Houdaille Industries, Inc. v. Edwards

Eddie Edwards (plaintiff) worked for Houdaille Industries, Inc. (Houdaille) (defendant), a reinforced-concrete-beam manufacturer. Houdaille constructed the concrete beams using steel cables manufactured by Florida Wire and Cable Company (FWC) (defendant). Manufacturing the beams involved stretching FWC’s cables through the concrete-beam mold. Edwards was killed when a steel cable snapped under tension. Houdaille paid out all required workers’-compensation benefits. Edwards’s personal representative then filed a wrongful-death action against FWC based on FWC’s breach of the implied-warranty-of-fitness, arguing that FWC’s breach proximately caused Edwards’s death. In response, FWC filed a third-party complaint against Houdaille, arguing that Houdaille’s active negligence as Edwards’s employer was the sole cause of Edwards’s death and that any negligence attributable to FWC was merely passive. FWC did not allege that any damages assessed against FWC would be solely based on FWC bearing vicarious, constructive, or derivative liability for Houdaille’s negligence. Houdaille moved for summary judgment, arguing FWC could not seek indemnification from Houdaille because Edwards’s claim against FWC was based on FWC’s alleged breach of the implied-warranty-of-fitness, which was a type of active negligence. The trial court agreed and granted Houdaille’s motion for summary judgment. FWC appealed, and the appellate court reversed, holding that (1) there were outstanding issues of fact regarding Houdaille’s relative fault; and (2) if a manufacturer, like FWC, was sued for breach-of-warranty by an injured employee, then the manufacturer could file a third-party indemnity complaint against the employee’s employer. Houdaille appealed.