## Facts

- A U.S. Marine Corps helicopter copilot drowned after a training crash off the Virginia coast when he could not escape through the copilot emergency exit hatch of a CH-53D helicopter.
- The decedent’s estate sued the helicopter manufacturer (Sikorsky, a division of United Technologies Corporation) under Virginia tort law, alleging defective design of the emergency escape-hatch system.
- The case was brought in federal court under diversity jurisdiction.
- A jury returned a general verdict for the plaintiff, and the district court denied the manufacturer’s post-verdict motion for judgment as a matter of law.
- The Fourth Circuit reversed and directed entry of judgment for the manufacturer based on a federal “military contractor defense.”
- The Supreme Court granted review to determine whether, and under what conditions, federal law displaces state design-defect liability for military contractors.

## Issues

1. Whether federal common law may displace state tort law to shield military equipment contractors from design-defect liability absent specific federal legislation.
2. What elements must be shown for a federal government-contractor defense to preempt state-law design-defect claims involving military equipment.

## Decision

- The Court held that federal common law may preempt state tort law in areas of uniquely federal interests, including procurement of military equipment.
- The Court held that displacement occurs only when state law significantly conflicts with an identifiable federal policy or interest.
- The Court adopted a three-part government-contractor defense for military design-defect claims: (1) the United States approved reasonably precise specifications; (2) the equipment conformed to those specifications; and (3) the supplier warned the United States about dangers known to the supplier but not to the United States.
- The Court vacated the Fourth Circuit’s judgment and remanded for further proceedings under the Court’s three-part standard.

## Legal Principles

- Federal common law can preempt state law when a dispute implicates uniquely federal interests and there is a significant conflict between state law and federal policy.
- Military procurement is a uniquely federal interest, and state tort duties that would effectively second-guess discretionary governmental design choices can conflict with federal policy.
- The FTCA discretionary function exception provides a reference point for identifying conflicts where judicial review of policy-based governmental design decisions is barred.
- Government approval must be substantive; mere governmental acceptance without meaningful review is insufficient to satisfy the “reasonably precise specifications” requirement.
- When the three elements are met, the challenged design is treated as effectively governmental, and state design-defect liability is displaced to the extent it conflicts with that federal interest.

## Conclusion

The Court established that state-law design-defect claims against military contractors may be preempted by a federal common-law government-contractor defense when the government approved reasonably precise specifications, the equipment conformed to them, and the contractor disclosed known, undisclosed hazards to the government.


Boyle v. United Techs. Corp., 487 U.S. 500 (1988)