Justia Products Liability Opinion Summaries

Articles Posted in Aviation
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Sikkelee was killed when a Cessna aircraft he was piloting crashed after taking off from North Carolina's Transylvania County Airport. The aircraft had a Lycoming engine; Sikkelee's widow alleged the aircraft lost power due to a defect in the design of the engine and its carburetor. The FAA had issued Lycoming a type certificate for the engine, certifying that the design performs properly and satisfies federal regulations. Sikkelee’s widow brought strict liability and negligence claims against Lycoming, alleging design defect. The Third Circuit held that Sikkelee’s state-law claims are not barred based on the doctrine of field preemption. On remand, the district court concluded the claims were conflict-preempted and that Lycoming was entitled to summary judgment on Sikkelee’s strict liability and negligence claims based on Pennsylvania law. The court granted Lycoming summary judgment on Sikkelee’s claim that Lycoming violated 14 C.F.R. 21.3 by failing to notify the FAA of the alleged defect. The Third Circuit reversed in part, rejecting an argument that Sikkelee’s claims were conflict-preempted because FAA regulations made it impossible for Lycoming to unilaterally implement design changes Pennsylvania law allegedly would have required. Lycoming has not produced clear evidence that the FAA would not have allowed it to change the design set forth in the type certificate. Summary judgment on Sikkelee’s strict liability and negligence claims was inappropriate because there are genuine disputes of material fact concerning causation. Summary judgment was proper on the failure-to-notify-the-FAA claim. View "Sikkelee v. Precision Airmotive Corp" on Justia Law

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The Textron Lycoming engine, manufactured in 1969, was installed on a Cessna aircraft in 1998. It was overhauled in 2004, with a carburetor in accordance with Lycoming’s type-certificated design. Sikkelee was piloting the aircraft when it crashed shortly after taking off. Sikkelee died. His estate sued, claiming that the aircraft lost power as a result of a malfunction or defect in the carburetor. The court held that Sikkelee’s claims, which were premised on state law standards of care, fell within the preempted “field of air safety.” An amended complaint incorporated federal standards of care by alleging violations of FAA regulations. Before trial, the court concluded that the federal standard of care was established in the type certificate. Reasoning that the FAA issues a type certificate based on its determination of compliance with pertinent regulations, it held that the FAA’s issuance of a type certificate for the engine meant that the federal standard of care had been satisfied as a matter of law. The court granted Lycoming partial summary judgment and certified an immediate appeal. The Third Circuit reversed, concluding that federal statutes and FAA regulations reflect that Congress did not intend to categorically preempt aircraft products liability claims. Subject to traditional principles of conflict preemption, including concerning specifications included in a type certificate, aircraft products liability cases may proceed using a state standard of care. View "Sikkelee v. Precision Airmotive Corp" on Justia Law

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In 2003, Russell, the sole occupant and pilot of an Agusta 109C helicopter, died after his helicopter crashed in Illinois. Russell, a resident of Georgia, was living in Illinois and working for an Illinois air ambulance service operating in the Chicago area. The helicopter was manufactured in Italy in 1989. The trial court dismissed claims against SNFA, a French company that manufactured a custom tail-rotor bearing for the helicopter, for lack of jurisdiction. The appellate court reversed and the Illinois Supreme Court affirmed, noting that Agusta and its American subsidiary, AAC, effectively operated as an American distributor for the tail-rotor bearings in the U.S. market and that SNFA custom manufactured the bearings at issue specifically for Agusta. By engaging a business entity located in Illinois, SNFA undoubtedly benefitted from Illinois’ system of laws, infrastructure, and business climate and has the requisite minimum contacts with Illinois for purposes of specific personal jurisdiction. The exercise of jurisdiction is reasonable; Illinois has an indisputable interest in resolving litigation stemming from a fatal Illinois helicopter accident.View "Russell v. SNFA" on Justia Law

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Crouch was piloting his Piper Lance II single-engine airplane with Hudson as passenger. After losing engine power at an altitude of 5000 feet, and finding it impossible to reach an airport, Crouch made a forced landing in a field near Bardstown. The plane’s engine was manufactured in 1978 and overhauled in 2005, with installation of a rebuilt magneto that allegedly detached, causing the crash. Both occupants survived but suffered serious permanent injuries, including paraplegia. The district court dismissed, on summary judgment, their allegations that the aircraft engine manufacturer was liable for negligently failing to warn airplane owners and operators, and failing to notify regulatory authorities, of defects in the engine and its components, finding that the allegations failed to make out a claim in avoidance of the applicable period of repose under the General Aviation Revitalization Act, 49 U.S.C. 40101. The Sixth Circuit affirmed. Plaintiffs did not show or even allege that a revised overhaul manual contained a substantive alteration that caused harm and the evidence did not support a theory that defendants withheld information. View "Crouch v. Honeywell Int'l, Inc." on Justia Law