Powers v. Lycoming Engines
272 F.R.D. 414
E.D. Pa.2011Background
- Two consolidated putative nationwide class actions challenge Lycoming Engines' liability and damages related to allegedly defective crankshafts in Lycoming engines.
- Plaintiffs seek certification under Rule 23(b)(3) to represent owners or former owners of aircraft with Lycoming engines; class includes 49 states and D.C. with a two-subclass structure by current ownership.
- Lycoming defends against class certification, arguing non-common liability and damages, non-typical claims, and predominance/manageability issues due to state-law variations.
- Choice-of-law disputes center on whether Pennsylvania law applies or whether application of Pennsylvania law would violate due process and full faith and credit, given numerous contracting states.
- The court applies the state of purchase as the governing law for the implied warranty claim, finds real conflicts among states, and ultimately Denies nationwide class certification.
- The court also concludes predominance and superiority under Rule 23(b)(3) are not satisfied due to numerous state-law differences, notices, defenses, and damages, making nationwide certification inappropriate.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Choice-of-law conflict exists? | Plaintiffs contend there is a real conflict among states with different privity rules and warranty law. | Lycoming asserts state-by-state differences undermine a single governing law for the class. | Yes, there is a real conflict requiring further analysis. |
| Most significant relationship applies to implied warranty? | Purchases occur across many states; purchase state should govern. | Pennsylvania policy favors its own law due to Lycoming’s location and corporate structure. | Purchase states collectively have the more significant relationship; apply the law of the state of purchase. |
| Does the conflict-of-laws analysis offend due process/Full Faith and Credit? | Applying purchase-state law respects states with direct interests in their residents. | Pennsylvania has insufficient aggregation of contacts to apply its law to all class members. | Application of Pennsylvania law would violate due process and full faith and credit; Pennsylvania law not applicable to all class members. |
| Do common questions predominate under Rule 23(b)(3)? | Common liability and damages predominate because all class members face similar issues. | Varied state warranties, defenses, and notice requirements require individualized inquiries. | Predominance not satisfied; individualized inquiries would predominate. |
| Is class action superiority appropriate? | Class treatment would be efficient and uniform. | Managing a nationwide class with divergent state laws is impractical and would fail superiority. | Superiority not satisfied; class action not superior to other methods. |
Key Cases Cited
- Berg Chilling Sys., Inc. v. Hull Corp., 435 F.3d 455 (3d Cir. 2006) (conflict of laws resolved via Restatement methods)
- Hammersmith v. TIG Ins. Co., 480 F.3d 220 (3d Cir. 2007) (flexible interest balancing in conflict-of-laws analysis)
- LeJeune v. Bliss-Salem, Inc., 85 F.3d 1069 (3d Cir. 1996) ( Restatement §188 significant relationship framework)
- Specialty Surfaces Int’l, Inc. v. Continental Cas. Co., 609 F.3d 223 (3d Cir. 2010) (balance of governmental interests in choice-of-law)
- In re Bridgestone/Firestone, Inc. Tires Prods. Liab. Litig., 288 F.3d 1012 (7th Cir. 2002) (manageability and choice-of-law in large-scale class actions)
- In re Hydrogen Peroxide Antitrust Litig., 552 F.3d 305 (3d Cir. 2008) (predominance standard in class actions)
- Amchem Prods., Inc. v. Windsor, 521 U.S. 591 (U.S. 1997) (extensive class-action certification requirements)