Justia Products Liability 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