Executive Jet Aviation, Inc. v. United States

507 F.2d 508, 19 Fed. R. Serv. 2d 1274, 1974 U.S. App. LEXIS 5671
CourtCourt of Appeals for the Sixth Circuit
DecidedDecember 12, 1974
Docket74-1243
StatusPublished
Cited by104 cases

This text of 507 F.2d 508 (Executive Jet Aviation, Inc. v. United States) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Executive Jet Aviation, Inc. v. United States, 507 F.2d 508, 19 Fed. R. Serv. 2d 1274, 1974 U.S. App. LEXIS 5671 (6th Cir. 1974).

Opinion

PHILLIPS, Chief Judge.

Executive Jet Aviation, Inc., and Executive Jet Sales, Inc., brought this action against the United States under the Federal Tort Claims Act, 28 U.S.C. §§ 1346(b), 2401(b), 2671-2680. The District Court dismissed the complaint, holding that Executive Jet is not the real party in interest and that lack of jurisdiction prevents joinder of Executive Jet’s insurers, who are the real parties in interest. Executive Jet appeals from this dismissal. For the reasons stated below, we reverse and remand for further proceedings.

On July 28, 1968, one of Executive Jet’s aircraft crashed on takeoff from the Cleveland, Ohio, airport after its engines had ingested a large number of seagulls that had been roosting on the runway. 1 The plane was covered by a $1,300,000 policy of aircraft hull insurance issued by a group of British insurance companies. On October 17, 1968, Executive Jet received $1,300,000 from the insurers pursuant to a typical loan receipt agreement, under which Executive Jet was obligated to make repayment only out of any net recovery it might obtain from those liable for the crash. In addition, the agreement required that Executive Jet stand ready to institute suit in its own name for the purpose of effecting such a recovery. The insurers, however, were to bear the expense and to assume direction and control of any such litigation.

By letter dated May 6, 1969, Executive Jet submitted to the Federal Aviation Administration a written claim in the *511 amount of $1,763,643.64. 2 The letter’ made no reference to the insurers or to the loan receipt agreement.

On May 12, 1969, Executive Jet filed a complaint against the United States in the action out of which this appeal arises, alleging negligence on the part of the FAA air traffic controllers in not warning of the presence of seagulls on the runway and praying for $1,763,643.64 in damages. In an answer filed July 24, 1969, the Government raised several issues, including the defense that Executive Jet was not the real party in interest.

In an unreported opinion rendered on November 2, 1973, the District Court looked to the law of Ohio as stated in Cleveland Paint & Color Co. v. Bauer Manufacturing Co., 155 Ohio St. 17, 97 N.E.2d 545 (1951), and concluded that the loan receipt arrangement was a mere fiction that would not avoid subrogation. Thus the insurers, rather than Executive Jet, were held to be the real parties in interest. The court noted in passing that even if federal law were to control the effect of the loan receipt, the same result would be achieved under what the court considered the better federal rule announced in City Stores Co. v. Lerner Shops, Inc., 133 U.S.App.D.C. 311, 410 F.2d 1010 (1969). Further, the District Court held that because the insurers had not filed an administrative claim within two years of the accident as required by 28 U.S.C. § 2401(b), the insurers could not be joined as plaintiffs. Therefore, the court dismissed the complaint with prejudice, and Executive Jet perfected this appeal.

I

In the view that we take of this case, we need not decide whether the effect of the loan receipt arrangement is governed by state or federal law. It is conceded that under the law of Ohio payment pursuant to a loan receipt is considered outright payment and does not avoid subrogation of the insurer. Cleveland Paint & Color Co. v. Bauer Mfg. Co., supra, 155 Ohio St. 17, 97 N.E.2d 545 (1951). In our opinion the federal courts should follow the same rule. Thus we would reach the same result on the subrogation issue regardless of whether we apply the State law of Ohio or federal law.

Executive Jet insists that the federal practice has been to respect the form of loan receipts and to find no subrogation *512 when this device is employed. Principal reliance is placed on Luckenbach v. W. J. McCahan Sugar Refining Co., 248 U.S. 139, 39 S.Ct. 53, 63 L.Ed. 170 (1918), an admiralty case in which the Supreme Court considered a loan receipt transaction and found “no good reason . . . either for questioning its legality or for denying it effect.” Id. at 148, 39 S.Ct. at 55. Luckenbach, however, is distinguishable because of its unusual factual setting. In that case the insurer was liable only contingently — it would have incurred liability to the insured shipper only after it had been established that recovery against the carrier for the lost cargo was impossible. Furthermore, if the insurer had paid the shipper outright before the carrier’s liability had been determined, the carrier would have become liable to no one. Therefore, the loan receipt device was used so that the insured would not be deprived of the use of the money for which either the insurer or the carrier eventually would incur liability.

Thus in Luckenbach there were present at least some of the indicia of a true loan. In the case at bar, not only were the insurers absolutely liable to Executive Jet, but the terms of the loan did not require repayment of a definite sum at a definite time and did not assess any interest charges. Nor is it mere coincidence that the amount loaned was precisely equal to the aircraft’s agreed value in the insurance policy. Further, we note that under the loan receipt agreement the insurers assumed the expense, control, and direction of litigation against any third parties who might be liable for the plane crash. This, of course, is precisely the result that would be achieved in the ordinary case of payment and subrogation. These circumstances lead us to conclude that the transfer of $1,300,000 to Executive Jet was a loan in name only. In fact it was an outright settlement of a loss covered under the insurance policy, and we are unwilling to permit the form of the transaction to control its substance.

Executive Jet insists, however, that it does not rely solely upon Luckenbach and that subsequent federal cases have given literal effect to loan receipt agreements in circumstances similar to those in the case at bar. Executive Jet refers us particularly to Augusta Broadcasting Co. v. United States, 170 F.2d 199 (5th Cir. 1948), a case under the Tort Claims Act in which the court held “that the giving of the loan receipt did not affect [the insured’s] right to sue . . ..” Id. at 200. However, the court in that case stated its conclusion without any reasoning or analysis. Moreover, it appeared to rely only on Luckenbach and a decision by the Georgia Court of Appeals. Obviously the Georgia case can provide no support for Executive Jet’s position, and insofar as

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507 F.2d 508, 19 Fed. R. Serv. 2d 1274, 1974 U.S. App. LEXIS 5671, Counsel Stack Legal Research, https://law.counselstack.com/opinion/executive-jet-aviation-inc-v-united-states-ca6-1974.