The California Supreme Court sharply limited asbestos liability for valve and pump manufacturers (and their insurers) in O'Neil v. Crane Co., 2012 WL 88533 (Jan. 12, 2012). The court resolved conflicting appellate court decisions and, in so doing, joined Washington (Simonetta v. Viad Corp., 165 Wn.2d 341 (2008)) and the 6th Circuit (Lindstrom v. A‐C Product Liability Trust, 424 F.3d 48 (6th Cir. 2005)), in holding that valve and pump manufacturers have no duty to warn about the hazards associated with other manufacturers' asbestos products, even though those products were incorporated into valves and pumps. The Supreme Court acknowledged that valve and pump manufacturers are "peripheral defendants" that are often sued because most of the target asbestos manufacturers are in bankruptcy.
O'Neil involved a common fact pattern. Plaintiff's deceased husband served on board an aircraft carrier from 1965‐1967. Two manufacturers, Crane Co. and Warren Pumps, provided valves and pumps for the ship during its construction in the...
