In re Air Crash Near Clarence Center

49 Misc. 3d 493, 18 N.Y.S.3d 500
CourtNew York Supreme Court
DecidedAugust 11, 2014
StatusPublished

This text of 49 Misc. 3d 493 (In re Air Crash Near Clarence Center) is published on Counsel Stack Legal Research, covering New York Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Air Crash Near Clarence Center, 49 Misc. 3d 493, 18 N.Y.S.3d 500 (N.Y. Super. Ct. 2014).

Opinion

OPINION OF THE COURT

Frederick J. Marshall, J.

On February 12, 2009, Continental Connection Flight 3407 crashed on approach to the Buffalo Niagara International Airport, killing all 49 passengers and crew, as well as one individual on the ground. Douglas Wielinski died when the fallen aircraft struck his home in Clarence, New York. His wife and daughter, who were also at home, suffered injuries but managed to escape the burning dwelling.

The aircraft was operated by Colgan Air, Inc., a regional carrier, in accordance with a capacity purchase agreement (CPA) with Continental Airlines, Inc. Colgan has admitted that its pilot and copilot were negligent and that the negligence of its pilot and copilot caused the crash of Flight 3407 and the death of Douglas Wielinski.

Continental, in moving for summary judgment, takes the position that it bears no legal responsibility for the happening of the accident. The several bases asserted by Continental will be discussed and decided herein.

To succeed on a motion for summary judgment, the proponent of the motion must establish his cause of action or defense by submitting proof in admissible form so as to warrant a finding by the court that the proponent has established his cause of action or defense, as a matter of law. (Zuckerman v City of New York, 49 NY2d 557 [1980].) Once this showing has been made, the burden shifts to the party opposing the motion to demonstrate by admissible evidence that a material question of fact exists, thus requiring a trial. (See id.) “[M]ere conclusions, expressions of hope or unsubstantiated allegations or assertions are insufficient.” (Id. at 562.)

Continental first contends that it owed no duty to the plaintiffs because it exercised no control of, or supervision over, Colgan and had no say in the hiring, training, or retention of Colgan’s pilots. (See Hamilton v Beretta U.S.A. Corp., 96 NY2d 222 [2001].)

“A duty may arise . . . where there is a relationship either between defendant and a third-person tortfeasor that encompasses defendant’s actual control of the third person’s actions, or between [495]*495defendant and plaintiff that requires defendant to protect plaintiff from the conduct of others. Examples of these relationships include master and servant, parent and child, and common carriers and their passengers.” (Hamilton v Beretta U.S.A. Corp. at 233.)

Whether a duty exists is a legal determination to be made by the court. (Eaves Brooks Costume Co. v Y.B.H. Realty Corp., 76 NY2d 220 [1990].)

The relationship of Continental and Colgan warrants close examination.

The undisputed evidence shows that Continental and Colgan entered into a “Code-Share” arrangement whereby one airline operates flights which are marketed by another airline. (See aff of John Marshall, June 10, 2014, ][ 7.)1 In this case, the relationship and obligations of the two airlines were governed by a CPA dated February 2, 2007. (See exhibit A attached to the affirmation of Philipp L. Rimmler, Esq., dated July 14, 2014.)

Under that agreement, which included defendant Pinnacle Airlines Corp.,2 airplanes owned by Pinnacle would be flown by Colgan, a Federal Aviation Administration (FAA) approved carrier, over designated regional routes established by Continental. These flights would be operated by Colgan under the “Continental Connection” service mark.

Under the CPA, Continental agreed to purchase all the seats on each flight. The seat tickets would then be sold by Continental and Continental would retain all the revenue from such ticket sales. Continental was also responsible for marketing each flight and establishing and publishing fares and schedules. Colgan had the right to use Continental “marks” (i.e., name and logo), and did so both within and without the Flight 3407 aircraft. Finally, Continental provided certain baggage, ground handling and gate services.

Under the CPA, Colgan was responsible for providing the flight and cabin crews, gate agents and other ground personnel necessary to operate the flights. There is no dispute that Captain Renslow, the pilot, and Rebecca Shaw, the copilot on Flight 3407, were employees of Colgan and that Colgan was solely responsible for hiring and training them. Colgan was required to comply with all governmental regulations and was [496]*496further required to maintain all “certifications, permits, licenses, certificates, . . . required by governmental authorities.” (CPA § 4.02.) At the time of the crash of Flight 3407, Colgan possessed a current operating certificate from the FAA.

Under section 4.03 of the CPA, Colgan was obligated to “provide Regional Airline Services with appropriate standards of care, but in no event lower than such standards utilized by Continental as of the date of this Agreement.” According to section 4.06 of the CPA, Colgan remained “solely responsible for the safe operation of its aircraft.” However, Continental, under the same section, had “the right, at its own cost, to inspect, review and observe [Colgan’s] operations of Scheduled Flights.”

Based on this relationship, Continental claims that Colgan was an independent contractor; that Colgan had absolute control over the aircraft and its crew; that Colgan was responsible for all pilot hiring, pilot training, aircraft maintenance and all in-flight operations.

Generally, a party who retains an independent contractor is not liable for the independent contractor’s negligent acts. (See Kleeman v Rheingold, 81 NY2d 270 [1993]; also see Brothers v New York State Elec. & Gas Corp., 11 NY3d 251 [2008].)

Our common law has, for public policy reasons, produced three general categories of exceptions to the general rule. (See Kleeman at 274.) They are as follows:

1. Negligence of the employer in selecting, instructing or supervising the contractor;

2. Employment for work that is especially or inherently dangerous;

3. Instances in which an employer is under a specific nondelegable duty. (See Kleeman at 274.)

Preliminarily, the court finds that Colgan acted in the capacity of an independent contractor for Continental. The CPA states that “[Colgan] will act, for all purposes, as an independent contractor and not as an agent for Continental.” (See CPA § 7.04 [b].) The CPA further provided that “[n]othing in this Agreement shall be interpreted or construed as establishing between the parties a partnership, joint venture or other similar arrangement.” (CPA § 10.11.)

Plaintiffs’ claim that Colgan was an agent of Continental has no merit. A principal-agent relationship is marked by evidence of the “consent of one person to allow another to act on his or her behalf and subject to his or her control, and consent by the [497]*497other so to act.” (Maurillo v Park Slope U-Haul, 194 AD2d 142, 146 [2d Dept 1993].) There is no evidence to suggest that Colgan was subject to the control of Continental with respect to its operation of Flight 3407. Continental’s role was limited to ticket sales, the establishment of fares and schedules and certain ground services. It did not have or exercise any control over the hiring and training of Colgan pilots, maintenance or mechanical issues or the in-flight operation of Colgan’s aircraft.

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Bluebook (online)
49 Misc. 3d 493, 18 N.Y.S.3d 500, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-air-crash-near-clarence-center-nysupct-2014.