Polskie Linie Lotnicze Lot SA v. The Boeing Company

CourtDistrict Court, W.D. Washington
DecidedSeptember 30, 2022
Docket2:21-cv-01449
StatusUnknown

This text of Polskie Linie Lotnicze Lot SA v. The Boeing Company (Polskie Linie Lotnicze Lot SA v. The Boeing Company) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Polskie Linie Lotnicze Lot SA v. The Boeing Company, (W.D. Wash. 2022).

Opinion

UNITED STATES DISTRICT COURT 4 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 5

6 POLSKIE LINIE LOTNICZE LOT S.A., CASE NO. C21-1449RSM 7 Plaintiff, ORDER GRANTING IN PART DEFENDANT’S MOTION TO 8 v. DISMISS 9 THE BOEING COMPANY, 10 Defendant.

11 I. INTRODUCTION 12 This matter is before the Court on Defendant Boeing’s Motion to Dismiss, Dkt. #28, 13 and its subsequently filed Motion for Protective Order, Dkt. #34. Plaintiff Polskie Linie 14 Lotnicze LOT (“LOT”) has sued Boeing for damages related to its purchase of Boeing’s 737 15 MAX aircraft. The Complaint in this case is 143 pages. Dkt. #1. LOT alleges it was damaged 16 after the crashes of 737 MAX aircraft in 2018 and 2019, Lion Air Flight 610 and Ethiopian 17 Airlines Flight 302. After the second crash, the 737 MAX was grounded by aviation 18 authorities and Boeing acknowledged certain defects. At that point LOT had leased fourteen 19 737 MAX aircraft, five of which were delivered before the 737 MAX was grounded, and nine 20 of which were never delivered. 21 Seeking to hold Boeing responsible for its ensuing financial losses, LOT alleges the 22 following causes of action: 23 1. fraudulent misrepresentation; 24 1 2. negligent misrepresentation; 3. fraudulent concealment/omission; 2 4. unilateral mistake; 3 5. mutual mistake; 4 6. rescission; 5 7. violation of the implied warranty of merchantability; 6 8. violation of the implied warranty of fitness for a particular purpose; 7 9. violation of the Washington Consumer Protection Act (“CPA”); 8 10. product liability under the Washington Product Liability Act (“WPLA”); 9 11. tortious interference with contracts; and 10 12. tortious interference with a business expectancy. 11 Dkt. #1. 12 Boeing moves for dismissal of all claims. Having considered the issues, the Court 13 denies this Motion in part, grants the Motion in part with leave to amend, and denies Boeing’s 14 Motion for a Protective Order. 15 II. BACKGROUND 16 For purposes of this Motion to Dismiss, the Court will accept all facts in the Complaint, 17 Dkt. #1, as true. The Court will briefly summarize the allegations. 18 Plaintiff LOT is a corporation organized and existing under the laws of Poland, and 19 maintains its principal place of business in Poland. LOT is a commercial airline that operates 20 scheduled air services, among other places, between the United States and Poland, pursuant to 21 the terms of a foreign air carrier permit issued by the United States Department of 22 Transportation. Boeing is an aerospace company involved in the design, manufacture, and sale 23 of commercial aircraft. 24 1 In August of 2011, Boeing’s Board of Directors authorized the launch of a new iteration of 737 aircraft to compete with the Airbus A320 NEO—the “MAX” Series. In its launch 2 announcement, Boeing emphasized the connection to the 737 product line’s service history 3 explaining that “[w]e call it the 737 MAX because it optimizes everything we and our 4 customers have learned about designing, building, maintaining and operating the world’s best 5 single-aisle airplane.” 6 Rather than designing a new aircraft from scratch, Boeing launched a new engine variant 7 of the existing 737. To make the new 737 more fuel efficient, and therefore competitive with the 8 A320 NEO, the preexisting 737 NG’s engines were to be replaced with the larger, more fuel- 9 efficient CFM International LEAP1-B (the “LEAP1-B”) engines. 10 In its launch announcement Boeing asserted, inter alia, that: “The 737 MAX will deliver 11 big fuel savings that airlines will need to successfully compete in the future. Airlines will 12 benefit from a 7 percent advantage in operating costs over future competing airplanes as a result 13 of optimized CFM International LEAP-1B engines, more efficient structural design and lower 14 maintenance requirements;” and “Airlines will continue to benefit from maximum reliability. 15 The 737 MAX will build upon the Next-Generation 737’s highest reliability performance of any 16 airplane in the world – 99.7 percent on-time departure rate.” 17 Boeing’s 737 MAX launch announcement did not disclose that as compared to the most 18 recent 737 NG, the addition of the LEAP1-B engines would, inter alia: change the aircraft’s 19 center of gravity; decrease aircraft stability; negatively affect flight handling characteristics to 20 make the aircraft more susceptible to the catastrophic risk of aerodynamic stall; and create 21 inherent safety risks. 22 23 24 1 LOT alleges, “Boeing eschewed the opportunity to properly engineer the 737 MAX and instead found a way to fit the new, larger engine on an existing airframe, thereby creating 2 inherent risks that Boeing would later attempt and fail to mitigate.” 3 Boeing concealed that the use of LEAP1-B engines, and their placement on the airframe, 4 rendered the 737 MAX distinct from its 737 predecessors, and the design changes advertised 5 did not disclose the full scope of differences between the prior 737 variants and the 737 MAX. 6 The 737 MAX program’s overarching goal and primary design objective was to achieve 7 commonality with the 737 NG, and to ensure that the Federal Aviation Administration (“FAA”) 8 would not require a new “type certificate” or require aircraft simulator training for pilots 9 transitioning to the 737 MAX from the 737 NG, which some of Boeing’s largest customers 10 were flying at the time. 11 The FAA approved Boeing’s application for an amended type certificate rather than a 12 new type certificate. Under an amended type certificate, as agreed by the FAA and Boeing, 13 only the significant, “new and novel” differences between the 737 NG and the 737 MAX were 14 required to be certified to current regulatory airworthiness standards. 15 Boeing added a software-based flight control logic called the Maneuvering 16 Characteristics Augmentation System (“MCAS”) to the 737 MAX to compensate for the 17 problems caused by using larger engines. Boeing allegedly concealed this system, which did 18 not exist on any other 737 aircraft, from regulators and operators such as LOT. Boeing claimed 19 that it did not need to identify MCAS as “new and novel” because it had been covered under 20 existing regulations relating to flight control systems and were included on the military Boeing 21 767 refueling tanker. However, the version of MCAS on the 737 MAX was different, relying 22 on one sensor instead of two, and controlling the aircraft’s movement in ways that the MCAS 23 on the military tanker did not. 24 1 Boeing knew of problems with the 737 MAX MCAS system at the outset of its design and through the certification process. For example, in 2012, it took a Boeing test pilot more 2 than 10 seconds to respond to uncommanded MCAS activation in a flight simulator, which the 3 pilot found to be “catastrophic.” In a November 27, 2012, email a Boeing employee noted that 4 an MCAS light indication on the flight control panel had been removed enabling Boeing to hide 5 MCAS’s existence. In March of 2016 Boeing revised the MCAS flight control logic; in this 6 second iteration of MCAS, Boeing chose to omit key safeguards that had previously been 7 included in earlier iterations used on the 767 military tanker. The FAA was not informed by 8 Boeing of this change to MCAS. On June 16, 2016, a Boeing employee noted an issue that 9 would prove critical to the 737 MAX crashes: a test pilot was having trouble countering 10 repetitive MCAS activation, and the employee questioned whether such difficulties were a 11 safety or certification issue. Boeing concealed this information, by e.g., continuing to tout the 12 benefits of MAX’s LEAP1-B engines without mentioning unintended side effects. 13 The lengthy Complaint discusses many other issues with the MCAS system, too 14 numerous to recount in this Order.

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