Houston Lighting & Power Co. v. Eller Outdoor Advertising Co.
This case addresses whether a party entitled to indemnification for damages to an injured employee can recover indemnity under the Public Utilities Act from an employer covered by the Workers’ Compensation statute. Tommy Eugene Miller, an employee of Eller Outdoor Advertising, was electrocuted by a power line owned by Houston Lighting & Power Company (HL&P). Miller's family received workers' compensation benefits from Eller and later settled a wrongful death action against HL&P. HL&P then sued Eller for indemnification, arguing Eller violated the Public Utilities Act. The trial court ruled that the Workers' Compensation Statute precluded HL&P's suit. However, the appellate court reversed, holding that the specific indemnification provision of the later-enacted Public Utilities Act should control over the more general Workers' Compensation Act, allowing for harmonization of the statutes. The case was remanded to determine the merits of HL&P's indemnification claim.