The Minnesota Supreme Court has now spoken, bringing to an end the litigation against Cirrus for its alleged failure to train pilot Gary Prokop.
Prokop flew his new Cirrus SR22 into conditions of poor visibility and crashed, killing himself and his passenger. The passenger’s family sued Cirrus, as will as Prokop’s estate, claiming that Cirrus didn’t properly train Prokop on the use of the plane’s autopilot. The wrinkle is that Cirrus had agreed by contract to provide the pilot a full course of training but, when the time came, Cirrus skipped the lesson on using the autopilot to exit bad weather.
A jury awarded more than $10 million to the families of the pilot and passenger. The jury felt that, had Cirrus provided the contracted-for training, the accident wouldn’t have happened.
The Minnesota Court of Appeal reversed. It ruled that Minnesota law permits no claim for injuries suffered as a result of "educational malpractice" and, when you boil it all down, "educational malpractice" was exactly what plaintiffs were claiming. A dissenting judge reasoned that plaintiffs were not claiming that the training was in error, but rather that it wasn’t provided at all. Thus, Minnesota’s bar to "educational malpractice" claims shouldn’t apply.
The Minnesota Supreme Court agreed to review the case. In its decision, handed down just yesterday, the Supreme Court more or less agreed with the dissenting appellate court judge that the case didn’t involve the educational malpractice doctrine. Rather, the Supreme Court felt that the case was really a traditional products liability case. Nonetheless, it ruled for Cirrus.
The Supreme Court reasoned as follows:
- The Cirrus aircraft is a dangerous product;
- Therefore, Cirrus was required to provide instructions on how properly to use the aircraft, including the autopilot, to avoid injury;
- Cirrus provided such instructions in its manuals and other written materials;
- No one argues that the written materials were wrong or otherwise inadequate; and
- The fact that Cirrus failed to provide flight training on the use of the autopilot is irrelevant.
Case closed. In short, the Court ruled that while a manufacture has a duty to warn the user about the dangers of a product and how to avoid injury, it does not have a duty to train the user. Finally, the Court ruled that, even if Cirrus had agreed to train the pilot, the failure to do what it agreed allows for only contract damages, not wrongful death damages. While damages for breach of contract are inadequate and ill-suited for cases involving personal injury, the Supreme Court ruled that only contract damages were available under the circumstances.
A dissenting judge disagreed:
a party should not be "immunized[d]. . .from tort liability for his wrongful acts" just because those acts "grow out of" or are "coincident" to a a contract .. .If the mere presence of a contract foreclosed all tort liability, medical malpractice claims would cease to exist. A passenger injured in a car accident while riding in a taxi cab would have only a breach of contract claim against he cab driver and cab company. A paid babysitter who failed to prevent injury to a child would be liable only in contract. . . "