Nachtsheim v. Beech Aircraft Corp.

William Steil, the president of Production Tool Corporation (plaintiff), died when a private plane he was piloting crashed. There had been reports of ice in the area where the plane went down. The plane was manufactured by Beech Aircraft Corporation (Beech) (defendant). Production and Edward Nachtsheim (plaintiff), who was representing Steil’s estate, sued Beech for products liability, arguing that Beech’s design of the plane made it unsafe for flying in ice. Beech argued that the crash was caused by pilot error. The plaintiffs sought to introduce evidence of a crash of another Beech airplane of the same design. This plane had crashed near St. Anne, Illinois, approximately one year after Steil’s plane crashed. Similarities between the crashes included the type of airplane, the pilots’ certification levels, and icy weather conditions at the time of the crashes. Differences included the altitudes of the planes when control was lost, the fact that the St. Anne pilot had a record of piloting issues, the fact that the St. Anne pilot had radioed a problem with his autopilot function, the fact that the amount of time the St. Anne plane had been picking up ice could not be determined, and the angle of the planes relative to the ground when they crashed. The district court weighed the evidence under Federal Rule of Evidence 403 (Rule 403) and ultimately excluded evidence of the St. Anne crash. The jury returned a verdict in favor of Beech. The plaintiffs appealed.