State Farm General Insurance Company (Subrogee of Alfred Badal) Vs. Colder Products Company


    Stephen Smith and Sung Ho (Sean) Kim obtained summary judgment on behalf of Colder Products Company in a lawsuit brought by State Farm General Insurance Company. Plaintiff, State Farm, claimed that Colder Products Company ("CPC") caused or was responsible for property damage that occurred to State Farm's insured Alfred Badal's home. Plaintiff alleged that the property damage resulted from water leaking from a coupling designed and manufactured by CPC. At the time of the incident, the subject coupling was attached or assembled to a Watts RIL-10 water filter system.

    Defendant CPC contended that it was not responsible for the incident and property damage because the subject coupling was not intended to be used with a Watts RIL-10 water filter system. In fact, the RIL-10 water filter has an on-product label that instructs users to assemble or attach brass fittings to the water filter. Those brass fittings are packaged along with the RIL-10 water filter. CPC further contended that there was no evidence of product defect with the subject coupling.

    Based on the foregoing, the court found that CPC sustained its initial substantive burden of proof, so the burden shifted to plaintiff to establish a triable issue of material fact. The court found that CPC established that there was no evidence of product defect with the coupling, that the coupling was misused, and that the coupling was not used for its intended purpose.

    In an attempt to establish a triable issue of material fact, State Farm offered a declaration from an expert, who alleged that the subject coupling had a product defect. State Farm's expert also explained that someone removed the subject coupling from another water filter system and then installed the coupling into the Watts RIL-10 filter.

    In response to State Farm's expert's declaration, CPC reasoned that, pursuant to well-established case law, CPC cannot, and should not be forced to, anticipate every unintended and unforeseeable manner by which its coupling would be broken apart from another filter system and then incorporated into another filter. CPC concluded that it should not be held liable for another person's engineering spirit by which s/he ignored the installation instructions for the Watts RIL-10 filter and cannibalized two different water filter systems to create one Frankenstein-like water filter system.

    The court held that plaintiff failed to overcome its burden to create a triable issue of fact. Accordingly, summary judgment was granted in favor of CPC and as against State Farm.

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