B. Bass and Richard L. Taylor, cross-appeal from the district court’s denial of their motions for new trials after judgment was entered on jury verdicts against them. Finding no error, we affirm.

I.

Seven former employees of E.I. duPont de Nemours and Company (“duPont”) at the Spruance Plant in Richmond, Virginia, filed an action in the District Court for the Northern District of Texas against fourteen manufacturers of asbestos-containing materials. This case was transferred to the Eastern District of Virginia and consolidated with similar actions filed by other former duPont employees. The consolidated case was then divided into two sets of six cases each. This appeal concerns the six-case set which went to trial in Norfolk in November 1988.

The employees’ action claimed compensatory and punitive damages on the grounds that the manufacturers supplied asbestos-containing products to duPont’s Spruance Plant without warning the employees of the possible adverse health effects. Five of the employees had worked as insulators for duPont, a job which required them to handle the asbestos-containing products on a regular basis. Prior to trial, each of the defendant manufacturers except Celotex and Raymark Industries, Inc. settled with each of the plaintiffs.

After a jury trial, judgment was entered on the verdicts against Celotex and Ray-mark and in favor of four of the employees and their wives as follows: Vincent H. Lewis — $150,000; Herman L. Mensing— $300,000; Elwood F. Hamlet — $200,000; Daniel L. Willis — $100,000.2 Judgment was also entered on the verdict in favor of the two manufacturers against Roy B. Bass and Richard L. Taylor, and their motion for new trial was denied. Celotex appeals,3 and Bass and Taylor cross-appeal.

II.

On appeal, Celotex contends that the trial court erred in refusing to permit the [796]*796“sophisticated user” defense. Celotex also contends that Virginia’s Statute of Repose is an absolute bar to the employees’ claims. In their cross-appeal, Bass and Taylor contend that the trial court abused its discretion in denying their motion for a new trial because the evidence supporting their claims was essentially indistinguishable from that adduced by the prevailing plaintiffs. We address each of these issues in turn.

Simply stated, the sophisticated user defense may be permitted in cases involving an employer who was aware of the inherent dangers of a product which the employer purchased for use in its business. Such an employer has a duty to warn his employees of the dangers of the product, and the manufacturer is absolved of any concurrent duty to warn those same employees. Phrased another way, if the employer/purchaser has “equal knowledge” of the product’s dangers, then the manufacturer may be able to rely on the employer/purchaser to protect its own employees from harm. See generally In re: Asbestos Litigation (Mergenthaler), 542 A.2d 1205 (Del.Super.Ct.1986). “Equal knowledge” alone, however, is not enough.

Virginia recognizes the sophisticated user defense. In Featherall v. Firestone Tire and Rubber Co., 219 Va. 949, 252 S.E.2d 358, 366 (1979), the Virginia court adopted the formulation of the defense set forth in Restatement (Second) of Torts § 388 (1965).4 Comment n to § 388 has been incorporated into Virginia law.5 Goodbar v. Whitehead Bros., 591 F.Supp. 552, 557 (W.D.Va.1984), aff'd, 769 F.2d 213 (4th Cir.1984). Comment n was recently considered by this Court in the context of an action very similar on its facts to that involved in the instant appeal. Oman v. Johns-Manville Corp., 764 F.2d 224 (4th Cir.), cert. denied sub nom. Oman v. H.K. Porter, 474 U.S. 970, 106 S.Ct. 351, 88 L.Ed.2d 319 (1985). Oman is dispositive of this issue.

In Oman, this Court, sitting en banc, construed Comment n as requiring the balancing of the following factors to determine the extent of a manufacturer’s duty to warn;

(1) the dangerous condition of the product; (2) the purpose for which the product is used; (3) the form of any warnings given; (4) the reliability of the third party as a conduit of necessary information about the product; (5) the magnitude of [797]*797the risk involved; and (6) the burdens imposed upon the supplier by requiring that he directly warn all users.

Id. at 233.

Applying this balancing test to the facts before it, the Oman court found that the product, asbestos-containing insulation materials, was “very dangerous” and that the burden on the manufacturers in placing a warning on the product was “not great.” The court further found that the employer was unaware of the danger until 1964, and once it became aware, it failed to convey such knowledge to its employees. Thus, the en banc court held that the lower court did not err in refusing to give a sophisticated user instruction to the jury. Id. Celotex’s efforts to distinguish Oman are unavailing.

Both Oman and the instant case involve the same type of product, asbestos-containing insulation, and indeed Celotex cites nothing in the record to show that its product was less dangerous than the Oman product. Moreover, Celotex did not contend that it would have been unduly burdensome to have placed warnings on the products. No warnings were even attempted, and Celotex may not now argue that warnings would probably have had little effect.

Celotex argues extensively that it should now be absolved of liability arising out of its failure to warn because duPont itself possessed extensive knowledge of the dangers of asbestos from at least 1960. Celo-tex’s proffer of proof on this issue, however, does not address one critical point: whether Celotex knew the extent of du-Pont’s knowledge during or prior to the period of the plaintiffs’ exposure. Celotex may not escape liability by reconstructing the past to show merely what the employer/purchaser knew. Comment n clearly focuses on what the product manufacturer knew and the reasonableness of its reliance on the employer prior to and during the time the workers were exposed. Moreover, Celotex offers no evidence that it apprised duPont of the dangers of the insulation or that it attempted to ascertain whether duPont could reasonably be relied upon to disseminate information about the dangers of the product. The fact that an employer possesses knowledge of a product’s dangers does not extinguish the manufacturer’s liability unless the manufacturer can also show that it had reason to believe that the employer was or would be acting to protect the employees. Celotex has made no such showing here. The district court did not err in excluding evidence of the sophisticated user defense.

III.

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905 F.2d 793 (Fourth Circuit, 1990)

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