## Facts

- Chad M. Koppie claimed he acquired title in 1987 to a Convair 880 aircraft (originally worth about $10 million) for $5,000 from Hudson General Corporation after Hudson enforced a lien for storage and maintenance charges.
- Koppie’s purported ownership was subject to a recorded interest held by Cromwell State Bank, which later assigned its interest to an entity called the “880 Partnership.”
- The 880 Partnership resold the aircraft to Ligon “Air,” and both the 880 Partnership and Ligon Air were controlled by the same two individuals.
- Koppie applied to the FAA for a Certificate of Aircraft Registration in his name; the FAA denied the request by letter dated June 23, 1987, citing conflicting ownership claims reflected in its records.
- In mid-1987, Koppie observed a person he believed was associated with Ligon Air working on the aircraft, reinforcing that Ligon Air continued to assert control.
- Koppie later signed a document releasing his ownership claims to the aircraft, but subsequently asserted the release had been nullified.
- Koppie sued Ligon Air (state-law claims under diversity) and the United States under the FTCA, alleging the FAA wrongfully refused to register the aircraft to him and instead recognized or issued registration favoring Ligon Air, causing $667,000 in damages.
- The district court entered judgment for both defendants, and Koppie appealed.

## Issues

1. Whether Koppie proved a superior ownership interest in the aircraft (and resulting entitlement to damages) against Ligon Air in light of recorded interests and subsequent transfers.
2. Whether the United States could be liable under the FTCA for the FAA’s denial of Koppie’s registration application and related registration record decisions amid conflicting ownership claims.

## Decision

- The Seventh Circuit affirmed the district court’s judgment for Ligon Air and the United States.
- The court held Koppie failed to establish a superior ownership interest or a viable basis for damages against Ligon Air given the recorded chain of interests and transfers.
- The court held Koppie’s FTCA claim failed because the FAA’s registration actions in response to conflicting documentation did not constitute a cognizable state-law tort basis for FTCA liability and were barred to the extent they involved protected governmental decision-making.
- The court found Koppie’s claimed damages and causal theory unpersuasive on the record presented, including the effect of his signed release.

## Legal Principles

- A purchaser who acquires property subject to recorded liens or interests bears the risk that those interests and later assignments may defeat the purchaser’s asserted title.
- FAA aircraft registration processing based on conflicting ownership documentation does not, without a cognizable analogous private-party duty under state tort law, create liability against the United States under the FTCA.
- FTCA claims are unavailable where the complained-of agency conduct falls within statutory limits on waiver of sovereign immunity, including protection for discretionary governmental functions.
- A claimant must show a legally recognized duty, breach, and proximate causation of damages; skepticism about causation and the effect of a signed release may defeat asserted ownership-based loss claims.

## Conclusion

The Seventh Circuit affirmed judgment for both defendants because Koppie did not prove superior title or damages against Ligon Air, and he could not convert the FAA’s registration decisions amid disputed ownership into actionable liability against the United States under the FTCA.


Koppie v. United States, 1 F.3d 651 (7th Cir. 1993)