California law is instructive. Under the common law equitable indemnity doctrine as modified in American Motorcycle Assn. v. Superior Court (1978) 20 Cal.3d 578 [143 Cal.Rptr. 692, 574 P.2d 763], liability among joint tortfeasors may be apportioned on a comparative fault basis. Such apportionment may appropriately be effected between a strictly liable defendant and a negligent defendant, as well as between multiple negligent defendants.
In the recent American Motorcycle decision, after reviewing the origins and development of the common law equitable indemnity doctrine, the court concluded that in light of the principles of Li, [LI V. YELLOW CAB CO. OF CALIFORNIA, 13 Cal. 3d 804, 532 P.2d 1226, 119 Cal. Rptr. 858 (1975)] the all-or-nothing character of the doctrine should be modified to permit partial indemnity among multiple tortfeasors on a comparative fault basis. (20 Cal.3d at pp. 591-599.) The American Motorcycle opinion addressed at some length the question of whether California's present contribution statutes should be interpreted to preclude the evolution of such a common law comparative indemnity doctrine, and concluded that the Legislature did not intend to bar such a common law development. (20 Cal.3d at pp. 599-605.) Thus,