Pearson v. Northeast Airlines, Inc.

On August 15, 1958, John Pearson died in the crash of a Northeast Airlines, Inc. (Northeast) (defendant) airplane near Nantucket, Massachusetts. John, a resident of New York, purchased his ticket at Northeast’s New York office. The plane took off from La Guardia Airport in New York City. Northeast was a Massachusetts corporation. Marilyn Pearson (plaintiff), John’s widow and administratrix, primary heir of John’s estate, and a New York resident, filed a wrongful-death suit against Northeast in the United States District Court for the Southern District of New York. The district court, relying on a New York Court of Appeals decision involving the same accident but a different plaintiff (Kilberg v. Northeast Airlines, Inc., 172 N.E.2d 526 (N.Y. 1961)), applied Massachusettes’s wrongful-death statute but refused to enforce the $15,000 limit on recovery included in that statute. [Editor’s Note: The New York Court of Appeals is New York’s highest state court.] The jury awarded damages well over the Massachusetts limit. On appeal, the United States Court of Appeals for the Second Circuit held that the district court’s failure to include the $15,000 limit was a violation of the Full Faith and Credit Clause of the United States Constitution, given that the action was based on the Massachusetts statute. Finding that the issue was significant because of the ongoing development of New York conflict-of-laws rules, the appellate court granted Marilyn’s application for a hearing en banc.