Judge Eunice Lee, nominated by President Biden to the Second Circuit, wrote a unanimous decision that reversed a lower court and ruled that family members could pursue damages claims against companies that they contend caused a fatal helicopter crash killing two Army pilots. The November 2023 decision was in Jones v Goodrich Pump & Engine Control Systems Inc.

 

What happened in this case?  

Army officers John David Hortman and Steven Redd were piloting a military helicopter during a training exercise when it crashed, killing them both. Evidence suggested that defects in the design and manufacture of an engine module caused the crash. Surviving family members of the two victims, led by Brenda Jones and Adalia Lee Redd, filed suit seeking damages from the corporations that manufactured and sold the key part.

The trial court, however, dismissed the case on summary judgment. It ruled that a federal law, the Federal Aviation Act (FAAct), pre-empted the families’ claims from going forward. It also ruled that they had not presented sufficient evidence to prove strict liability for manufacture or design defects. The families appealed to the Second Circuit.

 

How did Judge Lee and the Second Circuit Rule and Why is it Important?

Judge Lee wrote a unanimous decision that reversed the lower court and sent the case back so that the families could pursue their claims. Judge Lee explained that the district court had misinterpreted prior Second Circuit precedent and that the FAAct applies only to accidents involving “civil aircraft”, not to “military aircraft” like the helicopter in this case. In addition, Judge Lee wrote that a review of the record demonstrated that the families had presented enough evidence to seek a jury determination on their claims of design defects. While the companies could raise other defenses, she concluded, the lower court decision should be vacated so that the families could have their day in court on their claims.

Judge Lee’s ruling is obviously important so that the surviving families could seek justice on their claims concerning the tragic deaths of Hortman and Redd. In addition, the decision will also benefit others seeking to hold corporations accountable for aircraft defects, particularly in the Second Circuit states of New York, Connecticut, and Vermont. The ruling also serves as an important reminder of the significance of promptly confirming high-quality nominees like Judge Lee to our federal courts.