Jarmuth v. Aldridge

Kenneth Aldridge, through his business KWA Leasing, Inc. (KWA) (defendants), owned a private vintage aircraft known as a Vultee. Aldridge hired an aircraft mechanic licensed by the Federal Aviation Administration (FAA) to look at a possible fuel problem with the Vultee. The mechanic discovered a problem with the carburetor and, with Aldridge’s approval, sent the carburetor to an outside company to be overhauled. The mechanic then reinstalled the repaired carburetor, conducted the annual inspection for the Vultee, and certified the Vultee as airworthy. A few days later, Michael Garofalo was piloting the Vultee with a passenger when the carburetor float malfunctioned. The Vultee crashed, killing both occupants. As the administrator of Garofalo’s estate, Jeffrey Jarmuth (plaintiff) sued Aldridge and KWA. Jarmuth claimed that (1) as the Vultee’s owners, Aldridge and KWA had a duty to personally inspect the Vultee to determine its airworthiness, (2) Aldridge and KWA had negligently failed to fulfill this duty, and (3) this negligence was the cause of the crash and Garofalo’s death. Aldridge and KWA moved for summary judgment, arguing that having an FAA-certified mechanic inspect the aircraft had fulfilled their duty to ensure that the Vultee was airworthy. The district court found that the owner of a private aircraft could rely on a mechanic’s finding of airworthiness and dismissed Jarmuth’s negligence claim. Jarmuth appealed.