Bell Helicopter Textron, Inc. v. Arteaga
113 A.3d 1045
| Del. | 2015Background
- On Oct. 15, 2010 a Bell-manufactured helicopter registered to and operated by a Mexican company crashed in Mexico, killing nine Mexican citizens. Mexican authorities found a defective inboard strap fitting to be the cause.
- The helicopter and the particular fitting were designed and manufactured in Texas; Bell Helicopter is a Delaware corporation with principal operations in Texas.
- Plaintiffs (Mexican citizens, representatives of decedents) sued Bell in Delaware Superior Court and asked the court to apply Texas law to liability and damages; Bell moved to apply Mexican law and earlier sought dismissal on forum non conveniens.
- The Superior Court applied the Restatement (Second) most‑significant‑relationship test and ruled Texas law governed (giving weight to place of manufacture and Bell’s Texas connections); Bell appealed interlocutorily.
- The Delaware Supreme Court reversed, holding that under the Restatement contacts and §6 principles Mexico has the most significant relationship for liability, damages, and remedies and that the situs of injury (Mexico) is not fortuitous.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Which sovereign’s substantive law (liability, damages, remedies) governs tort claims arising from the crash? | Arteaga: Texas law should apply (plaintiffs asked for Texas law on liability/damages). | Bell: Mexican law governs because crash, victims, operator, and aircraft registration are all Mexican. | Reversed Superior Court: Mexican law governs — Mexico has the most significant relationship. |
| Does the Restatement presumption favoring law of the place of injury get rebutted as "fortuitous" here? | Plaintiffs: crash site is fortuitous because specific Veracruz locale had limited ties to victims. | Bell: place of injury is not fortuitous — victims lived/worked in Mexico and flight was domestic. | Held: situs is not fortuitous; presumption for Mexican law stands. |
| Is the place of manufacture (Texas) dispositive under the §145 contacts and §6 principles? | Plaintiffs: manufacturing in Texas and Bell’s Texas HQ give Texas a dominant interest. | Bell: place of manufacture is a less significant contact; focus should be where product was used and victims resided (Mexico). | Held: place of manufacture is insufficient to overcome the presumption favoring Mexico; policy and comity concerns favor Mexico. |
| Should ease of applying English/Texas law (no translators) tip choice‑of‑law towards Texas? | Plaintiffs: practical ease and plaintiffs’ preference for Texas law justify applying Texas law in Delaware. | Bell: logistical convenience cannot override neutral Restatement analysis and comity. | Held: linguistic/practical convenience is a weak §6 factor and cannot defeat the Restatement analysis favoring Mexico. |
Key Cases Cited
- Martinez v. E.I. DuPont de Nemours & Co., 86 A.3d 1102 (Del. 2014) (forum non conveniens decision emphasizing deference to situs law when injury-producing conduct occurred abroad)
- Ison v. E.I. DuPont de Nemours & Co., 729 A.2d 832 (Del. 1999) (discussing fortuitous situs and limits on treating foreign situs as fortuitous when victims are domiciliaries there)
- Travelers Indem. Co. v. Lake, 594 A.2d 38 (Del. 1991) (describing Delaware’s use of Restatement contacts and qualitative analysis for choice of law)
- SIGA Tech., Inc. v. PharmAthene, Inc., 67 A.3d 330 (Del. 2013) (standard of review for de novo review of legal issues)
- McLennan v. Am. Eurocopter Corp., 245 F.3d 403 (5th Cir. 2001) (recognizing Texas’s strong interest in applying its law to manufacturers domiciled or operating in Texas in cross‑border aviation product cases)