Jimenez v. Superior Court

127 Cal.Rptr.2d 614 (2002)

Facts

McMillin Scripps II completed the Galleria and Renaissance housing developments. Viking Industries, Inc. (Viking) manufactured the windows in the Galleria development; T.M. Cobb Company (Cobb) manufactured the windows in the Renaissance development. Ps, owners of one of the Galleria homes, brought this action against window manufacturers Viking and Cobb, and also against two companies (Medallion Industries, Inc., and Minnoch Supply Co.) that had supplied and installed the windows. Ps asserted that Ds had 'designed, developed, manufactured, produced, supplied and placed into the stream of commerce' defective windows installed in the Galleria and Renaissance homes and that the defects caused property damage. P alleged strict liability and negligence causes of action. D moved for summary adjudication of the strict liability cause of action. D argued that the manufacturer of a product installed in a mass-produced home, unless it has ownership or control over the housing development, cannot be held strictly liable to a homeowner for a defective or dangerous condition in the home. Ps argued that manufacturers of component parts of mass-produced houses are strictly liable for damages caused by those component parts, including damage to other parts of the houses in which they are installed. Ps alleged damages to the 'stucco, insulation, framing, drywall, paint, wall coverings, floor coverings, baseboards, and other parts of the home.' D was granted its motion for summary adjudication. P petitioned for a writ of mandate. The Court of Appeal issued a writ directing the trial court to vacate its order granting the defense motion for summary adjudication. It held that the doctrine of strict products liability applied to manufacturers of defective component parts installed in mass-produced homes and that this strict liability extended to injuries to other parts of the house in which the defective component was installed. Ds appealed.