## Facts

- Fred Hoffman and co-owners possessed a 1939 Piper Cub aircraft and performed some maintenance themselves.
- After damage during a landing attempt, Hoffman hired Simplot Aviation, Inc. to repair the aircraft, including landing-gear work and an inspection.
- Simplot employees performed the repairs and a visual inspection near the left wing assembly, including an area involving a clevis bolt.
- An employee left a note stating the aircraft was safe for “one takeoff and landing,” and Hoffman confirmed that assurance by phone.
- Hoffman attempted to fly the aircraft from a farm strip toward Simplot’s facility.
- During flight, a clevis bolt in the left wing assembly failed; the left wing collapsed and the aircraft crashed, injuring Hoffman, his wife, and Hoffman’s partner and damaging the aircraft.
- Plaintiffs claimed the bolt was rusted/defective and that a proper inspection should have обнаружed and corrected the condition; defendants disputed that any defect was apparent.

## Issues

1. Whether strict liability in tort for defective products extends to a provider of repair/inspection services.
2. Whether an implied-warranty theory applies to repair services, and whether the jury must be instructed to connect any implied obligation to fault and to defenses such as contributory negligence.
3. Whether special verdicts finding equal negligence yet awarding recovery on implied warranty (while rejecting strict liability and express warranty) were so inconsistent that judgment could not stand.

## Decision

- The Idaho Supreme Court reversed the judgment for plaintiffs and remanded for a new trial.
- The court declined to extend strict liability in tort to the provision of personal repair/inspection services.
- The court held that the implied-warranty instructions were erroneous in a service context because they risked treating implied warranty as a no-fault guarantee, untethered from breach of a duty of care.
- The court concluded that the special verdicts reflected confusion or contradiction, reinforced by improper instructions, requiring a new trial.

## Legal Principles

- Strict liability in tort, as developed for defective products placed into commerce, does not automatically apply to pure service transactions such as repair and inspection work.
- Any implied obligation arising from a service contract is fault-based: the service provider is expected to perform with reasonable care and skill, and liability must be tied to a breach of that duty.
- Where negligence and implied-warranty concepts overlap in service cases, jury instructions must clearly define the elements and explain how contributory negligence affects recovery.
- A judgment cannot stand where special verdicts are internally inconsistent in a way that indicates the jury likely misunderstood the governing legal standards.

## Conclusion

The court rejected strict liability for aircraft repair services and ordered a new trial because the implied-warranty instructions improperly suggested no-fault liability and the special verdicts were inconsistent with the jury’s negligence findings.


Hoffman v. Simplot Aviation, Inc., 97 Idaho 32, 539 P.2d 584 (Idaho 1975)