Washburn v. Beatt Equipment Co.
840 P.2d 860 | Washington Supreme Court | 1992
What This Case Means for Subcontractors
A propane fuel system installed in 1969 caught fire and exploded in 1986, severely burning a worker. Beatt Equipment Company argued it wasn't liable because a statute of repose had expired, but the Washington Supreme Court ruled that companies performing significant manufacturing work—like welding, wrapping, and coating—qualify as manufacturers and are not protected by the statute of repose. The court upheld the jury's finding that Beatt was liable for supplying an unsafe product, awarding the injured worker $6 million in damages.
Key Takeaways
- •If you add substantial labor and materials to transform an unfinished product into a finished, usable one, you may be classified as a manufacturer—which removes your statute of repose protection and extends your liability exposure indefinitely.
- •Don't rely on old installation dates to shield you from liability; courts will examine what work you actually performed, not just when you performed it.
- •Document your role carefully: if you're only assembling or installing someone else's finished product, you have stronger repose protections than if you're manufacturing or substantially modifying the product.
Defendant took an unfinished and unusable product, and by use of its labor and materials made it economically valuable.
Frequently Asked Question
Does the statute of repose protect me if I installed equipment decades ago?
Not if you performed substantial manufacturing work like welding, wrapping, or coating. Courts look at what you actually did to the product, not just when you did it. If you transformed an unfinished product into a finished, usable one, you're a manufacturer and the statute of repose won't protect you—you can face liability years or decades later.
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