Sophisticated Users of Defective Products Do Not Require Warning

The California Supreme Court handed down its opinion (.pdf) in the case of Johnson v. American Standard, Inc. affirming the principle that the “sophisticated user” doctrine is a valid defense under California law. Federal courts have long held that a sophisticated user of a product does not need to be warned of the products potential to cause harm.

Generally, under California law a manufacturer has a duty to warn users of its products about the potential risks or harm caused by the use of the product. In Johnson, the Defendant argued was not required to warn the Plaintiff, a heating and air-conditioning technician, of the risks of using R-22, a gas used in air conditioners units. The Defendant contended that because Mr. Johnson was a sophisticated user, i.e. he worked in the industry and 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 agreed with the Defendant’s reasoning, and granted its motion for summary judgment. After appeal, the Court of Appeal affirmed, which led to the Supreme Court’s recent decision in the case. Now, the “sophisticated user” doctrine is part of California law.