Angus Chemical Co. v. IMC Fertilizer, Inc.
An explosion at a nitroparaffin plant owned by Angus Chemical Company and managed by IMC Fertilizer Group, Inc. in Louisiana led to multiple lawsuits. Angus and IMC eventually settled, with Angus releasing IMC from most claims arising from the explosion. Subsequently, Angus sued IMC's insurers in Louisiana. IMC then initiated a declaratory action in Texas, contending that the release granted to IMC by Angus also extended to IMC's insurers. The district court ruled in favor of Angus, but the court of appeals reversed this decision. The Texas Supreme Court granted Angus's application for writ of error, reversing the judgment of the court of appeals and remanding the case to the district court. The Supreme Court held that under Texas law, an insurer is not released from liability unless explicitly named in the release, regardless of whether the insured has been released.