Robinson Helicopter Company, Inc. v. Mirna McAuliffe, Individually and as Co-Personal Representative of the Estate of Ryan McAuliffe, Deceased, et al.

The General Aviation Revitalization Act of 1994 (GARA) provides that “no civil action for damages for death or injury *** arising out of an accident involving a general aviation aircraft may be brought against the manufacturer” more than 18 years after the manufacturer delivers the aircraft to its first purchaser. 49 U.S.C. 40101 note, § 2(a)(1). If a “new” part is added to or replaces an original part and later is “alleged to have caused” the accident, then an eighteen-year clock runs from the date of the replacement or addition. Id. § 2(a)(2). GARA “supersedes any State law to the extent that such law permits a civil action described in subsection (a) to be brought after the applicable limitation period for such civil action.” Id. § 2(d). Petitioner is the manufacturer of a general aviation aircraft, as defined by GARA, which was delivered to its first purchaser in 2000 and was involved in an accident in 2019. Prior to the accident, certain aspects of the main rotor system were replaced with identical parts. Respondents filed state-law design-defect claims against petitioner, alleging that the original design of the main rotor system of the general aviation aircraft sold in 2000 was defective and caused the 2019 accident. The question here is whether mere replacement of original parts with parts that are identical to the parts they replaced is sufficient to trigger a new rolling repose period under GARA.