General Motors Corporation v. Hudiburg Chevrolet, Inc.

Summary

The Supreme Court of Texas addressed statutory and common-law indemnity under Texas law in a products-liability dispute involving a truck assembled from a GM chassis and a Rawson-Koenig service body. The court held that statutory indemnity is triggered by pleadings alleging a defect in the relevant product or component, that a seller may be independently liable for losses caused by its own acts or omissions, and that indemnity duties may apply between component and finished-product manufacturers. The court affirmed summary judgment for Rawson-Koenig on statutory indemnity and otherwise remanded for further proceedings concerning GM and Hudiburg's potential indemnity rights and independent liability.

Holdings

1. A component-product manufacturer owes a statutory duty to indemnify a seller only when the claimant's pleadings fairly allege that the component itself is defective; an allegation that the finished product is defective does not automatically allege defects in every component. The underlying pleadings did not fairly allege that Rawson-Koenig's service body was defective.
2. A seller is not entitled to statutory or common-law indemnity for losses caused by acts or omissions attributable to the seller independently, even if the seller cannot be held liable to the injured claimant on that independent theory. Merely selling a defective product does not itself constitute independent liability for purposes of section 82.002.
3. The statutory duty to indemnify is triggered by the claimant's pleadings and does not depend on proof or adjudication of a product defect or the manner in which the underlying action concluded.
4. Section 82.002 does not require a component-product manufacturer to indemnify a seller for losses arising from alleged defects unrelated to the component. GM's statutory indemnity obligation extends only to losses related to allegations that GM's chassis was defective, and only if Hudiburg was not independently liable.

Questions Presented

1. Whether the underlying pleadings fairly alleged that Rawson-Koenig's service body was defective so as to trigger statutory indemnity under Texas Civil Practice and Remedies Code section 82.002.
2. Whether Hudiburg's alleged conduct, including arranging for assembly by B & M, failing to inspect, or selling a defective truck, established independent liability barring statutory or common-law indemnity.
3. Whether a component-product manufacturer has a statutory duty to indemnify a seller for losses arising from alleged defects in a finished product unrelated to the component manufacturer's product.
4. Whether the statutory indemnity scheme requires proof of a product defect before the manufacturer's duty to indemnify is triggered.
5. Whether the summary judgment record established that Hudiburg's claimed losses were attributable solely to defects unrelated to GM's chassis.

Disposition

reversed_and_remanded