TX STATETexas Court of Appeals, 1st District (Houston)
2014

Hercules Offshore, Inc. and the Hercules Offshore Drilling Company, LLC v. Excell Crane & Hydraulics, Inc.

454 S.W.3d 70Texas Court of Appeals, 1st District (Houston) • Decided 2014Modified

HOLDING

Hercules Offshore and its drilling company hired Excell Crane for services under a contract with both indemnity and insurance provisions. When an employee was injured, a dispute arose over whether Excell's insurance had to pay first before Hercules could claim indemnification. The Texas Court of Appeals ruled that the insurance requirement must be satisfied before the indemnity obligation kicks in, even when the indemnity language is very broad. This protects contractors by ensuring insurance coverage is exhausted first.

KEY FINDINGS

Broad Indemnification

If your contract names the other party as an 'additional assured' on your insurance, that insurance must be exhausted before they can claim indemnification from you

Insurance Requirements

Broad indemnity language does not override the priority of insurance requirements—courts will enforce the insurance-first rule under maritime law

Flow-Down

Include clear insurance requirements and 'additional assured' language in your subcontracts to establish a payment hierarchy that protects you

FULL COURT OPINION