Gardemal v. Westin Hotel Co.

Gardemal's (plaintiff) husband drowned after a Westin Regina hotel doorman allegedly directed the couple to a dangerous, unmarked beach in Mexico; the hotel was managed by Westin Mexico (defendant), a subsidiary of Westin Hotel Company (defendant), a Delaware corporation. Gardemal sued both under Texas law, arguing Westin (the parent) should be liable for its subsidiary's negligence under alter-ego and single-business-enterprise theories, given their shared stock ownership, common officers, and financing arrangements. The record showed the companies were incorporated in different countries, strictly observed corporate formalities, and that Westin Mexico was adequately capitalized. The district court granted Westin summary judgment, and Gardemal appealed.