Product Liabilty - No Duty To Warn For Sophisticated Users

Scott Barber

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Product Liability: The California Supreme Court recently handed down its opinion in Johnson v. American Standard, Inc. (S139184) affirming that the "sophisticated user" doctrine is a valid defense in California.  Federal court have long held that there is no duty to warn a sophisticated user of a product's potential for harm.

Generally, in California a manufacturer has a duty to warn users of its products about the potential risks or harm.  In Johnson, the Defendant argued that it did not need to warn the Plaintiff, a heating and air-conditioning technician of the risks of using R-22, a gas used in air conditioners.  The Defendant argued that since Mr. Johnson was a sophisticated user, i.e. he was well-aware, due to his training and experience, of the risks associated with R-22, that they had no duty to provide him with any warnings.

The trial court granted Defendant's motion for summary judgment and the Court of Appeal affirmed, holding that the sophisticated user doctrine does apply in California.  The Supreme Court affirmed and the "sophisticated user" doctrine is now part of California law.