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Western Helicopter Services, Inc. v. Rogerson Aircraft Corp.

Citations: 811 P.2d 627; 311 Or. 361; 1991 Ore. LEXIS 32Docket: USDC Civil 87-1435-FR; SC S37702

Court: Oregon Supreme Court; May 14, 1991; Oregon; State Supreme Court

Narrative Opinion Summary

The Supreme Court of Oregon was requested by the U.S. District Court for the District of Oregon to accept certification of two legal questions concerning wrongful death claims and product liability under Oregon law. This request arose from a case involving a helicopter crash resulting in a wrongful death and the destruction of a helicopter, leading to claims of strict liability, negligence, and breach of warranty. The district court sought clarity on whether the statute of limitations for wrongful death or product liability applied and if it was tolled by the plaintiff's knowledge of the cause. The Oregon Supreme Court declined to certify the questions, citing existing precedent from Korbut v. Eastman Kodak Co. as controlling. The decision emphasized the statutory requirements for certification, including the necessity for questions to originate from designated courts, involve Oregon law, and lack controlling precedent. The court determined that the criteria were not sufficiently met to warrant certification, asserting that existing jurisprudence provided adequate guidance. Consequently, the certification was denied, leaving the district court to resolve the issues based on current precedent.

Legal Issues Addressed

Certification of Legal Questions under ORS 28.200

Application: The Oregon Supreme Court declined to accept certification of legal questions from the U.S. District Court, illustrating the discretionary nature of the process and emphasizing the necessity of meeting statutory criteria.

Reasoning: The Oregon Supreme Court has discretion regarding the acceptance of such certifications and has previously addressed certified questions since the law's enactment in 1983. However, in this instance, the court declined to accept the certification for the first time, outlining the criteria for accepting certified questions.

Controlling Precedent in Certification Decisions

Application: The court found that existing precedent in Korbut v. Eastman Kodak Co. served as controlling precedent, influencing its decision to deny certification.

Reasoning: However, the court disagreed with the district court's view that there was no controlling Oregon precedent, asserting that the precedent set in Korbut is binding.

Criteria for Certification of Questions

Application: The court detailed five requirements for certification: originating from a designated court, posing a question of law, involving Oregon law, potentially determinative of the case, and lacking controlling precedent.

Reasoning: The certifying court must fulfill five specific requirements for certification of legal questions.

Statute of Limitations in Wrongful Death and Product Liability Claims

Application: The case highlighted the conflict regarding which statute of limitations applies to wrongful death claims based on product liability, with the court ultimately relying on existing state precedent.

Reasoning: The first question asked whether the statute of limitations for wrongful death claims under ORS 30.020(1) or for product liability actions under ORS 30.905 applies to a wrongful death claim based on product liability.