## Facts

- Houdaille Industries, Inc. employed Eddie Edwards in a plant manufacturing reinforced concrete beams using steel cable produced by Florida Wire and Cable Company.
- In the manufacturing process, the steel cable was stretched under stress through a mold; Edwards was killed when the cable broke.
- Houdaille paid workers’ compensation benefits to Edwards’ survivors as required by law.
- Edwards’ personal representative sued Florida Wire for wrongful death, alleging breach of implied warranty of fitness and that the breach proximately caused Edwards’ death.
- Florida Wire filed a third-party complaint against Houdaille seeking common-law indemnity, alleging Houdaille negligently conducted the detensioning process, improperly inserted the strand in the jack, improperly installed the jack, and failed to instruct employees adequately.

## Issues

1. Whether a manufacturer sued for an alleged defective product contributing to an on-the-job death may obtain common-law indemnity from the decedent’s employer absent a contractual indemnity provision.
2. Whether common-law indemnity is available when the manufacturer’s potential liability is based on its own alleged active wrongdoing, rather than purely vicarious or derivative liability for the employer’s conduct.

## Decision

- The Florida Supreme Court quashed the district court’s decision and reinstated the trial court’s summary judgment for Houdaille on Florida Wire’s indemnity claim.
- The court held that Florida Wire could not pursue common-law indemnity against Houdaille because no special relationship made Florida Wire only vicariously, constructively, derivatively, or technically liable for Houdaille’s alleged negligence.
- The court emphasized that common-law indemnity is not a device for reallocating fault among joint or concurrent tortfeasors.

## Legal Principles

- Common-law indemnity is available only when the indemnitee is wholly without fault and liability is imposed solely by operation of law due to the wrongful act of another.
- A “special relationship” is required such that the indemnitee’s liability is vicarious, constructive, derivative, or technical (e.g., principal–agent or similar relationships), not based on the indemnitee’s own misconduct.
- A manufacturer whose liability is predicated on its own conduct (including breach of implied warranty, strict liability, or negligent manufacture/design allegations) is not entitled to common-law indemnity from another party whose alleged negligence is separate and independent.
- Absent the required special relationship, a third-party manufacturer has no common-law right to indemnification from the injured worker’s employer.

## Conclusion

The court held that a product manufacturer sued for a defect-based theory may not obtain common-law indemnity from the injured employee’s employer without a special relationship that makes the manufacturer only derivatively liable for the employer’s wrongdoing; summary judgment for the employer was proper.


Houdaille Indus., Inc. v. Edwards, 374 So. 2d 490 (Fla. 1979)