## Facts

- A Navy instructor pilot died after being inadvertently ejected from a T-34C aircraft when the pilot restraint system (PRS) released without command during a training maneuver.
- The PRS was manufactured by a contractor and installed pursuant to Navy-approved specifications for the Navy trainer aircraft.
- A Navy investigation identified a possible cause as contact between the aircraft control stick grip and the rotary buckle that releases the restraint belts.
- During the aircraft’s development, the Navy conducted multiple test phases, identified PRS deficiencies, and required corrective action.
- The Navy issued detailed specifications, drawings, and test requirements for the PRS and retained authority to approve or reject design changes after iterative design work.
- The decedent’s representative sued the PRS manufacturer and related aircraft entities under state products-liability theories, alleging defective design and related claims, including failure to warn.
- The district court granted summary judgment for defendants on the ground that the government-contractor defense barred the claims, and the plaintiff appealed.

## Issues

1. Whether the defendants satisfied the Boyle government-contractor defense elements so that state-law design-defect liability for the PRS was displaced by federal common law.
2. Whether the defense also barred failure-to-warn and other post-delivery theories based on alleged duties to provide additional warnings or safety information.
3. Whether any genuine dispute of material fact precluded summary judgment on the Boyle elements.

## Decision

- The Fifth Circuit affirmed summary judgment for all defendants.
- The court held that the Navy approved reasonably precise PRS specifications through active, detailed involvement in testing and design approval.
- The court held the record showed the PRS conformed to Navy-approved specifications and there was no evidence of deviation.
- The court held there was no evidence defendants failed to warn the Navy of risks known to defendants but not to the Navy, given the Navy’s own testing, investigations, and awareness of the hazard.
- The court held the defense could apply to failure-to-warn/post-delivery claims where the Navy controlled relevant warnings, manuals, training, and safety communications, and state duties would conflict with federal procurement and military decision-making.

## Legal Principles

- State-law liability for design defects in military equipment is displaced when: (1) the United States approved reasonably precise specifications; (2) the equipment conformed to those specifications; and (3) the contractor warned the United States of dangers known to the contractor but not to the United States.
- “Approval” requires meaningful governmental review and decision-making; detailed specifications developed through government testing and iterative design evaluation satisfy the first element.
- The second element is met when the product, as delivered and installed, matches the government’s approved drawings/specifications and acceptance processes show compliance.
- The third element turns on comparative knowledge: absent proof the contractor withheld unique risk information, the element is satisfied when the government already knew of the relevant hazard.
- The defense may extend to failure-to-warn and related theories when the government exercises control over warnings or information provided to end users and imposing state duties would create a significant conflict with federal interests.

## Conclusion

The Fifth Circuit held that the Navy’s detailed control over the PRS design and related communications, the absence of evidence of nonconformity, and the lack of proof that defendants possessed undisclosed safety knowledge required application of the Boyle government-contractor defense, barring both design-defect and failure-to-warn claims.


Kerstetter v. Pac. Sci. Co., 210 F.3d 431 (5th Cir. 2000)