The appeal arises from a fatal helicopter sightseeing crash in Kailua, Hawai‘i, that killed Ryan McAuliffe. The helicopter’s main rotor hub and blades were replaced with identical serialized components from Robinson in 2018, slightly more than eighteen years after the original aircraft was delivered.
The McAuliffes sued Robinson, arguing that GARA’s rolling provision restarted the eighteen-year repose period because the crash was allegedly caused by the newly replaced rotor system.
The district court had granted summary judgment for Robinson, requiring the McAuliffes to show that the replacement parts were substantively altered from the original design. The Ninth Circuit held this interpretation was legal error, noting that GARA’s text applies to any "new component... which replaced another" part without imposing a substantive alteration requirement.
Because the district court’s misinterpretation permeated its causation analysis, the panel remanded for the lower court to address whether the McAuliffes provided sufficient evidence that the replaced hub or blades were the proximate cause of the accident.
The panel also affirmed summary judgment on the fraud exception, concluding that the McAuliffes failed to make particularized allegations or offer evidence that Robinson knowingly misrepresented material information to the Federal Aviation Administration.
Finally, the court held that the district court did not abuse its discretion in denying leave to amend the complaint, finding the McAuliffes had not been diligent in pursuing their claim over two and a half years.