Lockhart v. Heede International, Inc.
This memorandum addresses a motion to dismiss a third-party complaint filed by Heede International, Inc. against the Tennessee Valley Authority (TVA). The original lawsuits involved personal injury or wrongful death claims by TVA employees or their survivors, arising from a tower crane collapse. Heede, an original defendant, sought contribution or indemnity from TVA. The court found that the Federal Employee’s Compensation Act (FECA) provides the exclusive remedy for plaintiffs against TVA and bars third-party actions for contribution or indemnity against TVA, absent a contract of indemnity. The court rejected Heede’s arguments that TVA impliedly agreed to indemnify Heede or waived its immunity, noting the limited application of the Ryan Stevedoring doctrine to non-admiralty cases. Consequently, the court granted TVA's motion, dismissing Heede's third-party complaint against TVA.