Gehl Brothers Manufacturing Co. v. Superior Court

In these original proceedings, we are called upon to review the propriety of a trial court’s order which determined that plaintiff’s settlement with one of three alleged joint tortfeasors had been entered into in good faith. Analyzed in light of the applicable Tech-Bilt (infra) factors, it is our view that the trial court erred in determining, as a threshold matter, that the defendant with whom plaintiff settled could be assigned no liability for plaintiff’s injuries as a matter of law. The facts before the trial court readily revealed a likely possibility that a jury could assess substantial liability to the settling defendant, should that defendant be held in the case, with the result that the settlement could not have been effected in good faith. Therefore, the order will be reversed.

Facts

Plaintiff Jose Guzman, a 61-year-old farm worker, was badly injured when he became entangled in the exposed drive shaft linking his tractor with a forage unloading farm wagon.

The underlying action which followed was based on negligence, strict products liability, and breaches of warranty. The three named defendants therein had been collectively involved in the manufacture and…