Narrative Opinion Summary
This case involves an appeal by PAM Transport and Andrew Mertyris against a district court ruling in favor of Freightliner Corporation, centered around a contribution claim following a fatal collision. In 1988, a Freightliner truck driven by Mertyris collided with an Arizona Department of Transportation vehicle, resulting in a wrongful death settlement. Mertyris and PAM Transport settled the claims for $985,000, thereby extinguishing their liability and that of Freightliner. They sought contribution from Freightliner under A.R.S. 12-2501, but the district court held that A.R.S. 12-2506, which abolishes joint and several liability, precluded such a claim. The district court certified a question to the Arizona Supreme Court regarding the applicability of contribution rights under these circumstances. The Arizona Supreme Court concluded that contribution is not available when liability is several only, and is permissible only among joint tortfeasors who pay more than their share in a reasonable settlement extinguishing others' liabilities. The court found the statutory exceptions in A.R.S. 12-2506(D) did not apply, affirming the denial of the contribution claim and remanding for further proceedings consistent with this interpretation.
Legal Issues Addressed
Abolishment of Joint and Several Liability Under Arizona Revised Statutes Section 12-2506subscribe to see similar legal issues
Application: The court determined that A.R.S. 12-2506, which abolishes joint and several liability, precludes a claim for contribution when liability is several only.
Reasoning: The U.S. District Court ruled that A.R.S. 12-2506, which abolished joint and several liability, barred the contribution claim.
Contribution Under Arizona Revised Statutes Section 12-2501subscribe to see similar legal issues
Application: The appellants sought contribution from appellees under A.R.S. 12-2501, claiming entitlement to recover amounts paid in settlement.
Reasoning: Appellants subsequently sought contribution from Appellees under A.R.S. 12-2501.
Interpretation of Arizona Revised Statutes Section 12-2506(D)subscribe to see similar legal issues
Application: The exceptions to the prohibition of contribution claims outlined in A.R.S. 12-2506(D) were found not applicable in this case, thereby affirming the denial of the contribution request.
Reasoning: Since the exceptions listed in A.R.S. 12-2506(D) did not apply in this case, the Appellants' request for contribution was denied.
Right to Contribution Among Joint Tortfeasorssubscribe to see similar legal issues
Application: The Arizona Supreme Court confirmed that contribution is only permissible among joint tortfeasors who have paid more than their share, provided the settlement extinguishes others' liabilities and is reasonable.
Reasoning: Contribution is allowed only among joint tortfeasors who have paid more than their share of liability if the settlement extinguishes others' liabilities and is reasonable.