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Guity v. Lawson Environmental Services & Response Co.

Citations: 22 F. Supp. 3d 631; 2014 U.S. Dist. LEXIS 69775; 2014 WL 2120078Docket: Civil Action No. 11-2506

Court: District Court, E.D. Louisiana; May 21, 2014; Federal District Court

Narrative Opinion Summary

In a dispute involving contractual indemnity obligations, United States Environmental Services, L.L.C. (USES) filed a Motion for Summary Judgment against Lawson Environmental Service, L.L.C. (Lawson) following an incident where two Lawson employees were injured. Both companies had entered into Master Service Contracts with BP entities, containing cross indemnity provisions covering claims arising from the contracts. USES, asserting entitlement to defense and indemnity as a third-party beneficiary of the Lawson contract, sought indemnification for claims related to the Macondo well incident. Lawson contended that USES was a contractor for a different BP entity, questioning USES's claim to indemnity. The court, applying maritime law principles of contract interpretation, determined that the indemnity provisions were unambiguous and required Lawson to indemnify USES for the claims. Consequently, the court granted USES's motion, obligating Lawson to provide defense and indemnification, and allowed USES to seek attorneys’ fees and costs. The court's decision emphasized the clear contractual language and the parties' roles under the agreements at the time of the incident, concluding that USES was entitled to the protections sought under the cross indemnity provisions.

Legal Issues Addressed

Interpretation of Indemnity Agreements under Maritime Law

Application: The court found that the cross indemnity provisions clearly obligated Lawson to indemnify USES for injuries to Lawson's employees, as both parties were contractors for BP entities at the time of the incident.

Reasoning: Under maritime law, indemnity agreements are to be interpreted in their entirety, giving words their plain meaning unless ambiguity exists.

Obligations under Cross Indemnity Provisions

Application: The court held that Lawson must indemnify USES due to the cross indemnity provision, which applied to injuries of Lawson's employees arising during the incident.

Reasoning: The cross indemnity provisions are clear, stating Lawson is to indemnify USES for injuries to Lawson's employees.

Summary Judgment Standard

Application: The court granted summary judgment in favor of USES because there was no genuine issue of material fact, and USES was entitled to judgment as a matter of law.

Reasoning: The legal standard for summary judgment requires that there be no genuine issue as to any material fact, allowing the movant to win judgment as a matter of law.

Third-Party Beneficiary Rights in Contractual Agreements

Application: USES argued it was a third-party beneficiary of the Lawson agreement, a claim supported by the court's interpretation of the contract provisions.

Reasoning: USES argues it is entitled to these based on the clear language of the cross indemnity provisions, asserting it is a third-party beneficiary of the Lawson agreement intended to protect its interests.