Johnson v. American Standard, Inc.

William Keith Johnson (plaintiff) was a trained and certified heating, ventilation, and air-conditioning (HVAC) technician from 1996 to 2002. Johnson sued American Standard, Inc., and other air-conditioning manufacturers and chemical suppliers (collectively, the manufacturers and suppliers) (defendants) for injuries stemming from his diagnosis of pulmonary fibrosis, a lung disease that can result from breathing phosgene gas. Johnson specifically alleged injury from welding a refrigerant line on an evaporator manufactured in 1965 by American Standard, Inc. Johnson alleged that the manufacturers and suppliers failed to warn of the risks of a common refrigerant, R-22, breaking down into dangerous phosgene gas if heated through the welding process. HVAC technicians had generally known about the dangers and risks associated with R-22 and phosgene gas as early as 1931. In Johnson’s professional certification and training, he learned about the risks of R-22 and phosgene gas. Beginning in 1997, every time Johnson purchased R-22, he received and sometimes read its Material Safety Data Sheet, which detailed the dangers of refrigerant chemicals, including R-22. Under claims of negligence and strict liability, Johnson alleged the manufacturers and suppliers failed to warn of the hazards of R-22 exposure. The manufacturers and suppliers moved for summary judgment, contending they had no duty to warn Johnson, a professional HVAC technician, who belonged to a class of sophisticated users who were well aware of the dangers of R-22. The trial court granted the manufacturers and suppliers’ motion for summary judgment, ruling the sophisticated-user doctrine alleviated a duty to warn trained and certified HVAC technicians of R-22’s potential health hazards. The appellate court affirmed. Johnson appealed.