Chesapeake Operating, Inc. v. Nabors Drilling USA, Inc.
This case consolidates two appeals concerning indemnity claims in personal injury lawsuits that arose from a Louisiana oil well drilling site but were filed in Texas courts. The core issue is whether Texas or Louisiana law should govern the indemnity provisions in the contract between Chesapeake Operating, Inc. and Nabors Drilling USA, Inc., as Louisiana law would void indemnities for negligent parties, while Texas law, with certain exceptions, would enforce them. The court applied the Restatement (Second) of Conflict of Laws sections 187 and 188, focusing on the state with the most significant relationship to the indemnity issue. It concluded that Texas law applies, emphasizing the parties' domicile, place of negotiation, the location of the indemnity performance (litigation in Texas), and the contractual freedom policy. Consequently, the court affirmed the summary judgment enforcing Nabors' indemnity claim in the Alms case (14-00-00173-CV) and reversed and remanded the judgment denying Nabors' claim in the Fritz case (14-00-00580-CV).