Boyle v. United Technologies Corp., 487 U.S. 500 (1988)
Military equipment that meets prior requirements set by the federal government cannot have a design defect sufficient to hold its manufacturer liable.
Boyle's son was a Marine helicopter co-pilot who died when his helicopter crashed into the ocean during a training exercise. Although his son survived the initial impact, he drowned because he was unable to escape the helicopter, which was a CH-53D model built by the Sikorsky Division of United Technologies for the armed forces. Boyle brought a product liability action against Sikorsky on the grounds that the helicopter's emergency escape system was defectively designed and that Sikorsky had failed to properly repair a component of the automatic flight control system. He prevailed in the trial court and received $725,000 in damages from the jury. However, the intermediate appellate court disallowed the defective design claim because it ruled that the military contractor defense applied to Sikorsky.Opinions
- Antonin Scalia (Author)
- William Hubbs Rehnquist
- Byron Raymond White
- Sandra Day O'Connor
- Anthony M. Kennedy
In areas where there is a uniquely federal interest, federal common law prevails in any conflict with state law. When a government contract requires a certain design, it trumps any state duty of care that clashes with it. Government employees and agencies are free from liability under the Federal Tort Claims Act when they engage in their discretionary functions. The design of a helicopter is a discretionary function, so military contractors have immunity if their equipment conforms to the specifications provided by the federal government. The Navy approved the design of the helicopter before it was built. Any duty for the supplier would consist only of warning the government about any risks in the use of the equipment.
- William Joseph Brennan, Jr. (Author)
- Thurgood Marshall
- Harry Andrew Blackmun
Federal laws should pre-empt state law only if Congress has explicitly provided that they should supersede state law, unless a few narrow exceptions apply. Congress has declined to grant immunity to military contractors, despite their efforts to obtain it. Uniquely federal interests do not arise in the context of non-government employees like military contractors.
- John Paul Stevens (Author)
Congress should have the authority over creating an entirely new doctrine because it is better situated than the courts to balance the conflicting interests that are at stake.Case Commentary
The Federal Tort Claims Act now covers this area of law more broadly, providing immunity when federal officials are acting within the scope of their employment, even if their actions are not discretionary. Therefore, this lawsuit probably would not have survived as long as it did if it were brought now.
U.S. Supreme CourtBoyle v. United Technologies Corp., 487 U.S. 500 (1988)
Boyle v. United Technologies Corp.
Argued October 13, 1987
Reargued April 27, 1988
Decided June 27, 1988
487 U.S. 500
David A. Boyle, a United States Marine helicopter copilot, drowned when his helicopter crashed off the Virginia coast. Petitioner, the personal representative of the heirs and estate of Boyle, brought this diversity action in Federal District Court against the Sikorsky Division of respondent corporation (Sikorsky), alleging, inter alia, under Virginia tort law, that Sikorsky had defectively designed the helicopter's copilot emergency escape-hatch system. The jury returned a general verdict for petitioner, and the court denied Sikorsky's motion for judgment notwithstanding the verdict. The Court of Appeals reversed and remanded with directions that judgment be entered for Sikorsky. It found that, as a matter of federal law, Sikorsky could not be held liable for the allegedly defective design because Sikorsky satisfied the requirements of the "military contractor defense."
1. There is no merit to petitioner's contention that, in the absence of federal legislation specifically immunizing Government contractors, federal law cannot shield contractors from liability for design defects in military equipment. In a few areas involving "uniquely federal interests," state law is preempted and replaced, where necessary, by federal law of a content prescribed (absent explicit statutory directive) by the courts. The procurement of equipment by the United States is an area of uniquely federal interest. A dispute such as the present one, even though between private parties, implicates the interests of the United States in this area. Once it is determined that an area of uniquely federal interest is implicated, state law will be displaced only where a "significant conflict" exists between an identifiable federal policy or interest and the operation of state law, or the application of state law would frustrate specific objectives of federal legislation. Here, the state-imposed duty of care that is the asserted basis of the contractor's liability is precisely contrary to the duty imposed by the Government contract. But even in this situation, it would be unreasonable to say that there is always a "significant conflict" between state law and a federal policy or interest. In search of a limiting principle to identify when a significant
conflict is present, the Court of Appeals relied on the rationale of Feres v. United States, 340 U. S. 135. This produces results that are in some respects too broad and in some respects too narrow. However, the discretionary function exception to the Federal Tort Claims Act does demonstrate the potential for, and suggest the outlines of, "significant conflict" between federal interest and state law in this area. State law is displaced where judgment against the contractor would threaten a discretionary function of the Government. In sum, state law which imposes liability for design defects in military equipment is displaced where (a) the United States approved reasonably precise specifications; (b) the equipment conformed to those specifications; and (c) the supplier warned the United States about dangers in the use of the equipment known to the supplier but not to the United States. Pp. 487 U. S. 504-513.
2. Also without merit is petitioner's contention that, since the Government contractor defense formulated by the Court of Appeals differed from the instructions given by the District Court to the jury, the Seventh Amendment guarantee of jury trial requires a remand for trial on the new theory. If the evidence presented in the first trial would not suffice, as a matter of law, to support a jury verdict under the properly formulated defense, judgment could properly be entered for respondent at once, without a new trial. It is unclear from the Court of Appeals' opinion, however, whether it was in fact deciding that no reasonable jury could, under the properly formulated defense, have found for the petitioner on the facts presented, or rather was assessing on its own whether the defense had been established. The latter would be error, since whether the facts established the conditions for the defense is a question for the jury. The case is remanded for clarification of this point. Pp. 487 U. S. 513-514.
792 F.2d 413, vacated and remanded.
SCALIA, J., delivered the opinion of the Court, in which REHNQUIST, C.J., and WHITE, O'CONNOR, and KENNEDY, JJ., joined. BRENNAN, J., filed a dissenting opinion, in which MARSHALL and BLACKMUN, JJ., joined, post, p. 487 U. S. 515. STEVENS, J., filed a dissenting opinion, post, p. 487 U. S. 531.