On March 19, 2019, the United States Supreme Court redefined the scope of a manufacturer’s liability under General Maritime Law for asbestos-related injuries caused by third-party integrated parts. In Air & Liquid Sys. Corp v. Devries, Case No. 17-1104, 2019 US LEXIS 2087 (03/19/2019), the Supreme Court held that a manufacturer has a duty to warn users when its product requires subsequent incorporation of another part—such as asbestos material—that the manufacturer knows is likely to render the integrated product dangerous for its intended use.

In Devries, two Navy veterans and their wives filed suit against manufacturers of certain equipment (i.e., pumps, blowers, and turbines) that was used aboard Navy ships. The equipment required asbestos insulation or asbestos parts in order to properly function. However, the manufacturers did not always incorporate the asbestos parts into their products. Rather, the manufacturers provided much of the equipment without asbestos, or “bare metal,” to the Navy, who then independently added the asbestos to the equipment.

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