## Facts

- Alaskan Oil retained a broker to locate a used aircraft and, through the broker, agreed to buy a 1970 Beechcraft airplane owned by G.W. Davis Construction Company.
- Central Flying had possession of the aircraft, had performed repair and storage work for Davis, and facilitated the sale to Alaskan Oil.
- The sale closed on March 3, 1987 for $65,000; Central Flying kept $53,000 from the sale proceeds to satisfy Davis’s repair and storage debt.
- After purchase, Alaskan Oil encountered significant mechanical and structural problems, including replacement of both engines, the fuel cell, and de-icing boots, and discovery of extensive corrosion.
- A detailed inspection in March 1988 concluded the aircraft was so corroded that repair was not economically feasible; Alaskan Oil sold the plane for salvage and sought to recover its losses.

## Issues

1. Whether Arkansas strict products liability permits recovery when the only claimed damages are economic losses to the product itself.
2. Whether the evidence was sufficient to support a finding that the aircraft was defective and unreasonably dangerous at the time of sale.
3. Whether Central Flying, acting as a selling intermediary with possession and financial involvement in the transaction, qualified as a statutory “supplier” subject to strict liability under Arkansas law.

## Decision

- The Eighth Circuit affirmed the judgment for Alaskan Oil on strict liability.
- The court held Arkansas allows strict-liability recovery even when damages are limited to the product itself.
- The court held the evidence supported the jury’s finding that the aircraft was defective and unreasonably dangerous when sold.
- The court held Central Flying fit within Arkansas’s definition of a “supplier” and could be held strictly liable.
- The damages award of $54,500 and the jury’s allocation of 80% responsibility to Central Flying were left undisturbed.

## Legal Principles

- Under Arkansas law, strict products liability may be available even when the plaintiff’s loss is confined to damage to the product itself (a minority approach rejected in many jurisdictions).
- On appellate review of a jury verdict, evidence is viewed in the light most favorable to the verdict; reversal for insufficiency is improper where a reasonable jury could find defect and unreasonable danger at the time of sale.
- Arkansas products-liability statutes define “supplier” broadly to include entities that play a meaningful role in placing a product into the stream of commerce, including intermediaries who possess, market, transfer, and profit from the sale.

## Conclusion

The court upheld a strict-liability judgment for a defective aircraft despite the buyer’s losses being limited to the aircraft itself, and it treated the intermediary that possessed and brokered the sale while retaining sale proceeds as a statutory supplier subject to strict liability under Arkansas law.


Alaskan Oil, Inc. v. Central Flying Serv., Inc., 975 F.2d 553 (8th Cir. 1992)