The United States Court of Appeals for the Third Circuit affirmed a lower court's ruling that the General Aviation Revitalization Act ("GARA") does not protect Continental Motors, Inc. ("Continental") from liability for a defective exhaust valve.
In 2010, Daniel Snider died after the aircraft in which he was a passenger crashed due to an engine failure. Mr. Snider's widow and son sued Continental, alleging that it had negligently manufactured a component part of the engine that ultimately failed. Plaintiffs specifically alleged that the engine's exhaust valve guide in the cylinder assembly was defective. The plane's cylinder assembly had been replaced six years prior to the crash. At trial, the jury agreed with the plaintiffs' contentions and found Continental liable.
On appeal, Continental alleged that GARA, which bars lawsuits against the manufacturer of an "aircraft or any 'component, system, subassembly, or other part of the aircraft' if the manufacturer's product failed more than eighteen years after the product was delivered," insulated it from liability. In support of its argument, Continental stated that a third-party manufactured the allegedly defective exhaust valve guide that was installed six years prior to the crash.
The Court disagreed, noting that the "'exhaust valve guides ... were designed by Continental and manufactured specifically for Continental.'" Continental also "tested the hardness of the exhaust valve guides and individually reamed each guide to specifically fit a particular Continental cylinder assembly." Given these facts, the Court concluded that sufficient evidence existed for the jury to have concluded that Continental manufactured the defective part within the eighteen years preceding the fatal crash.
The Court also rejected Continental's other arguments on appeal, holding that (1) there was sufficient evidence to support a finding that a manufacturing defect caused the accident; (2) the jury instructions at trial were proper; and, (3) the plaintiff's documentary evidence and expert witness testimony were admissible. Snider v. Sterling Airways, Inc., No. 173182, 2018 U.S. App. LEXIS 36685 (3d Cir. Dec. 28, 2018).
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