Boyle v. United States Technologies Corp.

Brief Fact Summary.

Petitioner sued Respondent for a design defect in the helicopter it built for the United States.

Synopsis of Rule of Law.

In cases involving uniquely federal interests, federal law controls over state law.

Facts.

United States Marine David A. Boyle died in a helicopter crash. Boyle’s father (Petitioner) brought a lawsuit against the United States contractor that built the helicopter, Sikorsky Division of the United Technologies Corporation (Respondent), in federal court under diversity jurisdiction. Petitioner argued that under state tort law Respondent was liable for a design defect in the helicopter.

Issue.

May a federal contractor use federal law as a defense in a state tort law claim?

Held.

Yes, federal law is applicable in civil liabilities against government contractors. The case is reversed and remanded to determine whether a reasonable jury could find for Petitioner under the appropriate federal law.

Dissent.

Justice Brennan

Justice Brennan argued that this government contractor defense must be established by Congress and not the courts. He also argued that the repercussions would be great because the defense was too broad.

Justice Stevens

Justice Sevens argued that the Court should have deferred to Congress.

Discussion.

The Court determined that civil liabilities arising out of the performance of federal procurement contracts are uniquely federal concerns. The Court further determined that application of state tort law to the facts of the case would significantly conflict with this federal interest. This was because the United States approved the helicopter’s specifications, the equipment met those specifications, and Respondent warned the government of possible dangers in the helicopter’s use. Thus, the Court concluded that federal law providing government contractors with protection from liability was applicable in this case.