620 So. 2d 1244 (Fla. 1993)
Casa Clara is a cornerstone Florida Supreme Court decision on the economic loss rule in products liability, especially in the construction context. The case addresses whether homeowners and condo associations may recover in tort from an upstream component supplier when a defective building material causes deterioration of the structure but no personal injury or damage to property other than the structure itself.
Can homeowners and condominium associations recover in tort (negligence or strict liability) or on implied warranty against an upstream component supplier for purely economic losses where a defective product (concrete) damages only the completed structure of which it is a part and not other property?
Under Florida's economic loss rule, a party may not recover in tort (including negligence and strict products liability) for purely economic losses caused by a defective product where the product damages only itself and there is no personal injury or damage to other property. For purposes of the "other property" exception, the relevant product is the finished product purchased by the plaintiff; integrated components of that product are not "other property." Absent privity, a plaintiff generally cannot recover purely economic losses on a common-law implied warranty theory against a remote supplier.
No. The economic loss rule bars plaintiffs' negligence and strict liability claims because the defective concrete damaged only the structures themselves—the products the plaintiffs purchased—and not other property. The common-law implied warranty claim fails for lack of privity. The negligent misrepresentation claim likewise cannot proceed under these circumstances.
Casa Clara is the leading Florida case applying East River's economic loss doctrine to construction defects, making three enduring points: (1) the integrated product test defines the "product" as what the plaintiff purchased, so damage to a finished structure by a defective component is not damage to "other property"; (2) tort claims for product quality and performance are barred absent personal injury or other property damage; and (3) privity is required to recover purely economic loss on implied warranty from a remote supplier. Even after Tiara narrowed the economic loss rule to the products-liability context, Casa Clara continues to govern Florida products cases and is tested frequently for its precise articulation of the other-property analysis and the limits of tort in construction disputes.