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Blazevska v. Raytheon Aircraft Co.

Citations: 522 F.3d 948; 2008 U.S. App. LEXIS 7653; 2008 WL 962161Docket: 06-16028

Court: Court of Appeals for the Ninth Circuit; April 10, 2008; Federal Appellate Court

Narrative Opinion Summary

The case involves a wrongful death suit filed by the family members of eight Macedonian residents who perished in a 2004 plane crash in Bosnia against Raytheon Aircraft Company, the aircraft's manufacturer. The plaintiffs alleged defects in the aircraft under Macedonian law. The district court granted summary judgment in favor of Raytheon, citing the General Aviation Revitalization Act of 1994 (GARA), which imposes an eighteen-year statute of repose for claims against aircraft manufacturers. The court ruled that the plaintiffs' claims were barred as the aircraft was manufactured in 1980, and the crash occurred in 2004. The plaintiffs argued that the presumption against extraterritoriality should prevent GARA's application; however, the court concluded that this presumption was irrelevant as GARA pertains to seeking compensation in U.S. courts and does not regulate international conduct. Jurisdiction was based on federal diversity, with Raytheon being a Kansas corporation and the appellants Macedonian citizens. The court affirmed the district court's judgment, emphasizing that GARA's application does not extend to extraterritorial conduct, aligning with the principle that U.S. statutes are presumed to apply domestically unless explicitly stated otherwise.

Legal Issues Addressed

Application of the General Aviation Revitalization Act of 1994 (GARA)

Application: GARA's statute of repose, which limits aircraft manufacturers' liability to eighteen years post-delivery, was applied to bar the wrongful death claims against Raytheon, as the crash occurred more than eighteen years after the aircraft's manufacture.

Reasoning: The district court granted summary judgment in favor of Raytheon, ruling that the plaintiffs' claims were barred by the eighteen-year statute of repose established by the General Aviation Revitalization Act of 1994 (GARA).

Federal Diversity Jurisdiction

Application: Jurisdiction was established under federal diversity jurisdiction due to the parties' citizenship differences and the controversy exceeding $75,000.

Reasoning: Jurisdiction is established under federal diversity jurisdiction, with appellants being Macedonian citizens and Raytheon a Kansas corporation, involving a controversy exceeding $75,000.

Presumption Against Extraterritoriality

Application: The court found that the presumption against extraterritoriality did not apply to GARA, as it governs the ability to seek compensation from manufacturers in U.S. courts and does not regulate conduct abroad.

Reasoning: Consequently, the presumption against extraterritoriality is not applicable to the General Aviation Revitalization Act (GARA), as it solely governs the ability to seek compensation from general aviation aircraft manufacturers in U.S. courts and does not regulate conduct occurring abroad.

Summary Judgment Review

Application: The court reviewed the district court's summary judgment de novo, focusing on the proper application of substantive law and interpretation of federal statutes.

Reasoning: The court reviews the district court's summary judgment de novo, focusing on the proper application of substantive law and the interpretation of federal statutes.