Sandridge Energy, Inc. v. John Barfield and Tana Barfield, Wife, Individually, and John Barfield and Tana Barfield as Next Friends of C.B. and K.B., Minor Children, 642 S.W.3d 560

Background:

SandRidge contracted with OTI to modify electrical distribution lines; OTI lineman John Barfield worked on energized overhead supply lines while de-energizing lower portions.
SandRidge refused to de-energize the supply lines while OTI performed the work; Barfield regularly performed such tasks and completed daily job hazard analyses identifying "hot lines."
While attempting to remove a stuck hot tap with an insulated "hot stick," Barfield received an electrical shock causing severe burns and amputations.
Barfield sued SandRidge under Texas Civil Practice & Remedies Code Chapter 95, alleging SandRidge exercised control, knew of the danger, and failed to adequately warn.
SandRidge moved for summary judgment arguing (1) Barfield knew the lines were energized so no warning was required (open-and-obvious doctrine) and (2) it did not retain control as Chapter 95 requires. The trial court granted summary judgment; the court of appeals reversed. The Texas Supreme Court granted review.

Issues:

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Chapter 95 requires a warning even when the contractor actually knew the danger (open-and-obvious)	Barfield: Actual knowledge does not negate Chapter 95's "failed to adequately warn" element; statute doesn't import open-and-obvious defense	SandRidge: Chapter 95 incorporates common-law adequacy-of-warning rules; no duty to warn when danger is open and obvious/known to invitee	Court: Chapter 95 incorporates common-law open-and-obvious rule; Barfield's knowledge conclusively negated failure-to-warn, so summary judgment proper for SandRidge
Whether the necessary-use exception to the open-and-obvious doctrine applies here	Barfield: Even if open-and-obvious applies, necessary-use exception applies because work required use of dangerous premises and risk was unavoidable	SandRidge: Safety policies anticipate work by qualified personnel; risk was avoidable by contractor precautions so exception inapplicable	Court: Declined to decide whether exception applies to contractors generally but held exception not met on facts — Barfield could avoid risk given experience, tools, and training
Whether SandRidge exercised control over how work was performed (Chapter 95 control element)	Barfield: SandRidge controlled safety by refusing to de-energize lines, showing retained control	SandRidge: Contract terms negate retained control; dispute over control not resolved	Court: Did not reach control issue because warning/knowledge dispositive; summary judgment affirmed on adequacy-of-warning ground

Key Cases Cited

Austin v. Kroger Tex., 465 S.W.3d 193 (Tex. 2015) (general rule: no duty to warn of open-and-obvious dangers)
Los Compadres Pescadores, L.L.C. v. Valdez, 622 S.W.3d 771 (Tex. 2021) (applied open-and-obvious doctrine in Chapter 95 context where issue was fact-bound)
Ineos USA, LLC v. Elmgren, 505 S.W.3d 555 (Tex. 2016) (discussed incorporation of common-law concepts into Chapter 95 interpretation)
Gen. Elec. Co. v. Moritz, 257 S.W.3d 211 (Tex. 2008) (questioned applying necessary-use exception to independent contractors)
Parker v. Highland Park, 565 S.W.2d 512 (Tex. 1978) (clarified burden and scope of open-and-obvious doctrine at common law)