McAuliffe v. Robinson Helicopter Company

── McAuliffe v. Robinson Helicopter Company ── Court: Court of Appeals for the Ninth Circuit Date: April 21, 2026 Category: General FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT MIRNA MCAULIFFE; THOMAS No. 24-6086 MCAULIFFE, Individually and as D.C. No. Co-Personal Representatives of the 1:21-cv-00193- Estate of Ryan McAuliffe, deceased, HG-WRP Plaintiffs - Appellants, v. OPINION ROBINSON HELICOPTER COMPANY, Defendant - Appellee. Appeal from the United States District Court for the District of Hawaii Helen W. Gillmor, District Judge, Presiding Argued and Submitted October 8, 2025 Submission Vacated November 6, 2025 Resubmitted April 14, 2026 Honolulu, Hawaii Filed April 21, 2026 Before: M. Margaret McKeown, Michelle T. Friedland, and Jennifer Sung, Circuit Judges. 2 MCAULIFFE V. ROBINSON HELICOPTER CO. Opinion by Judge McKeown; Partial Dissent by Judge Friedland SUMMARY* General Aviation Revitalization Act of 1994 The panel affirmed in part and reversed in part the district court’s summary judgment in favor of Robinson Helicopter Company in plaintiffs’ suit arising out of a helicopter sightseeing crash that killed their daughter, and remanded. The General Aviation Revitalization Act of 1994 (“GARA”) bars wrongful death actions against general aviation aircraft manufacturers commenced more than eighteen years after the aircraft has been delivered to the first purchaser. The helicopter’s main rotor hub and main rotor blades—the main culprits in the crash—were replaced with identical parts from Robinson in 2018, slightly more than eighteen years after Robinson manufactured the original helicopter. GARA Section 2(a)(2) (the “rolling provision”) restarts the eighteen-year repose period for newly replaced parts. GARA Section 2(b)(1) (the “fraud exception”) eliminates the repose period where the manufacturer has knowingly misrepresented, concealed, or withheld required * This summary constitutes no part of the opinion of the court. It has been prepared by court staff for the convenience of the reader.  MCAULIFFE V. ROBINSON HELICOPTER CO. 3 and material information from the Federal Aviation Administration. The panel held that the district court erred in requiring plaintiffs to show that the main rotor hub and main rotor blades had been substantively altered from the original parts in order to get the benefit of the rolling provision. The statute does not require substantive alteration. Because the district court’s misinterpretation permeated its causation analysis, the panel remanded for the court to address causation anew. The panel held that the district court did not err in concluding that plaintiffs failed to make particularized allegations or offer evidence that would permit them to benefit from the fraud exception. Finally, the panel held that the district court did not abuse its discretion in denying plaintiffs leave to amend their complaint. Dissenting in part, Judge Friedland joined the majority in concluding that plaintiffs failed to offer evidence of fraud and that the district court did not abuse its discretion in denying plaintiffs’ motion to amend their complaint. However, this court has previously interpreted GARA to require that a replacement part have a material alteration before the statute of repose can restart. Because there was no material alteration in the replaced parts here, she would affirm the district court’s summary judgment in favor of Robinson Helicopter Company. 4 MCAULIFFE V. ROBINSON HELICOPTER CO. COUNSEL Thomas G. Siracusa (argued) and Joseph A. Power Jr., Power Rogers LLP