Burden v. Johnson & Johnson Medical, Inc.
A dental assistant, Kathy Burden, filed a product liability lawsuit against multiple latex glove producers and distributors due to an allergic reaction. Distributor Owens & Minor, Inc. (and Owens & Minor Medical, Inc.) settled with Burden and subsequently sought indemnification for defense costs from two manufacturers, Becton Dickinson & Company and Ansell Healthcare Products, Inc. Owens argued for indemnification under Texas law, while the manufacturers asserted their offers to defend Owens were sufficient. The court upheld the constitutionality of the Texas indemnity statute, affirming that manufacturers generally have a duty to indemnify sellers. However, the court denied Owens's claim for indemnification, concluding that the manufacturers' prior offers to defend Owens were reasonable and met their statutory obligations, rendering Owens's incurred defense costs unnecessary.