Boyle v. United Technologies Corp.
487 U.S. 500 (1988)
Rule of Law:
Federal common law provides that a contractor for the United States military is not liable under state tort law for design defects in equipment if the government approved reasonably precise specifications, the equipment conformed to those specifications, and the contractor warned the government of dangers it knew of but the government did not.
Facts:
- On April 27, 1983, David A. Boyle, a U.S. Marine helicopter copilot, was participating in a training exercise.
- The CH-53D helicopter he was co-piloting, which was built by Sikorsky for the United States, crashed off the coast of Virginia Beach, Virginia.
- Boyle survived the impact of the crash but was unable to escape the submerged helicopter and drowned.
- The helicopter's emergency escape hatch was designed to open outward, rendering it ineffective against water pressure when submerged.
- Access to the escape hatch handle was also obstructed by other equipment within the cockpit.
- Sikorsky had built the helicopter, including the escape hatch system, in accordance with the design specifications provided and approved by the U.S. Navy.
Procedural Posture:
- David Boyle's father filed a diversity action against Sikorsky in the U.S. District Court.
- A jury returned a general verdict in favor of the petitioner, awarding him $725,000.
- The District Court denied Sikorsky's motion for judgment notwithstanding the verdict.
- Sikorsky, as appellant, appealed to the U.S. Court of Appeals for the Fourth Circuit.
- The Court of Appeals reversed the judgment, finding that Sikorsky was protected by the 'military contractor defense' as a matter of federal law.
- Boyle's father, as petitioner, was granted a writ of certiorari by the U.S. Supreme Court.
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Issue:
Does federal common law shield a government contractor from liability under state tort law for a design defect in military equipment when the contractor manufactured the equipment in accordance with specifications approved by the U.S. Government?
Opinions:
Majority - Justice Scalia
Yes, federal common law shields a government contractor from liability under state tort law for design defects in military equipment under certain conditions. The procurement of military equipment by the United States is an area of uniquely federal interest where the imposition of state tort law can create a 'significant conflict' with federal policy. This conflict arises from the 'discretionary function' exception to the Federal Tort Claims Act (FTCA), which insulates the government from liability for discretionary judgments, such as balancing safety and combat effectiveness in military equipment design. Permitting state tort suits against contractors for government-approved designs would effectively pass the financial burden to the government and allow 'second-guessing' of military decisions, undermining the policy of the FTCA exception. Therefore, state law is displaced when a contractor can prove the elements of the government contractor defense.
Dissenting - Justice Brennan
No, federal common law should not shield a government contractor from liability. The Court is engaging in judicial lawmaking by creating a broad immunity that Congress has explicitly chosen not to enact. This case is a dispute between private parties that does not directly implicate the rights and obligations of the United States, and any financial effect on the U.S. Treasury is too remote to justify displacing state tort law. The majority's reliance on the FTCA's discretionary function exception is misplaced because the statute is not directly applicable to a private contractor, and federal common law should not be created from the policy of an inapplicable statute. The Court's ruling creates an injustice by denying compensation to victims of a contractor's negligence.
Dissenting - Justice Stevens
No, the Court should not create this new legal doctrine. The task of balancing the competing policy interests of efficient government procurement and the protection of individual rights properly belongs to the legislative branch, not the judiciary. When faced with creating an entirely new doctrine to answer questions of policy on which Congress has not spoken, the Court should defer to the expertise of Congress. The Court is overstepping its bounds by legislating from the bench.
Analysis:
This landmark decision establishes the 'government contractor defense,' also known as the 'Boyle defense,' as a form of federal common law that preempts state product liability law. It significantly insulates military contractors from liability for design defects, provided they were acting in accordance with government specifications. The case solidifies the principle that where a 'significant conflict' exists between state law and a 'uniquely federal interest' like military procurement, federal law prevails. This ruling has had a profound impact, making it substantially more difficult for service members and civilians to sue contractors for injuries caused by military equipment, and it places the ultimate responsibility for design choices on the discretionary judgment of the government.
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