In Montgomery County v. Valk Mfg. Co., 317 Md. 185, 197 n.16, 562 A.2d 1246 (1989), the manufacturer of a snow plow found liable under a strict liability theory to a motorist killed in an accident with a truck using the plow, sued the truck owner for contribution. The plaintiff's direct claim against the truck owner for negligence was barred because the decedent was contributorily negligent in causing the accident. The Court of Appeals held that, under these circumstances, the manufacturer had no claim for contribution against the truck owner because the right of contribution was predicated on the third party defendant's direct liability to the plaintiff. See id. at 193. In explaining its decision, the Court quoted the following passage from Prosser and Keeton on the Law of Torts, 50 at 339-40 (5th ed. 1984): If there was never any liability to the plaintiff, as where the contribution defendant has the defense of family immunity, assumption of risk, or the application of an automobile guest statute, or the substitution of workers' compensation for common law liability, then there is no liability for contribution. Id. (alteration in original). The Court contrasted the liability, for contribution, of: (1) a defendant who maintained a defense of contributory negligence; and (2) a defendant who asserted a statute of limitations defense, and explained: Valk argues that contributory negligence is more like a statute of limitations than immunity in terms of barring third party claims. . . . We disagree with Valk's comparison. Both immunity and contributory negligence arise directly out of the wrongdoing itself. By contrast, a statute of limitations defense depends on litigation procedures transpiring after the wrongdoing has occurred. (Id. at 197 n.16.)