Roy v. Robinson Helicopter Company CA2/3

CourtCalifornia Court of Appeal
DecidedJanuary 6, 2025
DocketB330904
StatusUnpublished

This text of Roy v. Robinson Helicopter Company CA2/3 (Roy v. Robinson Helicopter Company CA2/3) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Roy v. Robinson Helicopter Company CA2/3, (Cal. Ct. App. 2025).

Opinion

Filed 1/6/25 Roy v. Robinson Helicopter Company CA2/3 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS

California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION THREE

DANIEL ROY, B330904

Plaintiff and Appellant, (Los Angeles County Super. Ct. No. 21STCV25235) v.

ROBINSON HELICOPTER COMPANY, INC.,

Defendant and Respondent.

APPEAL from an order of the Superior Court of Los Angeles County, Deirdre Hill, Judge. Affirmed. Kristensen Law Group and John P. Kristensen for Plaintiff and Appellant. Tim A. Goetz for Defendant and Respondent.

‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗ Plaintiff and appellant Daniel Roy, personal representative of the Estate of Stéphane Roy, appeals the trial court’s order granting defendant and respondent Robinson Helicopter Company’s motion to stay the action on forum non conveniens grounds under Code of Civil Procedure section 410.30.1 Roy and plaintiff Monique Longpré (plaintiffs),2 who are Canadian citizens and residents, filed suit against Robinson after a helicopter that Robinson manufactured, designed, and sold, experienced a mechanical failure and crashed during flight in Quebec. The crash killed Stéphane Roy,3 a Canadian citizen and resident who was piloting the helicopter. The helicopter was licensed and maintained in Canada. A Canadian governmental agency investigated the crash. We conclude the trial court did not abuse its discretion in concluding private and public interest factors weighed in favor of Quebec as the forum. We therefore affirm. FACTUAL AND PROCEDURAL BACKGROUND In July 2021, plaintiffs filed suit against Robinson in the Superior Court of Los Angeles County, asserting claims of negligence, strict products liability, wrongful death, and breach of warranties in connection with the helicopter crash that killed the decedent. Roy was appointed the trustee of the Estate of

1 All further undesignated statutory references are to the Code of Civil Procedure. 2 Longpré is not a party to this appeal. 3 Because Daniel and Stéphane Roy share the same last name, we refer to Stéphane Roy as the decedent.

2 Stéphane Roy by the Quebec Superior Court of Justice,4 and Longpré is the decedent’s mother. The complaint alleged that Robinson designs, manufactures, and sells the model R44 helicopter. Robinson also manufactured the rotor blades on this model of helicopter. The complaint alleged the rotor blades have an extensive history of debonding. The model R44 helicopter at issue in this case was imported to Canada in December 2009. It was purchased by a company in which the decedent was a shareholder. On July 10, 2019, the helicopter experienced a mechanical failure and crashed during flight in Quebec, killing the decedent. Examination of the wreckage demonstrated that the rotor blades’ rotational speed had dropped to a level insufficient to maintain flight. One of the rotor blades was found with multiple adhesive failures. The complaint alleged a “debonded rotor blade will cause significant vibrations during flight, making the helicopter incapable of continued safe flight.” The complaint thus asserted the helicopter was defective. In August 2022, Robinson moved to dismiss or stay the action based on forum non conveniens. It argued the decedent was a citizen and resident of Canada, the helicopter was imported to Canada when new, and a Canadian company had purchased it. Canada and the United States are contracting states to the Convention on International Civil Aviation, which provides that Canada has complete and exclusive sovereignty over airspace above its territory. As the state of registry, Canada also was responsible for determining whether the helicopter was airworthy and safe to fly. Moreover, the Canadian government established the pilot training and proficiency requirements cited

4 The record indicates that Roy is also the decedent’s brother.

3 throughout the Canadian government’s investigative report on the crash, which Robinson included with its motion. Robinson further contended that all evidence of the decedent’s training and experience as a pilot is located in Canada. After the helicopter was located, the helicopter and accident investigation were placed under the jurisdiction and control of the Transportation Safety Board of Canada (TSB), which investigated the crash and issued a report reflecting its findings. According to the TSB report, although the decedent held a Canadian private pilot license, he had not renewed his medical certificate and thus was no longer authorized to fly. The decedent also violated Canadian aviation regulations by failing to file a flight plan or itinerary for the flight. As a result, the decedent’s flight was not reported overdue until 23 hours after the accident. After local authorities were notified of the overdue aircraft, the Royal Canadian Air Force and Canadian Coast Guard initiated a large-scale aerial search that involved 18 aircraft, 44 observers, and 77 people on the ground. After 11 days, responsibility for the search transferred to the Surete du Quebec, which located the helicopter 14 days after it was reported missing in Quebec. Although the complaint alleged that the decedent had no surviving issue, the TSB report stated there was a passenger on board whose safety harness appeared to be working properly but was found unfastened. The passenger’s body was discovered 66 meters away from the helicopter wreckage. This led investigators to believe that the passenger survived a certain period of time after the impact, whereas the decedent did not.

4 The passenger was the decedent’s 14-year-old son. Robinson asserted this raised issues of Quebec’s simultaneous death laws.5 Robinson represented that it would make all documents concerning the United States Federal Aviation Administration (FAA) certification of the helicopter available in a Canadian proceeding, whereas plaintiffs could not compel numerous non- party Canadian witnesses who maintained the helicopter, participated in the search, and prepared the investigative report, to participate in a lawsuit in the United States. In opposition to the motion, plaintiffs argued that the United States National Transportation Safety Board had issued recommendations after 10 cases of debonding were discovered in Robinson rotor blades. In response, the FAA issued an airworthiness directive requiring, among other things, inspection of the blades and their replacement by January 2020.6 Pursuant to Canadian regulations, certain airworthiness directives issued by foreign regulatory authorities also have a mandatory effect in Canada. The FAA’s airworthiness directive concerning the model R44 helicopter was mandatory in Canada. The TSB report stated that rotor blades on the helicopter at issue showed signs of

5 Whether the decedent had any surviving issue was relevant because Longpré asserted standing pursuant to section 377.60. Under that provision, if a decedent has no surviving issue, a wrongful death cause of action may be asserted by “the persons . . . who would be entitled to the property of the decedent by intestate succession.” 6 As explained in the TSB report, “[a]n [airworthiness directive] is an instruction issued by a regulatory authority . . . after discovering a problem that compromises flight safety and requires mandatory maintenance and/or operational action as a corrective and/or preventive measure.”

5 debonding. Robinson appealed the TSB report. As part of that process, the TSB sent the report to the Australian Air Investigative Board for review, which confirmed the TSB’s results.

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Roy v. Robinson Helicopter Company CA2/3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/roy-v-robinson-helicopter-company-ca23-calctapp-2025.