CA Court of Appeal rules 'sophisticated user' defense bars claim of repairman exposed to poison gas

An air conditioner technician could not recover products liability damages for injuries he suffered while repairing a unit because the manufacturer could expect workers in his field to take adequate precautions against such dangers, the California Court of Appeal has ruled in affirming a summary

In so holding, the court explicitly recognized the sophisticated user doctrine as a viable defense under California products liability law.

The plaintiff was an EPA-certified heating, ventilation and air conditioning (HVAC) technician who worked on commercial systems. He was injured when phosgene gas was created by his brazing near refrigerant lines that were part of an evaporator unit manufactured by the defendant. (Brazing is a form of welding.)

The plaintiff filed claims for negligence and strict liability, alleging that the defendant failed to provide adequate warnings that harmful gas could be created when its units were serviced.

The defendant argued that under the sophisticated user doctrine, it had no duty to warn because the risk was within the professional knowledge of HVAC installers and repairers.