Larry Crouch v. Honeywell International, Inc.
2013 U.S. App. LEXIS 9650
6th Cir.2013Background
- Plane crash in Kentucky (Nov 21, 2006) injured pilot and passenger; magneto detachment allegedly caused engine power loss.
- Engine manufactured in 1978 by Lycoming Engines (AVCO); rebuilt magneto installed in 2005 by Jewell Aircraft per Lycoming overhaul manual.
- Plaintiffs (Crouches) sued multiple defendants, including AVCO, for negligent design, manufacture, and failure to warn/notify about defects.
- AVCO moved for summary judgment under GARA; engine age exceeded 18-year repose; district court limited scope and later reconsidered.
- District court found AVCO acted as a manufacturer due to mandatory manuals; held GARA barred suit; denial of leave to amend and new evidence addressed later on appeal.
- Appeal focused on GARA capacity and whether revised overhaul manual restarted the repose period or if misrepresentation/withholding exceptions apply; court affirmed denial of relief and upheld district court judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| GARA applicability to AVCO as manufacturer vs publisher | Crouches argue AVCO published manuals as publisher, not manufacturer | AVCO argues manuals are integral to manufacturing duties; suit falls under manufacturer protection | AVCO acted as manufacturer; GARA applies |
| Whether revised overhaul manual constituted a replacement part restarting GARA | Manual revisions should restart 18-year repose as a new part | Revision not a replacement part; not causally linked to crash | Revision did not constitute a replacement part triggering a new repose period |
| Whether § 2(b)(1) knowing misrepresentation/withholding exception applies | Evidence shows AVCO allegedly withheld information to FAA | Initial complaint insufficiently pleaded specifics; post-judgment amendment improper | § 2(b)(1) not satisfied; denial of amendment upheld; no abuse of discretion |
| Whether district court abused in denying leave to amend post-judgment | New evidence and proposed amendment should be allowed | Finality and need for compelling justification for late amendment | No abuse of discretion; denial affirmed |
| Whether discovery limitations affected GARA analysis | Limited discovery prejudiced response to time-bar defense | Discovery period appropriate; GARA dispositive irrespective of discovery scope | Not reversible error; summary judgment affirmed |
Key Cases Cited
- Caldwell v. Enstrom Helicopter Corp., 230 F.3d 1155 (9th Cir. 2000) (whether a flight manual can be a replacement part under GARA)
- Alter v. Bell Helicopter Textron, Inc., 944 F. Supp. 531 (S.D. Tex. 1996) (maintenance manual not a replacement part under GARA § 2(a)(2))
- Mason v. Schweizer Aircraft Corp., 653 N.W.2d 543 (Iowa 2002) (publication of maintenance manual as manufacturer duty under GARA)
- Colgan Air, Inc. v. Raytheon Aircraft Co., 507 F.3d 270 (4th Cir. 2007) (overhaul/maintenance manual not a part of the aircraft for GARA analysis)
- Inmon v. Air Tractor, Inc., 74 So.3d 534 (Fla. Dist. Ct. App. 2011) (modification vs replacement; no new repose without substantive change)