COUSINS v. SIKORSKY AIRCRAFT CORPORATION

CourtDistrict Court, E.D. Pennsylvania
DecidedMarch 26, 2025
Docket2:23-cv-02629
StatusUnknown

This text of COUSINS v. SIKORSKY AIRCRAFT CORPORATION (COUSINS v. SIKORSKY AIRCRAFT CORPORATION) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
COUSINS v. SIKORSKY AIRCRAFT CORPORATION, (E.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

JOANNE COUSINS, on behalf of the : CIVIL ACTION ESTATE OF MATTHEW COUSINS and : on behalf of his DOHSA beneficiaries, : TANYA COWBROUGH, on behalf of the : ESTATE OF ABBIGAIL COWBROUGH : and on behalf of her DOHSA : beneficiaries, KYLE HAGEN, on behalf : of the ESTATE OF KEVIN HAGEN and : his DOHSA beneficiaries, AMANDA : MacDONALD, on behalf of the ESTATE : OF BRENDEN IAN MacDONALD, and on : behalf of his DOHSA beneficiaries, : KATHRYN BOWEN, on behalf of the Est. : of Maxime Miron-Morin and on behalf : of his DOHSA beneficiaries, and : MICHAEL CUSTANCE, on behalf of the : ESTATE OF MATTHEW PYKE, and on : behalf of his DOHSA beneficiaries : : v. : : SIKORSKY AIRCRAFT COFRPORATION : doing business as Sikorsky, a : Lockheed Martin Company, : HELICOPTER SUPPORT, INC., doing : business as Helicopter Support, Inc., a : Lockheed Martin Company and : SIKORSKY INTERNATIONAL : OPERATIONS, INC., doing business as : Sikorsky International Operations, a : Lockheed Martin Company : NO. 23-2629

MEMORANDUM OPINION Savage, J. March 26, 2025 Defendant Sikorsky Aircraft Corporation lost its forum non conveniens bid to dismiss this case and allow plaintiffs to file a new action in Nova Scotia, Canada. Now it seeks to transfer the case to the District of Connecticut where its headquarters are located. Because Sikorsky has not demonstrated that the convenience of the parties and the witnesses outweighs the plaintiffs’ choice of forum, we shall deny the motion. Background The factual background of this products liability and wrongful death action is detailed in our Memorandum Opinion ruling on the forum non conveniens motion.1 We do not reiterate those facts. In summary, the action arises out of the crash of a CH-148

helicopter manufactured and designed by Sikorsky for the Canadian military in the Ionian Sea off the coast of Greece, killing the plaintiffs’ decedents. Plaintiffs allege the crash was caused by a defectively designed fly-by-wire Electronic Flight Control System (EFCS) which overrode the pilot’s manual commands while he was performing a maneuver.2 Plaintiffs, administrators of the decedents’ estates who reside in Canada, filed this action in the Eastern District of Pennsylvania, where Sikorsky had a facility in Coatesville it had dubbed as the “Home of the CH-148.”3 During the two years the fateful helicopter was at the Coatesville facility, Sikorsky installed final software upgrades, conducted final flight testing, and delivered the helicopter to the Canadian military.4 Sikorsky has since closed its Coatesville facility.5

Sikorsky moved to dismiss this action on forum non conveniens grounds, arguing that the case should be litigated in Canada where the plaintiffs reside and evidence in

1 Cousins on behalf of Est. of Cousins v. Sikorsky Aircraft Corp., -- F. Supp. 3d --, Civ. No. 23-2629, 2024 WL 4429061 (E.D. Pa. Sept. 30, 2024). 2 Compl. ¶¶ 2–4, 15–16, ECF No. 1. 3 Id. ¶ 8. 4 Decl. of Roger D. Lange in Supp. of Sikorsky’s Mot. to Dismiss ¶¶ 9–11 (attached as Ex. B to Defs.’ Mem. of L. in Supp. of Their Mot. for Transfer of Venue, ECF No. 47-1 [“Sikorsky’s Br.”]), ECF No. 47-3 [“First Lange Decl.”]. 5 Id. ¶ 13. possession of the Canadian military is located.6 We denied Sikorsky’s motion, concluding that the difficulties of litigating in the United States would not cause oppression and vexation out of all proportion to the plaintiffs’ convenience and did not override the plaintiffs’ choice of forum.7 Sikorsky now moves, pursuant to 28 U.S.C. § 1404(a), to transfer venue to the

District of Connecticut, where it has its principal place of business.8 It argues that that district would best serve the convenience of the parties and witnesses, and the interests of justice. Sikorsky submits the declaration of Roger Lange, a Sikorsky engineer who states that the CH-148 and the EFCS were designed in Sikorsky’s Connecticut facility.9 He claims that although nonparties BAE Systems in New York and the Canadian Department of National Defense (DND) participated in the CH-148’s design and development, Sikorsky maintained control over the work from its Connecticut headquarters.10 All Sikorsky employees who liaised with BAE and the DND did so from Connecticut.11 He

states that no design activities took place in Pennsylvania, and no current or former Sikorsky employees who participated in the CH-148’s design are located in

6 Defs.’ Mem. of L. in Supp. of Their Mot. to Dismiss Pursuant to Forum Non Conveniens 1–2, ECF No. 16-1 [“Sikorsky’s FNC Br.”]. 7 Cousins, 2024 WL 4429061, at *18. 8 Sikorsky’s Br. 1–2; Compl. ¶ 39. 9 Decl. of Roger D. Lange in Supp. of Sikorsky’s Mot. to Transfer Venue ¶¶ 5–10, 15–16 (attached as Ex. A to Sikorsky’s Br.), ECF No. 47-3 [“Second Lange Decl.”]. 10 Id. ¶¶ 15–17. 11 Id. ¶¶ 10, 17. Pennsylvania.12 Sikorsky argues that because plaintiffs’ allegations focus on the design of the CH- 148 and the EFCS, all US-based liability evidence is located in Connecticut where Sikorsky designs its aircraft products. It contends that because plaintiffs sued in a venue that is neither their home nor the place where the claim arose, their choice of forum is

entitled to little deference. Plaintiffs counter that Pennsylvania has significant ties to the litigation, justifying their choice of forum. They argue that Sikorsky has not demonstrated the unavailability of Connecticut-based nonparty witnesses, and that there are a number of nonparty witnesses located in Pennsylvania. In short, they contend Sikorsky has not demonstrated sufficient inconvenience or injustice to override their choice of forum. Analysis The standard governing a motion for transfer under Section 1404(a) is distinct from that governing a forum non conveniens motion. Dahl v. United Techs. Corp., 632 F.2d 1027, 1029 n.1 (3d Cir. 1980). A district court has broader discretion in applying Section

1404(a) than it does in applying the forum non conveniens doctrine. Piper Aircraft Co. v. Reyno, 454 U.S. 235, 253 (1981) (citing Norwood v. Kirkpatrick, 349 U.S. 29, 75 (1955)). A defendant moving for transfer of venue must show that (1) the case could have been brought in the proposed transferee forum; (2) the proposed forum will be more convenient for the parties and the witnesses; and (3) transfer will be in the interest of justice. 28 U.S.C. § 1404(a); In re McGraw-Hill Glob. Educ. Holdings LLC, 909 F.3d 48,

12 Id. ¶¶ 19–20. 57 (3d Cir. 2018) (citing Jumara v. State Farm Ins. Co., 55 F.3d 873, 879–80 (3d Cir. 1995)). This action could have been brought in the District of Connecticut. Sikorsky has its headquarters there. See 28 U.S.C. § 1391(b)(1), (c). So, we must consider the convenience of the parties and the witnesses (the private interests) and the interests of

justice (the public interests). If these considerations favor transfer, we may transfer the case. In re Howmedica Osteonics Corp, 867 F.3d 390, 401–02 (3d Cir. 2017) (citing Atl. Marine Const. Co. v. U.S. Dist. Ct. for W. Dist. of Tex., 571 U.S. 49, 62 & n.6 (2013); Jumara, 55 F.3d at 879).

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