Gonzalez v. Standard Tools and Equipment Co.

Oregon does not recognize the product line liability exception to the general rule of successor liability.

Plaintiff was injured at work while operating an automotive lift that had been purchased by Plaintiff's employer from Eagle Lift in 1998. In 2005, Eagle Lift’s successor company, Minuteman Distributors, was sold to Eagle Equipment. Eagle Equipment then merged with Standard Tools. Plaintiff sued Standard Tools, arguing that Oregon courts should adopt the product line exception to the general rule of successor liability. The general rule of successor liability protects corporations that have had all of the assets of another corporation transferred to it from the debts and liabilities of the transferor. There are four exceptions to this rule. Recently states have begun adopting a fifth exception called the “product line” exception. The product line exception assigns liability to the successor company that continues to produce the same type of product as the original company for defects in units of the same product line. Standard Tools made a motion for summary judgment, which was granted. On appeal, Plaintiff appealed the order of summary judgment, renewing his argument below. The Court held the trial court did not err because Oregon does not recognize the product line exception, as it would require the state to part from the long-established general rule and might come into conflict with some of the state’s laws. Affirmed.