The U.S. Court of Appeals for the First Circuit vacated a lower court's order granting summary judgment to a valet company after a hotel management corporation sought indemnification in underlying litigation from a guest's trip and fall on the curb that separates the hotel's valet driveway and its main entrance.

In a March 2 opinion, the First Circuit vacated the order granting summary judgment to Ultimate Parking, and remanded the case to the U.S. District Court in Rhode Island with instructions to enter judgment for Omni Hotel on its contractual cross-claim for indemnification, following "whatever proceedings the court deems appropriate to determine the amount due to Omni."