Fieldstone Co. v. Briggs Plumbing Products, Inc.

Briggs Plumbing Products, Inc., doing business as Briggs Industries; Verson Allsteel Press, the predecessor of Allied Products Corporation (together Allied); and CR/PL, Inc., manufactured inexpensive bathroom sinks, hundreds of which the Fieldstone Company installed in residential developments throughout San Diego County in the 1980’s. Field-stone, which brought this action to recoup costs of replacing sinks prematurely rusting and chipping, appeals from summary judgments in favor of the manufacturers. We affirm.

I

Factual and Procedural Background

The manufacturers produced low-cost enameled steel bathroom sinks; they carried written one-year warranties. Pursuant to Fieldstone’s specification, plumbing subcontractors installed the sinks in numerous Fieldstone residential developments. Instead of lasting twenty-five or more years as expected, unsightly rusting and porcelain chipping, or “popping,” occurred within one to five years, due to spot welding and inadequate coating around steel overflow outlets.

In response to homeowner complaints, Fieldstone spent more than $250,000 replacing 1,900 of the enameled steel sinks with ones made of vitreous china. When the…