DAE Aviation v. Old Republic Ins.

2012 DNH 152
CourtDistrict Court, D. New Hampshire
DecidedAugust 31, 2012
Docket11-cv-554-LM
StatusPublished

This text of 2012 DNH 152 (DAE Aviation v. Old Republic Ins.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
DAE Aviation v. Old Republic Ins., 2012 DNH 152 (D.N.H. 2012).

Opinion

DAE Aviation v . Old Republic Ins. 11-cv-554-LM Insurance UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

DAE Aviation Enterprises, Corp. d/b/a Emerson Aviation

v. Civil N o . 11-cv-554-LM Opinion N o . 2012 DNH 152 Old Republic Insurance Company; Phoenix Aviation Managers, Inc.; Nationair Insurance Agencies, Inc.; and Tracy N . Cardelli, Individually, and as Personal Representative of the Estate of Stephen D. Cardelli, J r .

O R D E R

In an action that has been removed from the New Hampshire

Superior Court, DAE Aviation Enterprises, Corp. (“DAE”)

petitions for a declaratory judgment concerning the extent of

its coverage under an insurance policy sold to it by Nationair

Insurance Agencies, Inc. (“Nationair”), issued by Old Republic

Insurance Company (“Old Republic”), and underwritten by Phoenix

Aviation Managers, Inc. (“Phoenix”). 1 Before the court are

motions for summary judgment filed by: (1) Tracy Cardelli

(“Cardelli”), whose claim against DAE brought DAE’s insurance

policy into play; (2) DAE; and (3) Old Republic and Phoenix 1 DAE’s petition also includes, as Count I I , a “contingent damages claim” in negligence against Nationair. As the court understands DAE’s pleading, Count II will spring to life if the court declares that DAE’s policy affords less coverage than was required by the airport at which DAE operated its business. (referred to collectively as “the insurers”). All three motions

are duly opposed. For the reasons that follow, each of the

three motions is granted in part and denied in part.

Summary Judgment Standard

“To prevail on summary judgment, the moving party must show

that ‘there is no genuine dispute as to any material fact and

the movant is entitled to judgment as a matter of law.’” Markel

Am. Ins. C o . v . Díaz-Santiago, 674 F.3d 2 1 , 29 (1st Cir. 2012)

(quoting Fed. R. Civ. P. 56(a)). Where, as here, the court is

presented with cross motions for summary judgment, the summary-

judgment standard is applied to each motion separately. See Am.

Home Assur. C o . v . AGM Marine Contrs., Inc., 467 F.3d 8 1 0 , 812

(1st Cir. 2006) (citing Reich v . John Alden Life Ins. Co., 126

F.3d 1 , 6 (1st Cir. 1997)). In other words, “[t]he presence of

cross-motions for summary judgment neither dilutes nor distorts

[the] standard of review.” Mandel v . Boston Phoenix, Inc., 456

F.3d 1 9 8 , 205 (1st Cir. 2006).

Background

Stephen Cardelli (“Mr. Cardelli”) died on June 1 3 , 2009,

when the plane he was piloting lost power and crashed just after

take-off, about a mile from the Laconia Municipal Airport

(“Laconia Airport”). The power loss resulted from a leak that

caused the plane’s engine to lose virtually all of its oil.

2 Shortly before the crash, M r . Cardelli had gotten the plane back

from DAE. DAE is a “fixed-base operator,” or FBO which

provides, among other things, aircraft maintenance at Laconia

Airport. Prior to M r . Cardelli’s crash, DAE had performed an

annual inspection of his plane that included an oil and filter

change. DAE also performed some other repair work, including a

windshield replacement.

The windshield was replaced on June 1 2 . At that time, a

DAE mechanic told M r . Cardelli that the plane would not be

available until late in the afternoon of June 1 3 , because the

material used to seal the windshield needed twenty-four hours to

cure, and it was necessary for the sealant to cure before DAE

could perform an engine run-up. A run-up is required after any

oil change, and had a run-up been performed, the mechanic

performing it would have detected the oil leak that caused M r .

Cardelli’s plane to crash.

On June 1 3 , M r . Cardelli went to pick up the plane,

arriving before the end of the twenty-four cure period for the

windshield sealant. When a DAE employee was unable to tell M r .

Cardelli where the plane was, M r . Cardelli went into a hanger

and found i t . He also went into an office and took the plane’s

log books, which contained entries indicating that all the work

on the plane, including a run-up, had been completed. Mr.

Cardelli then had a low-level DAE employee get the plane out of

3 the hangar for him. Thereafter, he taxied away, leaking oil

onto the runway, and took off on his fatal flight.

Mr. Cardelli’s surviving spouse, who is also the personal

representative of his estate, has sued DAE in the United States

District Court for the District of Maine. Among her claims is

one for negligence against DAE. Specifically, she asserts that

DAE breached its duty of care by: (1) gouging the oil-cooler

return hose and fracturing the oil-cooler return-line-attach

nipple; (2) failing to perform the required run-up; (3)

releasing the plane to M r . Cardelli before performing the run-

u p ; (4) failing to take steps, such as taping the plane’s doors

and fuselage, to indicate that the plane had not been made

airworthy; and (5) violating various federal regulations

governing aircraft service and inspection.

DAE’s operations at Laconia Airport were governed by an FBO

Operating Contract between DAE and the Laconia Airport Authority

(“LAA”). Article VI of that contract required DAE to carry

commercial general liability insurance and to provide the LAA

with a Certificate of Insurance “naming the LAA, the City of

Laconia, the Town of Gilford, and the County of Belknap as

Additional Insureds hereunder.” Resp’t’s Mot. Summ. J., Ex. D

(doc. n o . 3 7 - 3 ) , at 3 . Article VI further provides:

The coverage available to the LAA, the City of Laconia, the Town of Gilford, and the County of Belknap as Additional Insured, shall not be less than

4 a $2,000,000 Smooth Limit with respect to Premises- Operations . . . provided that such coverage is commercially available; a $2,000,000 Smooth Limit with respect to Products-Completed Operations arising out of the servicing or sale of fuel, oil and other petroleum products, provided that such coverage is commercially available; and a $1,000,000 Per Occurrence limit with a $100,000 Per Person Bodily Injury Sub-Limit with respect to all other Products- completed Operation exposure (i.e. Repair & Service, Pilot Supplies, Food & Beverage Sales, e t c . ) , provided that such coverage is commercially available. Smooth Limit is defined as a distinct limit of liability coverage per occurrence with no sub-limit for bodily injury to any person.

Id. Article VI also gave the LAA the discretion to require DAE

to maintain commercial umbrella liability insurance with a

coverage limit of at least $1 million per occurrence. See id.

There is no indication that the LAA ever required DAE to obtain

or maintain an umbrella policy.

At the time of M r . Cardelli’s fatal accident, DAE was

covered by a policy of airport liability insurance that was

issued by Old Republic and underwritten by Phoenix. The

policy’s “Comprehensive General Liability Insurance – Coverage

Part” recites that the “policy provides coverage to owners,

landlords and tenants of property and operations located on the

premises designated in the declarations of this policy as an

airport including all operations necessary and incidental

thereto.” Resp’t’s Mot. Summ. J., Ex. E (doc. n o . 3 7 - 4 ) , at 3 6 .

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