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Yonan v. Verson Allsteel Press Co.

Citations: 168 Ill. App. 3d 28; 522 N.E.2d 184; 118 Ill. Dec. 729; 1988 Ill. App. LEXIS 268Docket: No. 86—3220

Court: Appellate Court of Illinois; March 9, 1988; Illinois; State Appellate Court

Narrative Opinion Summary

In this case, an employee injured while using a press brake at work initiated a lawsuit against the manufacturer, Verson Allsteel Press Company, for damages. Verson, in turn, sought indemnity from Ross Operating Valve Company, which supplied a valve added to the equipment. The trial court dismissed Verson's claim, citing the absence of a necessary pretort relationship between Verson and Ross. Verson contended that the valve's defective design warranted indemnity under strict product liability principles, despite the lack of a pretort relationship. However, the court upheld that such a relationship is vital for an implied indemnity claim, as it signifies liability exposure due to another's actions. The court further emphasized that strict product liability does not negate the need for a defined legal relationship, such as employer-employee or owner-lessee, to establish indemnity. Consequently, the dismissal of Verson's claim was affirmed, with Justices McNamara and Freeman concurring in the decision.

Legal Issues Addressed

Implied Indemnity Requirements

Application: The court held that a pretort relationship is necessary to establish a claim for implied indemnity, rejecting the argument that strict product liability principles could substitute for this requirement.

Reasoning: The court, however, maintained that a pretort relationship is essential for an implied indemnity claim, as it indicates exposure to liability for another's wrongdoing.

Necessity of Defined Legal Relationship

Application: The court reiterated that a defined legal relationship, such as employer-employee, is required to support an indemnity claim.

Reasoning: Cases cited established that the relationship must be more than mere involvement in a common undertaking, requiring a defined legal relationship such as employer-employee or owner-lessee.

Strict Product Liability and Indemnification

Application: The court ruled that principles of strict product liability do not eliminate the need for a pretort relationship when seeking indemnification.

Reasoning: The ruling emphasizes that strict liability principles do not justify waiving the pretort relationship requirement in this context.