Facts of the Case

Following the death of US Marine helicopter pilot David A. Boyle, Delbert Boyle sued the helicopter's manufacturer ("Sikorsky") for defectively designing its copilot emergency escape hatch. On appeal from a state-law based jury verdict favoring Boyle, the Court of Appeals found that Sikorsky could not be held liable under Virginia tort law for any design flaws since it met the requirements of the "military contractor defense." Boyle appealed; the Supreme Court granted certiorari.

Question

Are state tort laws, holding independent military contractors liable for injuries caused by their design flaws, valid?

Conclusion

No. In a 5-to4 decision, the Court held that despite the absence of specific legislation immunizing government contractors from liability for design flaws, questions of their liability are of unique federal concern. As such, to the extent that it holds military contractors liable for design flaws, state law may significantly conflict with federal interests thereby requiring its displacement. The Court added that in the instant case, such displacement is appropriate since the United States approved the helicopter's specifications, the equipment met those specifications, and Sikorsky warned the government of possible dangers in the helicopter's use. Finally, since the Court of Appeals' use of the "military contractor defense" failed to specify if a reasonable jury could have found for Boyle, the Court vacated its judgment and remanded.