Texas Supreme Court: "Innocent" Component Part Manufacturers Have No Duty to Indemnify Customers Who Assemble End Product

The Texas Supreme Court ruled, in General Motors Corp. v. Hudiburg Chevrolet, Inc., 2006 WL 741552 (March 24, 2006), Docket No. 03-0987 |PDF|, that a manufacturer of a non-defective component part had no duty to indemnify its customer who had used the component in the assembly of the final product.  The case arose out of an auto accident involving a truck assembled by Hudiburg from a chassis supplied by General Motors and a truck bed supplied by Rawson-Koenig, Inc.  The plaintiff's alleged that the truck was defective since the bed and chassis separated in the accident causing the fuel tanks' filler systems to rupture.  The resulting fuel spill and fire killed one plaintiff and injured another.  After the truck dealer settled the plaintiff's claims, it sued the component manufacturers for indemnity.  The court reasoned that, if the plaintiff's loss was caused by the independent negligence of the dealer in assembling the truck, it is not entitled to indemnity under Texas law except to the extent that a component part supplier was itself at fault.  The court held that "if the component part manufacturer does not participate in the integration of the component into the finished product, it is not liable for defects in the final product if the component itself is not defective."

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