AK STATEAlaska Supreme Court
2001

Hoffman Construction Co. of Alaska v. U.S. Fabrication & Erection, Inc.

32 P.3d 346Alaska Supreme Court • Decided 2001Modified

HOLDING

Workers exposed to asbestos at Providence Hospital sued, and Hoffman Construction settled. Hoffman then tried to shift defense and indemnity costs to subcontractor U.S. Fabrication & Erection under their contract. The Alaska Supreme Court ruled that Hoffman must defend U.S. Fabrication (pay legal costs) because the asbestos claims arose from the project work, but Hoffman doesn't have to indemnify (reimburse) them since Providence had no actual liability and causation was unclear. This matters because it shows courts will require contractors to pay for defense even when they may not ultimately owe indemnity.

KEY FINDINGS

Broad Indemnification

A broad indemnity clause can trigger a duty to defend (pay legal bills) even before liability is proven—this is a major cost exposure for contractors

Dispute Resolution

Removing work from your contract scope (like asbestos abatement here) doesn't eliminate your defense obligations if you still coordinate that work

FULL COURT OPINION