Knight v. Avco Corporation
4:21-cv-00702
| M.D. Penn. | Sep 18, 2025Background
- On May 4, 2019, a helicopter crashed in Chesapeake Bay, Maryland, killing pilots Charles Knight II and Matthew Clarke; both decedents and the plaintiffs (their spouses) are Maryland domiciliaries and the flight occurred entirely in Maryland.
- Plaintiffs allege Avco (through its Lycoming Engines division in Williamsport, Pennsylvania) defectively designed/manufactured the O-360-J2A engine, causing exhaust-valve coking, loss of compression, and engine failure; Avco contends pilot negligencye caused the crash.
- The engine was manufactured and certified in Pennsylvania, sold abroad, then ultimately installed on a helicopter operated in Maryland by a Maryland LLC for training/rental flights.
- Plaintiffs assert strict liability, negligence, and breach of warranties seeking compensatory and punitive damages; Avco moved to apply Maryland law on contributory negligence, damages cap, and punitive-damage proof standard.
- The Court conducted a Pennsylvania choice-of-law analysis (Klaxon rule) and applied issue-specific depecage: it concluded Maryland law applies to contributory negligence, while Pennsylvania law applies to compensatory damages cap and punitive-damages proof.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Applicable rule for plaintiff fault (comparative vs. contributory) | Pennsylvania comparative negligence should apply, allowing recovery unless >50% at fault | Maryland contributory negligence should apply (any plaintiff fault bars recovery) | Maryland contributory-negligence rule applies to liability issues |
| Cap on compensatory (non-economic) damages | Maryland cap should not apply; Pennsylvania uncapped regime should govern | Avco urges Maryland statutory cap to limit exposure | Pennsylvania uncapped compensatory-damages law applies |
| Standard/proof for punitive damages | Pennsylvania preponderance standard governs punitive awards | Maryland clear-and-convincing and actual-malice standards should control | Pennsylvania preponderance standard for punitive damages applies |
| Use of Maryland internal choice-of-law statute (Md. Cts. & Jud. Proc. §3-903(a)) / renvoi | Plaintiffs argued Maryland statute indicates Maryland law should defer to other states' law; urged renvoi | Avco opposed applying Maryland internal choice rule here | Court declined to apply renvoi or Maryland internal choice provisions; treated Maryland statute as irrelevant to Pennsylvania choice-of-law analysis |
Key Cases Cited
- Klaxon Co. v. Stentor Elec. Mfg. Co., 313 U.S. 487 (federal courts apply forum state choice-of-law rules)
- Coleman v. Soccer Ass’n of Columbia, 69 A.3d 1149 (Md. 2013) (reaffirming Maryland contributory-negligence doctrine)
- Owens-Illinois, Inc. v. Zenobia, 601 A.2d 633 (Md. 1992) (discussing purposes and limitations of punitive damages in Maryland)
- Murray v. Janssen Pharmaceuticals, Inc., 180 A.3d 1235 (Pa. Super. Ct. 2018) (discussing conflicts between Maryland and Pennsylvania damages law in pharmaceutical context)
- Shuder v. McDonald’s Corp., 859 F.2d 266 (3d Cir. 1988) (Pennsylvania interest in plaintiff-protecting comparative negligence)
- Sprague v. Walter, 656 A.2d 890 (Pa. Super. Ct. 1995) (Pennsylvania punitive-damages standard and definition of "outrageous" conduct)