## Facts

- Roy Leiske piloted a Cessna 421 owned and operated by Monarch Aviation Services (Monarch), a Wisconsin corporation.
- On April 29, 1996, Leiske flew passengers (including Andrew Schoeberle) from Milwaukee, Wisconsin, to Cedar Rapids, Iowa, intending to return to Milwaukee.
- The aircraft experienced mechanical trouble en route to Cedar Rapids.
- At the Cedar Rapids airport, Signature Flight Support Corporation (Signature) performed maintenance on the aircraft.
- After the maintenance, Signature and Leiske concluded the aircraft was airworthy, and the flight departed Cedar Rapids for Milwaukee.
- The aircraft’s problems continued after takeoff.
- While the aircraft was in airspace controlled by the Chicago Air Route Traffic Control Center, Federal Aviation Administration (FAA) air-traffic controllers directed the flight.
- Leiske proposed landing at the Monticello, Iowa airport (about 6.5 miles away), but controllers instructed him not to land there, stating it was not properly equipped for the aircraft, and instead directed him toward another airport about 18 miles away.
- The Monticello airport was, in fact, equipped for the aircraft, and the aircraft likely could have reached it safely absent the controllers’ mistake.
- The aircraft crashed in Iowa after traveling about 7.5 miles, killing the pilot and all passengers.
- All decedents and survivors were Wisconsin residents.
- The Leiske plaintiffs sued the United States under the Federal Tort Claims Act (FTCA) for alleged air-traffic-control negligence and asserted state-law negligence claims against Signature.
- The Schoeberle plaintiffs also asserted state-law claims against Monarch and the Leiske estate, and the parties sought rulings on which state’s law governed liability and damages.

## Issues

1. Under the FTCA, which state’s law governs the Leiske plaintiffs’ liability claim against the United States for alleged negligence by FAA controllers located at the Chicago Air Route Traffic Control Center?
2. Under Illinois choice-of-law rules, which state’s law governs liability claims against Signature, Monarch, and the Leiske estate arising from the maintenance, flight decisions, and crash?
3. Which state’s law governs compensatory damages for the wrongful-death and related claims asserted against the United States and the private defendants?
4. Which state’s law governs punitive damages sought by the Schoeberle plaintiffs against Signature, Monarch, and the Leiske estate?
5. May different states’ laws apply to different issues (liability vs. damages) and different parties within the same set of consolidated claims?

## Decision

- Illinois law governed the Leiske plaintiffs’ FTCA liability claim against the United States.
- Iowa law governed plaintiffs’ liability claims against Signature, Monarch, and the Leiske estate.
- Wisconsin law governed plaintiffs’ compensatory damages claims against all defendants (the United States, Signature, Monarch, and the Leiske estate).
- Iowa law governed punitive damages for the Schoeberle plaintiffs’ claims against Signature, Monarch, and the Leiske estate.
- The court granted in part and denied in part the parties’ competing choice-of-law requests by applying different states’ laws to different issues and parties.

## Legal Principles

- Under the FTCA, the United States’ liability is determined “in accordance with the law of the place where the act or omission occurred,” and the referenced “law” includes that state’s conflicts rules.
- For non-FTCA state-law claims in federal court, the court applies the forum state’s choice-of-law rules.
- Illinois choice-of-law analysis for torts uses a contacts-and-interests approach (often described in terms of the most significant relationship) rather than a single mechanical rule.
- Illinois choice-of-law analysis can treat liability, compensatory damages, and punitive damages as separate questions, allowing different governing laws for different issues.
- In multistate wrongful-death disputes, a common domicile of decedents and survivors can supply a strong basis for applying that state’s law to compensatory damages.
- Because punitive damages focus on punishment and deterrence, the place of injury and closely related conduct may have a strong regulatory interest in the punitive-damages rule.
- Applying different states’ laws to different issues and parties in one case is permissible when supported by the forum’s conflicts methodology.

## Conclusion

In this consolidated aviation-wrongful-death litigation, the court issued issue-specific choice-of-law rulings: Illinois law governed FTCA liability against the United States because the alleged controller negligence occurred in Illinois; Iowa law governed liability and punitive-damages issues for the private defendants tied to the Iowa-centered crash and conduct; and Wisconsin law governed compensatory damages for all defendants because all decedents and survivors were Wisconsin residents.


Schoeberle v. U.S., 2000 WL 186130 (2000)