Justia Aviation Opinion Summaries

Two individuals died in a 2012 plane crash involving a Piper PA-32-300 Cherokee 6 aircraft powered by a Lycoming engine manufactured by Avco Corporation in the early 1970s. The engine had undergone overhauls in 1983 and 2004, with several component parts serviced or replaced during those processes. The estates and families of the decedents brought suit in Rhode Island Superior Court against Avco, alleging strict liability, negligence, breach of warranty, and negligent infliction of emotional distress. Avco asserted a defense under the General Aviation Revitalization Act of 1994 (GARA), which bars certain claims against aircraft manufacturers after eighteen years, subject to specific exceptions for misrepresentation and newly installed parts.The Providence County Superior Court addressed the applicability of GARA’s exceptions. The court found that the plaintiffs’ amended complaint failed to plead, with the required specificity, facts showing that Avco knowingly misrepresented or withheld information from the FAA as required by GARA’s misrepresentation exception. As a result, discovery on this theory was limited. On the rolling provision, the court allowed discovery on specific parts allegedly replaced within eighteen years prior to the crash but found plaintiffs failed to prove that any such part was both manufactured by Avco and causally related to the accident. The trial justice granted summary judgment for Avco on all claims.The Supreme Court of Rhode Island reviewed the lower court’s grant of summary judgment de novo. The court held that GARA requires plaintiffs to plead specific facts to invoke the misrepresentation exception, which the plaintiffs had not done. The court also held that the plaintiffs failed to prove the application of GARA’s rolling provision, as they did not establish that any newly installed part made by Avco caused the crash. The Supreme Court affirmed the Superior Court’s judgment in favor of Avco. View "Williams v. Avco Corporation" on Justia Law

Five individuals residing near a New Orleans hospital brought suit after the hospital moved its helicopter landing pad from a one-story building near the Mississippi River to the top of a new tower in the center of the hospital complex. The plaintiffs, claiming that the new helipad created excessive noise and vibrations, sought a mandatory injunction requiring the hospital to relocate the helipad or otherwise abate the disturbance, as well as damages for nuisance and negligence.The defendants removed the case from state court to the United States District Court for the Eastern District of Louisiana. The district court denied the plaintiffs’ request to remand the case to state court, finding that their subsequent removal of class-action allegations and request to decline supplemental jurisdiction amounted to improper forum shopping. The district court then granted the defendants partial summary judgment, holding that Federal Aviation Administration regulations preempted any permanent injunction to relocate the helipad. The court also dismissed some of the plaintiffs’ claims for damages, but allowed their claims for general nuisance damages to proceed to trial. Before trial, the plaintiffs appealed the order, seeking review of the denial of their request for an injunction.The United States Court of Appeals for the Fifth Circuit reviewed the appeal. The court held that it lacked jurisdiction over the interlocutory appeal because the district court’s order did not explicitly deny an injunction and, even if it had the practical effect of denying injunctive relief, the plaintiffs did not show that they satisfied the requirements for interlocutory review under 28 U.S.C. § 1292(a)(1) and Carson v. American Brands, Inc. The appeal was dismissed for lack of jurisdiction. View "Rey v. LCMC Health Care Partners" on Justia Law

A property development company sought to build mixed-use housing developments near a public-use airport operated by the City of Longmont, Colorado. The proposed developments were located under the airport’s approach and departure paths. The company received preliminary approvals from the City for its projects and obtained “Determinations of No Hazard” from the Federal Aviation Administration (FAA), which found the developments would not obstruct flight paths. However, the FAA sent letters to the City warning that approving the developments would violate a grant assurance tied to the airport’s federal funding, specifically regarding land use compatibility. The City subsequently denied the company’s proposal, citing multiple reasons, including the FAA’s letters, concerns from state authorities, its own findings of incompatibility, and public opposition.After the City’s decision, the developer asked the FAA to withdraw its letters, but the FAA declined. The company then petitioned the United States Court of Appeals for the District of Columbia Circuit to order the FAA to vacate and withdraw these letters, arguing that the FAA’s actions directly caused its injury by influencing the City’s denial.The D.C. Circuit dismissed the petition for lack of standing. The court held that the developer failed to demonstrate that vacating the FAA’s letters would likely result in the City approving the developments, as the City had provided multiple independent reasons for its denial beyond the FAA’s communications. The court also found that the company did not comply with the court’s procedural rule requiring petitioners to argue and provide evidence of standing in their opening brief. Accordingly, the petition was dismissed. View "ModernWest Longmont, LLC v. FAA" on Justia Law

Two American companies, Declan Flight, Inc. and Right Rudder Aviation, LLC (RRA), developed successful sales and distribution relationships with Pipistrel, a Slovenian aircraft manufacturer, through contracts signed in 2020 and 2021. Their contracts contained forum-selection clauses specifying Slovenia as the forum for disputes. In 2022, Textron, Inc., a large U.S. aerospace company, acquired Pipistrel through its subsidiary Textron eAviation, Inc. Shortly after the acquisition, Textron and eAviation orchestrated the termination of Declan’s and RRA’s contracts. RRA also lost a separate sales contract with Mesa Airlines after Textron and eAviation allegedly interfered with that business relationship.Declan and RRA sued Textron and eAviation in the United States District Court for the Middle District of Florida, alleging tortious interference with the Pipistrel contracts and with the Mesa Airlines contract. The district court dismissed the claims related to the Pipistrel contracts (Counts I and II) for forum non conveniens, holding that the forum-selection clauses could be enforced by Textron and eAviation—nonsignatories—under the federal doctrine of equitable estoppel, thus requiring litigation to proceed in Slovenia. The district court also found that personal jurisdiction existed for the Mesa Airlines claim (Count III), but dismissed it for failure to state a claim.On appeal, the United States Court of Appeals for the Eleventh Circuit reversed the dismissal of Counts I and II. The court held that the applicability of the forum-selection clauses is governed by Slovenian law, not federal common law, and that Slovenian law does not permit nonsignatories to invoke these clauses. Thus, the district court erred in applying the modified forum non conveniens rule from Atlantic Marine. The Eleventh Circuit also reversed the finding of personal jurisdiction over Textron and eAviation as to Count III, remanding all claims for further proceedings. View "Declan Flight, Inc. v. Textron eAviation, Inc." on Justia Law

A 14-year-old passenger, Kevin Greenidge, died from cardiac arrest aboard an American Airlines international flight from Honduras to Florida. Kevin, who suffered from multiple health conditions, began experiencing breathing difficulties soon after takeoff. Despite the crew’s efforts and the assistance of two medical professionals on board, Kevin did not survive. During the resuscitation attempt, there was a dispute about whether the aircraft’s automated external defibrillator (AED) functioned properly, as several witnesses reported it failed to deliver a shock, despite internal device data indicating otherwise.Following Kevin’s death, his aunt, Melissa Arzu, acting individually and as administrator of his estate, filed suit against American Airlines in the United States District Court for the Northern District of Texas. She alleged liability and loss of consortium under the Montreal Convention and breach of contract under Texas law. Both parties moved for summary judgment. The district court granted summary judgment in favor of American Airlines on all claims, finding that the alleged deviations from airline policy and medical response did not constitute an “accident” under Article 17 of the Montreal Convention.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed summary judgment on the claims based on the crew’s allegedly ineffective medical response, holding that such a response does not amount to an “accident” under Article 17 without unusual circumstances or willful inaction. However, the court reversed summary judgment on the claims premised on the AED malfunction, finding that a genuine dispute remained as to whether the AED’s failure, in violation of FAA regulations, could be considered an “unexpected or unusual event.” The court also held that the Montreal Convention expressly preempts Arzu’s breach of contract claim. View "Arzu v. American Airlines" on Justia Law

A helicopter manufactured in 1997 by Bell Helicopter Textron Inc. was involved in a fatal crash in 2017 after an engine cowling came loose and struck the tail rotor. The pilot, working for a later owner, died in the accident. The pilot’s family brought suit against Bell, alleging that the flight manual was defective for failing to include an explicit warning about the dangers of flying with an unsecured engine cowling, even though the manual included a checklist item stating the cowling should be “Secured.” The physical cowling and its fasteners were original to the aircraft and had not been replaced or modified.Bell asserted that the General Aviation Revitalization Act of 1994 (GARA), an 18-year statute of repose, barred the suit. The plaintiffs responded that the repose period had been reset because Bell periodically revised the flight manual in the years before the crash. The 270th District Court of Harris County denied Bell’s summary judgment motion without explanation. Bell then sought mandamus relief from the Fourteenth Court of Appeals, which denied the petition without a substantive opinion.The Supreme Court of Texas held that GARA’s 18-year clock is only reset when a “new” part or component, including a substantive revision to the flight manual, is added or replaced and is alleged to have caused the accident. Because the engine-cowling instruction in the manual, which was the alleged defect, had not been revised since 1997, and no relevant “new” part was implicated, the rolling provision of GARA did not apply. The court conditionally granted Bell’s petition for writ of mandamus and directed the district court to grant summary judgment for Bell, holding that GARA bars the suit and that mandamus relief was appropriate to prevent litigation Congress has expressly foreclosed. View "IN RE BELL HELICOPTER SERVICES INC." on Justia Law

The case concerns a fatal helicopter crash during a sightseeing tour in Hawaii, resulting in the deaths of all aboard, including the plaintiffs’ daughter. The helicopter, manufactured by Robinson Helicopter Company in 2000, had its main rotor hub and blades replaced with new, identical parts from Robinson in December 2018, which was over eighteen years after the helicopter’s initial delivery. The plaintiffs alleged that defects in the replaced rotor hub and blades caused the crash, and brought claims for negligence, strict products liability, and failure to warn.The United States District Court for the District of Hawaii heard the case first. Robinson invoked the General Aviation Revitalization Act of 1994 (GARA), which generally bars actions against manufacturers eighteen years after delivery of the aircraft. The plaintiffs argued for exceptions under GARA’s “rolling provision”—which restarts the repose period for newly replaced parts—and the “fraud exception”—which removes the bar if the manufacturer concealed or misrepresented material information to the FAA. The district court granted summary judgment for Robinson, holding that the rolling provision did not apply because the replacement parts were not substantively altered from the originals, and that the plaintiffs failed to plead fraud with the necessary specificity. The court also denied the plaintiffs’ motion to further amend their complaint.On appeal, the United States Court of Appeals for the Ninth Circuit held that the district court erred in requiring a “substantive alteration” for the rolling provision to apply, as GARA only requires that a new part replaces an old one. The Ninth Circuit reversed the grant of summary judgment in part and remanded for a new causation analysis regarding the replaced parts. However, the court affirmed the lower court’s determinations that the plaintiffs failed to meet the requirements for the fraud exception and that denying leave to amend was not an abuse of discretion. View "MCAULIFFE V. ROBINSON HELICOPTER COMPANY" on Justia Law

A United States citizen of Pakistani descent challenged his continued placement on the federal No Fly List, which prohibits individuals from boarding flights in U.S. airspace. After enhanced screening and questioning by the FBI in 2012 and being prevented from boarding a flight in 2019, he sought redress through the Department of Homeland Security Traveler Redress Inquiry Program (DHS TRIP). He received an unclassified summary stating that his listing was based on concerns about his associations and candor regarding activities in Pakistan. He contested these grounds, denied any terrorist associations, and argued that his inclusion was erroneous.While his DHS TRIP redress was pending, he filed suit in the United States District Court, which ultimately concluded it lacked jurisdiction, as exclusive review of the Transportation Security Administration (TSA) Administrator’s order rested with the United States Court of Appeals for the District of Columbia Circuit. The district court transferred his claims to the appellate court.The United States Court of Appeals for the District of Columbia Circuit reviewed the TSA Administrator’s order, applying a “substantial evidence” and “arbitrary and capricious” standard, and reviewed constitutional claims de novo. The court dismissed the petitioner’s Religious Freedom Restoration Act claim for lack of standing, finding insufficient concrete plans to travel for religious purposes. It denied his other claims, holding that there is no fundamental right to air travel under substantive due process, and that the DHS TRIP process provides constitutionally adequate procedural protections. The court found that the Administrator’s order was supported by substantial evidence and not arbitrary or capricious. The court also rejected the argument that the major questions doctrine applied, finding TSA’s statutory authority adequate. The petition was dismissed in part and otherwise denied. View "Khalid v. TSA" on Justia Law

A man traveling with his family, including his thirteen-year-old daughter, on Delta Air Lines was reported by a flight attendant for suspected human trafficking or sexual abuse after comforting his distressed daughter during turbulence. The flight attendant relayed her suspicions to the flight captain, who then involved the airport station manager, resulting in a call to law enforcement. Upon landing, police detained and questioned the man and his daughter but found no probable cause for arrest. The incident caused the man significant emotional distress and exacerbated his pre-existing PTSD.He subsequently filed a lawsuit in the Circuit Court of the City of Newport News against the flight attendant, Delta, and Endeavor Air, alleging negligence, intentional infliction of emotional distress, tortious interference with parental rights, and false imprisonment. The defendants removed the case to the United States District Court for the Eastern District of Virginia and moved to dismiss, claiming immunity under Virginia Code § 63.2-1512. The district court agreed, holding that the defendants were immune because the report, even if made only to law enforcement and not to social services, was made in good faith and without malicious intent. The man appealed, and the United States Court of Appeals for the Fourth Circuit was uncertain whether the immunity statute applied in this context and certified the legal question to the Supreme Court of Virginia.The Supreme Court of Virginia, upon review of the certified question, held that Virginia Code § 63.2-1512 does not provide immunity to a nonmandatory reporter who, in good faith, reports suspected child abuse to law enforcement without also contacting a Department of Social Services employee or the designated hotline. The Court reasoned that the statutory language is clear and limits immunity to specific categories, which do not include complaints made solely to law enforcement by nonmandatory reporters. The answer to the certified question was “no.” View "Cupp v. Delta Air Lines, Inc." on Justia Law

Following two fatal airplane crashes involving Boeing 737 MAX aircraft in 2018 and 2019, which resulted in significant loss of life, the Department of Justice investigated Boeing for misleading the Federal Aviation Administration about changes to flight control systems. The Department initially entered into a Deferred Prosecution Agreement (DPA) with Boeing, requiring the company to pay a substantial fine and undertake remedial measures. After Boeing was alleged to have breached the DPA, the Department negotiated a Non-Prosecution Agreement (NPA) in 2025, again requiring compliance and penalties. Family members of crash victims challenged both the DPA and NPA, asserting violations of their rights under the Crime Victims’ Rights Act (CVRA).The families first moved in the United States District Court for the Northern District of Texas to set aside the DPA, arguing they were denied timely notice and the right to confer as crime victims. The district court found the Department had not acted in bad faith but had committed a legal error in initially failing to recognize the families as crime victims. The court concluded, however, that it lacked authority to review or alter the terms of the DPA. When the Department later moved to dismiss the charges based on the NPA, the families objected, but the district court granted the motion, finding the Department had provided sufficient reasons and had not acted with bad faith.The families petitioned the United States Court of Appeals for the Fifth Circuit for writs of mandamus. The Fifth Circuit held that the challenge to the DPA was moot because it was no longer in effect after Boeing’s breach. As to the NPA, the court found the Department had satisfied the CVRA’s requirements to confer with and treat the families fairly. The court also ruled it lacked jurisdiction under the CVRA to conduct a substantive review of the district court’s dismissal of charges. The petitions for writ of mandamus were denied. View "In re Ryan" on Justia Law