Beech Aircraft Corp. v. Rainey case brief

Beech Aircraft Corp. v. Rainey case brief

488 U.S. 153, 109 S. Ct. 439, 102 L. Ed. 2d 445, 1988 U.S.

CASE SYNOPSIS: Plaintiff surviving spouses brought an action against defendant manufacturer and defendant service company, seeking damages arising from an aircraft crash. The trial court (United States) entered judgment, upon a jury verdict, in favor of the manufacturer and the service company. On review, the United States Court of Appeals for the Eleventh Circuit reversed and remanded for a new trial. On rehearing en banc, the panel's judgment was reinstated.

FACTS: After the crash of a military plane, the surviving spouses brought their product liability suit against the manufacturer and the service company, which serviced the plane under contract with the Navy. The surviving spouses alleged that the crash had been caused by a loss of engine power due to a defect in the aircraft's fuel control system. The manufacturer and the service company advanced the theory of pilot error. At trial, portions of an investigatory report pointing to pilot error were admitted into evidence. The jury returned a verdict for the manufacturer and the service company.

ANALYSIS: A panel of the court of appeals reversed and remanded for a new trial because Fed. R. Evid. 803(8)(C) did not encompass evaluative conclusions or opinions, and thus, the conclusions contained in the investigatory report should have been excluded. On rehearing en banc, the court of appeals divided evenly on the question of R. 803(8)(C). On further review, the Court reversed and remanded in part because the trial court determined that certain of the report's conclusions were trustworthy and the trial court rightly allowed them to be admitted into evidence.

CONCLUSION: The Court reversed that part of the court of appeals' decision, which held that certain conclusions within an investigatory report should have been excluded at trial. The Court affirmed that part of the court of appeals' decision, which held that the trial court erred in refusing to permit the testifying surviving spouse to present a more complete picture his own investigation of the crash.

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