How have courts interpreted the doctrine of strict products liability in the context of defective appliances or other manufactured component products that are installed in a commercial real estate?

California, United States of America


The following excerpt is from Jimenez v. Superior Court, 82 Cal.App.4th 856, 98 Cal.Rptr.2d 587 (Cal. App. 2000):

In Golden v. Conway (1976) 55 Cal.App.3d 948, 951, 964, the court reversed a directed verdict against a tenant who suffered personal property damage from a fire allegedly caused by a defective wall heater the landlord had installed on the leased premises. The court stated: "In this case we see no reason to distinguish between appliances which are attached to the realty, and appliances or furniture which are not." (Id. at p. 961.)12 Golden therefore implicitly concluded that the doctrine of strict products liability applies to appliances or other manufactured component products that are installed in buildings.

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