Boyle v. United Technologies Corporation

PETITIONER: Delbert Boyle, Personal Representative of the heirs and Estate of David A. Boyle, Deceased
RESPONDENT: United Technologies Corporation
LOCATION: Chelsea, Michigan

DOCKET NO.: 86-492
DECIDED BY: Rehnquist Court (1988-1990)
LOWER COURT: United States Court of Appeals for the Fourth Circuit

CITATION: 487 US 500 (1988)
ARGUED: Oct 13, 1987
REARGUED: Apr 27, 1988
DECIDED: Jun 27, 1988

Donald B. Ayer - for the United States as amicus curiae by special leave of the Court urging affirmance
Louis Stanton Franecke - for the petitioner
Philip A. Lacovara - for the respondent

Facts of the case

Following the death of US Marine helicopter pilot David A. Boyle, Delbert Boyle sued the helicopter's manufacturer ("Sikorsky") for defectively designing its copilot emergency escape hatch. On appeal from a state-law based jury verdict favoring Boyle, the Court of Appeals found that Sikorsky could not be held liable under Virginia tort law for any design flaws since it met the requirements of the "military contractor defense." Boyle appealed; the Supreme Court granted certiorari.


Are state tort laws, holding independent military contractors liable for injuries caused by their design flaws, valid?

Media for Boyle v. United Technologies Corporation

Audio Transcription for Oral Argument - October 13, 1987 in Boyle v. United Technologies Corporation

Audio Transcription for Opinion Announcement - June 27, 1988 in Boyle v. United Technologies Corporation

William H. Rehnquist:

The opinions of the Court in three cases, No. 86-492, Boyle against United Technologies Corporation, No. 86-995, Murray against Carter and a companion case, and No. 86-1512, Pierce against Underwood will be announced by Justice Scalia.

Antonin Scalia:

The first of this, Boyle versus United Technologies Corporation comes to us by writ of certiorari to the United States Court of Appeals for the First Circuit.

David Boyle, a United States Marine helicopter pilot, drowned when his helicopter crashed off the coast of Virginia during a training exercise.

Petitioner, the representative of Boyle's estate, brought this suit in District Court alleging, under Virginia law, that respondents, Sikorsky Division of United Technologies, manufacturer of the helicopter, had defectively designed the emergency escape hatch system.

The jury returned a general verdict in favor of petitioner and awarded him $725,000.

The Court of Appeals reversed holding that Sikorsky could not be held liable for the allegedly defective design because it had satisfied the requirements of what the Court referred to as the military contractor defense.

We granted certiorari to decide whether such defense exists as a matter of federal law and its proper scope.

We reject petitioner's broadest contention that there is no justification in federal law for shielding government contractors from liability for design defects in military equipment.

We have in the past recognized that in a few areas involving uniquely federal interests, state law is preempted and replaced where necessary by federal law even in the absence of an explicit statutory directive so providing.

We hold today that the procurement of equipment by the United States is an area of uniquely federal interests and that a suit such as the present one directly implicates that interest.

Still, as we have said in the past, state law will be displaced in a situation such as this only where it significantly conflicts with the federal interest.

We think such a conflict exist where state tort law seeks to impose a duty contrary to that established by a federal procurement contract and where the design specified in that contract represents the type of governmental judgment that Congress sought to immunize through the discretionary function exemption to the Federal Tort Claims Act.

We further hold that the selection of the appropriate design for military equipment is the type of discretionary function that will require the displacement of state law.

Petitioner also challenges the scope of the defense recognized by the Court of Appeals.

We hold today that liability for design defects in military equipment cannot be imposed pursuant to state law when, (1), the United States approved reasonably precise specifications, (2), the equipment conformed to those specifications, and (3), the supplier warned the United States about the dangers and the use of the equipment that were known to the supplier but not known to the United States.

Finally, petitioner claims that the Court of Appeals erred in not remanding for a jury trial on the basis of the elements of the defense announced in its decision.

Because we find the Court of Appeals' opinion somewhat unclear regarding whether it believe that the elements of the defense were established as a matter of law, we remand for clarification on this point.

Justice Brennan has filed a dissenting opinion in which Justices Marshall and Blackmun joined.

Justice Stevens has also filed a dissenting opinion.