State Farm Insurance Companies v. Premier Manufactured Systems, Inc., 217 Ariz. 222

Summary

The Arizona Supreme Court held that Arizona’s statutory abolition of joint and several liability applies to strict products liability actions. Under A.R.S. § 12-2506, liability among participants in a defective product’s distribution chain is generally several only, with fault apportioned among tortfeasors. The court rejected constitutional challenges under Article 18, Section 6 of the Arizona Constitution and affirmed the superior court and court of appeals.

Holdings

1. A.R.S. § 12-2506 abolishes joint and several liability in strict products liability actions except for the specific statutory exceptions in § 12-2506(D). Liability among participants in the chain of distribution is several only, and fault must be apportioned among the tortfeasors.
2. The mere purchase of a defective component from a supplier does not establish a conventional principal-agent or master-servant relationship and does not trigger the joint-liability exception in § 12-2506(D)(2).
3. Applying several-only liability and comparative fault to strict products liability actions does not violate Article 18, Section 6's anti-abrogation clause or its prohibition on statutory limitations of damages.

Questions Presented

1. Whether A.R.S. § 12-2506 abolishes joint and several liability among participants in the chain of distribution in strict products liability actions.
2. Whether the agency or servant exception in A.R.S. § 12-2506(D)(2) applies merely because Premier purchased and incorporated Worldwide's component product.
3. Whether applying several-only liability and comparative fault to strict products liability actions conflicts with Article 18, Section 6 of the Arizona Constitution.
4. Whether A.R.S. §§ 12-2509 and 12-684 preserve joint and several liability in strict products liability actions.

Disposition

affirmed