Grizzly Mountain Aviation, Inc. v. Honeywell International, Inc.

CourtCourt of Appeals of Texas
DecidedOctober 17, 2013
Docket13-11-00676-CV
StatusPublished

This text of Grizzly Mountain Aviation, Inc. v. Honeywell International, Inc. (Grizzly Mountain Aviation, Inc. v. Honeywell International, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Grizzly Mountain Aviation, Inc. v. Honeywell International, Inc., (Tex. Ct. App. 2013).

Opinion

NUMBER 13-11-00676-CV

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI - EDINBURG

GRIZZLY MOUNTAIN AVIATION, INC., Appellant,

v.

HONEYWELL INTERNATIONAL, INC., Appellee.

On appeal from the County Court at Law No. 2 of Nueces County, Texas.

MEMORANDUM OPINION

Before Chief Justice Valdez and Justices Garza and Longoria Memorandum Opinion by Chief Justice Valdez Appellant, Grizzly Mountain Aviation, Inc. (“Grizzly”), sued appellee, Honeywell

International, Inc. (“Honeywell”), for property damages from a helicopter crash. Grizzly

requested that the trial court apply Connecticut law on the issue of the economic loss

rule to its suit. Honeywell requested that the trial court apply Oregon law, and alternatively moved for summary judgment on the basis that, under Texas law, the

economic loss rule barred Grizzly’s lawsuit. By signed orders, the trial court denied

both parties’ requests to apply foreign law and granted Honeywell’s motion for summary

judgment. By three issues, Grizzly contends that: (1) the trial court erred in applying

Texas law and/or Oregon law; (2) the trial court should have applied Connecticut law

because it has a more substantial relationship to this case than Texas or Oregon; and

(3) even if Texas law applies, the trial court’s summary judgment against Grizzly is

improper because the economic loss rule does not bar recovery of all of Grizzly’s

property damage. We affirm the trial court’s order denying Grizzly’s motion to take

judicial notice of Connecticut law and to apply Connecticut law. We affirm the trial

court’s summary judgment in favor of Honeywell.

I. THE FACTS 1

Grizzly filed a suit in Texas against Honeywell for products liability and warranty

violations in connection with a helicopter crash that occurred in Oregon. Grizzly was the

owner of the helicopter with a registration number of N263KA (the “accident helicopter”),

and Honeywell manufactured the engine and various engine replacement components

that had been installed in the accident helicopter. In its suit, Grizzly claimed that the

catastrophic failure of the engine reduction gearbox caused the accident helicopter to

lose power and crash. Grizzly alleged that Honeywell defectively designed and

manufactured the engine and component parts that caused the engine to fail. Grizzly

requested $3,350,000 in damages for property damage to the helicopter.

1 We have based this section of our memorandum opinion on Grizzly’s statement of facts.

2 Grizzly purchased the accident helicopter from its manufacturer, Kaman

Aerospace Corporation (“Kamen”) in June 2004. According to Grizzly, it also purchased

a second helicopter from Kaman with a registration number of N133KA. Grizzly alleges

that at some point, prior to the accident, it transferred the Honeywell-manufactured

engine from the N133KA helicopter to the accident helicopter.

Grizzly filed a motion for the court to apply Connecticut law, alleging that the

engine and component parts were designed and manufactured in that state. Honeywell

moved for summary judgment. Honeywell also filed a motion for the court to apply

Oregon law to the case. In its motion for summary judgment, Honeywell argued that

Oregon’s eight-year statute of repose barred Grizzly’s suit; or alternatively, if Oregon

law did not apply, Texas’s economic loss rule barred Grizzly from recovering for

property damage to the helicopter.

After a hearing, the trial court granted Honeywell’s motion for summary judgment.

The trial court did not specify the ground on which it granted the summary judgment. By

two separate orders, the trial court also denied both Honeywell’s motion to apply

Oregon law and Grizzly’s motion to apply Connecticut law. This appeal followed.

II. CHOICE OF LAW

By its first issue, Grizzly challenges the trial court’s determination that Oregon

law applies to this case. We conclude this contention is without merit because the trial

court explicitly denied Honeywell’s motion to apply Oregon law by signed order.

Accordingly, we overrule Grizzly’s first issue to the extent it argues that the trial court

erred in applying Oregon law. By its first and second issues, Grizzly argues that the trial

court erred in applying Texas law and not applying Connecticut law.

3 A. Standard of Review

Which state’s law governs an issue is a question of law for the court to decide.

Minn. Mining & Mfg. Co. v. Nishika Ltd., 955 S.W.2d 853, 856 (Tex. 1996); Grant

Thornton LLP v. Suntrust Bank, 133 S.W.3d 342, 357–58 (Tex. App.—Dallas 2004, pet.

denied). Accordingly, we must review the trial court’s decision to apply Texas law in this

case de novo. Minn. Mining & Mfg. Co. 955 S.W.2d at 856.

Texas courts presume that Texas law applies. PennWell Corp. v. Ken Assocs.,

Inc., 123 S.W.3d 756, 760–61 (Tex. App.—Houston [14th Dist.] 2003, pet. denied);

Pittsburgh Corning Corp. v. Walters, 1 S.W.3d 759, 769 (Tex. App.—Corpus Christi

1999, pet. denied). Texas courts can also presume that another state’s law is the same

as Texas law absent proof or argument to the contrary. Coca–Cola Co. v. Harmar

Bottling Co., 218 S.W.3d 671, 685 (Tex. 2006); Pittsburgh Corning Corp., 1 S.W.3d at

769. The party requesting application of a foreign law has the initial burden of showing

that the foreign law conflicts with Texas law. Compaq Computer Corp. v. Lapray, 135

S.W.3d 657, 672 (Tex. 2004) (“In reviewing the trial court’s decision, we must first

decide whether Texas law conflicts with the laws of other interested states, as there can

be no harm in applying Texas law if there is no conflict.”); Greenberg Traurig of N.Y.,

P.C. v. Moody, 161 S.W.3d 56, 69 (Tex. App.—Houston [14th Dist.] 2005, no pet.) (“A

court must make a conflicts-of-laws decision only when the case is connected with more

than one state and the laws of the states in question differ on one or more points in

issue.”) (citing Weatherly v. Deloitte & Touche, 905 S.W.2d 642, 650 (Tex. App.—

Houston [14th Dist.] 1995, writ dism’d w.o.j.), leave granted, mand. denied, 951 S.W.2d

394 (Tex. 1997)). Once the requesting party has shown that a conflict exists, it must

4 then show that the foreign law applies. Greenberg Traurig of N.Y., P.C., 161 S.W.3d at

94.

A party requesting a Texas court to apply another state’s law must comply with

rule of evidence 202. Pittsburgh Corning Corp. v. Walters, 1 S.W.3d 759, 769 (Tex.

App.—Corpus Christi 1999, pet. denied); see PennWell Corp., 123 S.W.3d at 760–61

(applying rule 203 to determine whether foreign law applied). Rule 202 states:

A court upon its own motion may, or upon the motion of a party shall, take judicial notice of the constitutions, public statutes, rules, regulations, ordinances, court decisions, and common law of every other state, territory, or jurisdiction of the United States. A party requesting that judicial notice be taken of such matter shall furnish the court sufficient information to enable it properly to comply with the request, and shall give all parties such notice, if any, as the court may deem necessary, to enable all parties fairly to prepare to meet the request.

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