Nabors Corporate Services, Inc. v. City of Long Beach

I. INTRODUCTION

Plaintiff Nabors Corporate Services, Inc. (Nabors) appeals from the dismissal of its complaint against defendants 1 following the sustaining of demurrers. According to Nabors, the trial court erred when it ruled that Nabors had no right to indemnity against defendants under Labor Code sections 1781 and 1784. 2 We affirm the dismissal of the section 1784 claim against Tidelands, but reverse the dismissal of Nabors’s section 1781 claim against the City.

1 Defendants are the City of Long Beach (the City) and two corporations, California Resources Long Beach, Inc. and Tidelands Oil Production Company. According to the operative complaint, there was “a unity of interest, ownership and control” between the two corporate defendants, and they have filed a joint respondents’ brief. We will refer to them collectively as Tidelands.

2 All further statutory references are to the Labor Code unless otherwise indicated. Although Nabors asserted other claims against defendants under the Labor Code and common law, it challenges on appeal only the court’s dismissal of its statutory indemnity claims under sections 1781 and 1784 and the related claim for declaratory…