Makers of non-defective components are not liable for damages caused when the part is added to a bigger assembly which does cause damage. Massachusetts SJC case Nemirovsky v Daikin North America LLC (2021) supports component parts doctrine.

HVAC system = integrated product. AC fan coils delivered per specs of system designer corroded prematurely.

Coil maker was not shown to be involved in system design had no responsibility for the failure of the system.

FACTS

Homeowner remodeled 22,000 sf home (big home) in Boston including new HVAC design and system.

Air conditioning system bought in 2008 failed. Industry standard AC fan coils leaked, even after many replacements.

WARRANTY STATUTE OF LIMITATIONS

2016 Suit brought warranty claims against HVAC coil maker – not tort claims. This kind of warranty claim – not brought within 4 years are barred by the Statute of Limitations. 4 year statute of limitations applies to beach of contract with only property damage – and it accrues at delivery regardless of when the aggrieved party finds out.  

WHAT MADE COILS FAIL?

There was no proof that the AC coils made to spec were defective. Plaintiff’s expert said the design with a Styrofoam drain pan not being metal, caused the coils to corrode prematurely.

The coils developed galvanic corrosion because the drain pan was made of a non-conductive material, current generated in the system was not properly grounded. 

#HOLDING COMPONENT PARTS DOCTRINE

Makers of non-defective components are not liable for damages caused when the part is added to a bigger assembly which does cause damage.

MISREPRESENTATION CLAIM

Coil maker told homeowner failures may be due to ‘off gassing’ within the home. It knew then that other assemblies had the same problem. Even after testing ruled out environmental factors, the off-gassing talk continued.

Court sent case back to determine reasonable reliance on representation and related damages, if any.