Richards v. United States

An American Airlines (AA) plane crashed in Missouri while traveling from Oklahoma to New York. All passengers died in the crash. Richards and other surviving family members of the deceased passengers (Richards) (plaintiffs) received a $15,000 settlement from AA, which was the maximum amount recoverable under Missouri law. Thereafter, Richards filed a wrongful-death suit in federal district court in Oklahoma against the Federal Aviation Administration (FAA) (defendant). Richards asserted liability under the Federal Tort Claims Act (FTCA), claiming the FAA negligently failed to enforce federal laws and regulations concerning maintenance and repair of AA aircraft at the FAA’s Tulsa, Oklahoma, location. The parties agreed that the negligence occurred in Oklahoma and the injury occurred in Missouri. Oklahoma did not have a maximum recoverable amount for wrongful death. The district court concluded that if Oklahoma law applied to Richards’s FTCA claim, then the entirety of Oklahoma law applied too, including the state’s conflict-of-laws principles. Because Oklahoma law provided that wrongful-death actions are governed by the law of the state in which the death occurred, the district court applied Missouri law to the action. The district court dismissed the complaint because the AA settlement gave each plaintiff the maximum amount recoverable under Missouri law. Richards appealed. The court of appeals affirmed, and the United States Supreme Court granted certiorari.