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

The case centers on an incident during a Delta Air Lines domestic flight, where a passenger’s behavior prompted concerns among fellow travelers and flight attendants. After an off-duty pilot and other passengers reported the passenger’s conduct as suspicious, the lead flight attendant, following consultation with the captain, approached the passenger and attempted to ask him to remain seated. This interaction escalated into a physical confrontation, leading the flight attendant to request assistance from a federal law enforcement agent onboard. The agent, with the flight attendant’s help, restrained the passenger until the plane landed. The passenger later alleged that he suffered physical and emotional injuries as a result of the restraint.At trial in the United States District Court for the Central District of California, a jury found in favor of the passenger, awarding him substantial damages for bodily and emotional injuries. However, the district court vacated the verdict, citing excessive damages and the interdependence of liability and damages. The court subsequently granted summary judgment for Delta Air Lines, concluding that the airline was immune from liability under the Aviation and Transportation Security Act (ATSA) for any injuries sustained after the flight attendants reported the passenger’s behavior to law enforcement.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s decision de novo. The Ninth Circuit affirmed the district court’s grant of summary judgment, holding that ATSA immunity applies not only to the initial disclosure of suspicious activity to law enforcement but also to subsequent conduct stemming from law enforcement’s decisions following such disclosure. The court found no genuine dispute of material fact regarding whether the passenger’s conduct was objectively suspicious or whether Delta was solely responsible for the injuries. As Delta was immune for all physical injuries, the passenger could not recover for any alleged emotional injuries under the Montreal Convention. View "BANDARY V. DELTA AIR LINES, INC." on Justia Law

A helicopter owned and operated by the Huntington Beach Police Department crashed in 2022, resulting in the death of Officer Nicholas Vella and serious injury to Officer RJ Garwood. The plaintiffs alleged that the crash was caused by a defect in the helicopter’s stability augmentation system. The helicopter, a model MD520N, was manufactured by The Boeing Company in 1998 and delivered to the police department that same year. It had a seating capacity of five and was type and airworthiness certified by the Federal Aviation Administration (FAA).The plaintiffs initially brought their claims for strict products liability, breach of warranties, and negligence in California state court. The case was removed to the United States District Court for the Central District of California on the basis of diversity jurisdiction. The defendants, including The Boeing Company and MacD Helicopters, moved to dismiss, arguing that the claims were barred by the General Aviation Revitalization Act’s (GARA) 18-year statute of repose. The plaintiffs contended that GARA did not apply to “public aircraft” such as those owned by governmental entities. The district court rejected the plaintiffs’ arguments, found that the helicopter met GARA’s definition of “general aviation aircraft,” and granted the motions to dismiss. The court certified its decision for interlocutory appeal and stayed further proceedings.The United States Court of Appeals for the Ninth Circuit considered whether GARA’s statute of repose applied to the police helicopter. The court held that the statute’s definition of “general aviation aircraft” includes government-owned aircraft, as long as the statutory requirements are met. The panel expressly rejected the argument that the Federal Aviation Act’s “public aircraft” definition is incorporated into GARA and concluded that GARA contains no “public aircraft” exception. The Ninth Circuit affirmed the district court’s dismissal of the lawsuit. View "VELLA V. MACD HELICOPTERS, INC." on Justia Law

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

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 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

Ronald B. Panting, an independent contractor serving as a Designated Pilot Examiner (DPE) for the FAA, was conducting a pilot certification checkride for Michael Trubilla in a plane rented from the LeMay Aero Club, a government-affiliated organization. Both men died when the plane crashed during the checkride. Five days prior to the accident, Ronald signed a covenant not to sue the government for injuries sustained while participating in Aero Club activities, applicable to himself and his estate. His spouse, Lynne D. Panting, sued the United States under the Federal Tort Claims Act, alleging negligent maintenance of the aircraft.The United States District Court for the District of Nebraska denied the government’s motion for summary judgment, ruling the covenant not to sue was void as against public policy under Nebraska law. The court did not address Lynne’s alternative argument that the covenant did not apply to Ronald’s activities as a DPE on the day of the crash. Following a bench trial, the district court found the government negligent and entered judgment for Lynne, awarding damages. The government appealed, challenging the district court’s decision regarding the covenant’s validity.The United States Court of Appeals for the Eighth Circuit held that it had jurisdiction to review the denial of summary judgment because the enforceability of the covenant was a purely legal issue. Applying Nebraska law, the appellate court determined the covenant was neither clearly repugnant to public policy nor the product of disparate bargaining power, and that the Aero Club did not provide a public or essential service. The Eighth Circuit reversed the district court’s judgment and remanded for consideration of whether the covenant covered Ronald’s activities as a DPE, and for further proceedings as appropriate. View "Panting v. United States" on Justia Law

William D. Lunn, individually and as the representative of the estates of his three deceased children, filed a wrongful death lawsuit against Continental Motors, Inc. (CMI) in October 2009, alleging a design defect caused an airplane crash that killed his children. In September 2012, CMI made an unapportioned offer of judgment for $300,000, which Lunn rejected. After a lengthy litigation process, a jury found in favor of CMI. Lunn moved for a new trial, which the district court granted in February 2021. CMI appealed, arguing the claims were barred by the statute of repose under the General Aviation Revitalization Act. The Court of Civil Appeals (COCA) reversed the district court's decision.CMI then sought attorney's fees, claiming entitlement under the offer of judgment statute since the judgment was less than their offer. The district court denied the motion, ruling the unapportioned offer invalid. CMI appealed this decision. COCA affirmed the district court's ruling, referencing prior cases that required offers of judgment to be apportioned among plaintiffs to be valid.The Supreme Court of the State of Oklahoma reviewed the case to address whether an offer of judgment under 12 O.S.2021, § 1101.1(A) must be apportioned among multiple plaintiffs. The court held that such offers must indeed be apportioned to allow each plaintiff to independently evaluate the settlement offer. The court emphasized that unapportioned offers create confusion and hinder the plaintiffs' ability to assess the offer's value relative to their claims. Consequently, the court vacated COCA's opinion and affirmed the district court's judgment, ruling CMI's unapportioned offer invalid. View "Lunn v. Continental Motors, Inc." on Justia Law