Justia Aviation Opinion Summaries

This case stems from a fatal plane crash in which a pilot, Chelsea Brittney Infanger, collided with exhaust stacks owned by a processing plant near the Burley Municipal Airport in Idaho. The stacks, which extended over 100 feet high, were situated within the runway’s approach path and had been the subject of prior regulatory concern. The pilot’s parents brought a wrongful death suit, alleging that the Idaho Department of Transportation’s Division of Aeronautics negligently failed to regulate or mitigate the known risk posed by these stacks, arguing that various statutory, common law, special relationship, and contractual duties compelled the Division to act.After settlements with other defendants, the case proceeded against the Division in the District Court of the Fourth Judicial District, Ada County. The Division moved for summary judgment, contending it owed no individualized duty to the deceased under the Airport Zoning Act, common law, or through a special relationship, and that it was immune under the Idaho Tort Claims Act. The district court agreed, holding that the Division’s statutory duties were general obligations to the public, not specific duties to individual aviators, and found no basis for liability under special relationship or contract theories. The court granted summary judgment to the Division, and the plaintiffs appealed.The Supreme Court of the State of Idaho affirmed the district court’s decision. It held that the Airport Zoning Act did not create a tort duty to a particular class of persons, but rather imposed general obligations for public safety, and thus could not support a negligence per se claim. The Court also found that the plaintiffs did not preserve or demonstrate the elements necessary for a special relationship or assumed duty sufficient to impose liability. The Court declined to award attorney fees, but granted costs to the Division. View "Infanger v. State of Idaho, Idaho Department of Transportation" on Justia Law

This appeal stemmed from a dispute between SilverWing at Sandpoint, LLC (“SilverWing”) and Appellant Bonner County, Idaho (the “County”). SilverWing sought to develop a residential hangar and taxiway adjacent to the Sandpoint Airport for residents who wished to park their aircraft in their home garage. SilverWing alleged that “[i]n 2007, the County provided to SilverWing an ALP that reflected the existing location of the Airport’s runway, and made no mention or reference to any plans for the runway to be moved. At the same time, the County promised that there were no plans regarding changes to runway location which would be incompatible with SilverWing’s development.” During the initial stages of engineering for the development, the County informed SilverWing that it needed to move the taxiway from where it was originally planned onto County-owned airport property, to accord with the County’s Airport Layout Plan (ALP). SilverWing proceeded with its development based on the County’s assurances, and built a taxiway and other infrastructure, including streets, to support its development. Once the taxiway was built, SilverWing learned that the placement of the taxiway was not approved by the FAA. After several years of legal maneuvering, SilverWing proceeded against the County in court, ultimately on a theory of promissory estoppel. After trial, a jury returned a verdict in favor of SilverWing. The County filed a motion for judgment notwithstanding the verdict (“JNOV”), which the district court denied. The County appealed. The Idaho Supreme Court reversed the district court’s ruling on the JNOV and vacated its ruling regarding attorney fees. The Court determined the district court erred with respect to JNOV on the claim of promissory estoppel: "SilverWing actually got what it claims the County promised—an FAA approved taxiway in the location where SilverWing built it. SilverWing can now sell its development with no regulatory uncertainty." View "SilverWing v. Bonner County" on Justia Law