Boyle v. United Technologies Corp
Citation and Court
Boyle v. United Technologies Corp., 487 U.S. 500 (1988). United States Supreme Court.
Facts
Marine Lieutenant David Boyle died when the military helicopter he was flying crashed and he could not escape because the escape hatch opened in the wrong direction. His father sued Sikorsky (a division of United Technologies), the helicopter’s manufacturer, asserting a state tort law claim for defective design. Sikorsky raised the government contractor defense, arguing that the hatch was built to military specifications. The district court entered judgment for Sikorsky; the Fourth Circuit affirmed.
Issue
Whether federal common law recognizes a government contractor defense that preempts state tort liability when a defense contractor manufactures equipment to government specifications.
Holding
The Supreme Court held five-to-four that federal common law does provide a government contractor defense that displaces state tort law under the stated conditions. The conflict between state tort liability and the procurement of military equipment presents a “significant conflict” with federal interests sufficient to warrant displacement of state law.
Rule / Doctrine
The government contractor defense displaces state tort law when: (1) the United States approved reasonably precise specifications for the challenged equipment; (2) the equipment conformed to those specifications; and (3) the contractor warned the United States of known dangers in the equipment that the government did not know about. The defense rests on the federal interest in the military procurement of equipment free from state-by-state tort liability variation.
Significance
Boyle is the leading case on displacement of state law by federal common law in the absence of a federal statute directly on point. It demonstrates that “significant conflict” with a uniquely federal interest — here, military procurement — can justify creation of federal common law that preempts state law. The decision is controversial because it extends federal protection to private defense contractors.