Getty Oil Co. v. Heim

372 A.2d 529, 1977 Del. LEXIS 599
CourtSupreme Court of Delaware
DecidedFebruary 24, 1977
StatusPublished
Cited by5 cases

This text of 372 A.2d 529 (Getty Oil Co. v. Heim) is published on Counsel Stack Legal Research, covering Supreme Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Getty Oil Co. v. Heim, 372 A.2d 529, 1977 Del. LEXIS 599 (Del. 1977).

Opinion

DUFFY, Justice:

This appeal involves survival and wrongful death actions arising from a fire at the Delaware City Refinery of Getty Oil Company. In the Superior Court three plaintiffs asserted various claims against Getty and/or Koppers Company, Inc., and/or Catalytic, Inc.; one plaintiff (Rose T. Walker) and two defendants (Koppers and Catalytic) are not parties to the appeal.

Several motions for summary judgment were submitted to the Superior Court, which made the following rulings in its opinion and order dated August 16, 1976:

“To summarize, defendant’s (Koppers Company, Inc.) motion for summary judgment is denied. With respect to plaintiffs’ (Carol Stanley, Executrix of the Estate of William J. Heal, and Caroline M. Heim, Widow of Edward F. Heim, et al.) motion against Getty for partial summary judgment, the Court finds Getty negligent as matter of law and thus grants said motion for summary judgment against Getty. However, Getty *531 may still present arguments regarding degree of fault and assumption of the risk in an effort to limit or avoid liability.” (Emphasis in the original.)

Appeals and cross-appeals were filed and we have considered them on an accelerated basis because a lengthy trial is scheduled in the Superior Court at the March Term.

Upon consideration of the briefs and the contentions of counsel made at oral argument, we have reached the following conclusions on the issues submitted:

(1) Strict liability: The Trial Court found that it “should have more factual guidance than is present in this record” before determining this issue. Clearly, that ruling determined neither a substantial issue nor did it establish a legal right and, therefore, it is not appealable under settled law. Pepsico, Inc. v. Pepsi-Cola Bottling Co. of Asbury Park, Del.Supr., 261 A.2d 520 (1969).

(2) Statutory negligence under 16 Del.C. § 6611: 1 The Trial Court stated that:

“The purpose of this statute, as clearly expressed, is to protect people and property from harm caused by fire or explosions. The injuries to decedents in this case would have been avoided had Getty maintained its equipment (i. e. its oily water sewer system) so that a large cloud of gas did not escape from it on November 8, 1971. Getty’s Zone 1 superintendent, Bastón, stated that the build-up of gas vapor in the sewer was caused by an unsafe act of a Getty foreman. Even without such an admission, the pressure [sic] of such a dangerous amount of gas in the air and the resultant explosion makes such a conclusion axiomatic.”

Getty argues that the statute is vague and overbroad, and that in applying it the Superior Court did not announce any standards by which liability is to be measured or tested. For present purposes, we agree with that contention but it is not helpful to Getty. We say this because the undisputed material facts before the Trial Court establish that Getty was negligent.

For purposes of this appeal it is unnecessary to formulate specific criteria under § 6611. In our view, the Act can be regarded (without prejudice to Getty) as codifying the prudent-man rule, which is to say that Getty was obliged to conduct its refinery in a reasonably careful way. William E. Baston’s report and testimony, which are not contradicted, show that the discharge of gasoline into the sewer system was an “unsafe act,” 2 inconsistent with Getty’s “standard operating procedures,” 3 *532 creating an “unusual” condition in the refinery. 4 The discharge of the large amount of cooling water into the sewer system, under the then prevailing conditions, compounded this “carelessness” and resulted in discharge of the explosive vapor. 5 The re- *533 suit, surely, was negligence on Getty’s part vis-a-vis these plaintiffs.

Thus, whether Getty’s conduct is tested by common law negligence standards or under a similar standard for § 6611, the result is the same: Getty was negligent.

(3) Proximate cause: The Superior Court did not discuss proximate cause but since it determined that the liability claim against Getty should go to the jury, it necessarily concluded that plaintiffs were not entitled to a ruling of law in their favor on the causation issue. We reach a different conclusion.

It is undisputed that a cloud of gas was ignited and exploded. There is a dispute as to the source of and responsibility for the ignition, but this is not before us. The only reasonable conclusion from what is before us is that the explosion took place almost instantly with the appearance of the cloud and that the explosion caused the deaths. In short, Getty’s negligence provided the fuel for the explosion. 6 Under these circumstances the only reasonable conclusion is that Getty’s negligence, already established, was a proximate cause of the deaths. We so hold. But we make no judgment about fault on Koppers’ part or any degree of fault as between Getty and Koppers.

(4) Assumption of risk: The Court ruled, without discussion, that Getty may present arguments, (presumably before the jury), regarding assumption of risk by the decedents. In our view, the uncontested evidence establishes that they did not assume the risk which is in issue. The governing law was stated by this Court in Robinson v. Meding, Del.Supr., 2 Storey 578, 163 A.2d 272, 276 (1960), as follows:

“ . . . [One] does not assume a risk which cannot be reasonably anticipated and which may be the result of the negligent act of another. . . . Usually this doctrine is not applicable unless there was knowledge, express or implied, of the existence of the risk with a corresponding appreciation of the extent of the danger. With such knowledge of the circumstances, plaintiff must have voluntarily exposed himself to the danger.”

Defendants may have assumed the risks incident to work at an oil refinery, where fires appear to be a common occurrence; but that is not this case. It was the negligent act of Getty which produced the “gas cloud” which was ignited and resulted in the deaths. There is nothing in the record which tends to show that decedents reasonably anticipated that risk or, indeed, that they assumed the risk of any negligence associated with it. 7 Robinson v. Med *534 ing, supra.

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Bluebook (online)
372 A.2d 529, 1977 Del. LEXIS 599, Counsel Stack Legal Research, https://law.counselstack.com/opinion/getty-oil-co-v-heim-del-1977.