Hart v. American Airlines, Inc. case brief
Posture: Plaintiff wins, the summary judgment is granted. It is offensive issue preclusion via another state.
Facts: There was a crash in Kentucky on Nov 8 1965; It was an American Airlines plane while plane was en route from NY to Kentucky. Crash resulted in death of 58 out of 62 people and many actions were instituted in other states and various U.S. district courts.
The first action was brought in Texas and plaintiffs won it. The case n Texas had the same exact issues of the airlines liability in regard to the negligence. The result was affirmed on appeal so now plaintiffs in other states are moving for summary judgment based on the Texas decision and hoping to get it binding on their own suit. Plaintiffs were not parties in that first Texas action, however their claim is that the liability of the airline was already decided and under collateral estoppel, the case is over.
Reasoning: To have the doctrine of collateral esoppel apply, there must be an identity of an issue that was already decided plus a full and fair opportunity to contest the decision so now the decision is controlling. Which are met here.
The burden shifts to defendant that it did not have a fair opportunity to contest at the 19 day trial its liability, otherwise full faith and credit applies. The court also denies that it matters that Kentucky has a less favorable defendant law because NY courts would still apply Kentucky law under choice of law. The other fact that Texas requires mutuality (all parties the same) while NY does not, and NY ignores that to stop the chance that a different outcome could occur.