Davis v. Sinclair Refining Co.
Charles Edward Davis, an Arco employee, sustained severe burns due to a defective pipe installed by Sinclair Refining Company, which later merged with Arco. Davis received workers' compensation benefits but also filed a third-party action against Sinclair and Arco, arguing Arco assumed Sinclair's liabilities through the merger. The trial court granted summary judgment for the appellees, asserting Davis had elected his remedy under workers' compensation laws. The Court of Appeals of Texas, Houston (14th Dist.), affirmed the summary judgment, ruling that corporate merger statutes were not intended to bypass the exclusive remedy of the Workers' Compensation Act and rejected the application of the "dual capacity" doctrine in this context. A dissenting opinion advocated for the adoption of a limited "dual capacity" doctrine when an employer contractually assumes the liabilities of a third-party tortfeasor through merger.