Smartwings AS v. The Boeing Company

CourtDistrict Court, W.D. Washington
DecidedFebruary 25, 2022
Docket2:21-cv-00918
StatusUnknown

This text of Smartwings AS v. The Boeing Company (Smartwings AS 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
Smartwings AS v. The Boeing Company, (W.D. Wash. 2022).

Opinion

6 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 7 AT SEATTLE

8 SMARTWINGS, A.S., a Czech Republic CASE NO. C21-918 RSM Company, 9 ORDER GRANTING IN PART Plaintiff, DEFENDANT’S MOTION TO DISMISS 10 v. 11 THE BOEING COMPANY, a Delaware 12 Corporation,

13 Defendant.

14 15 I. INTRODUCTION 16 This matter is before the Court on Defendant The Boeing Company’s Motion to Dismiss, 17 Dkt. #15, and its subsequently filed Motion for Protective Order, Dkt. #18. Plaintiff Smartwings, 18 a.s. (“Smartwings”), has sued Defendant The Boeing Company (“Boeing”) for damages related 19 to its purchase of Boeing’s 737-8 aircraft (the “737MAX”). Smartwings purchased or leased 45 20 737MAXs. In October 2018, and while the parties continued performance under their 21 agreements, Lion Air Flight 610, a 737MAX, crashed from the sky. Boeing assured the public 22 that the 737MAX was “as safe as any aircraft in the sky.” But in March 2019, a second 737MAX, 23 Ethiopian Airlines Flight 302, crashed from the sky. After the second crash, the 737MAX was 24 1 grounded by the FAA and Boeing acknowledged defects in the 737MAX. Smartwings, which 2 had structured its business to rely on the 737MAX, experienced extensive losses as a result. 3 Seeking to hold Boeing responsible, Smartwings has sued Boeing for its losses. 4 Smartwings alleges theories of breach of contract (first and second claims), breach of the duty of 5 good faith and fair dealing (third claim), fraud (fourth claim), material misrepresentation (fifth

6 claim), violation of the Washington Consumer Protection Act (sixth claim), and violation of the 7 Washington Products Liability Act (seventh claim). See generally Dkt. #1-2. In its motion to 8 dismiss, Boeing only seeks dismissal of Smartwings’ non-contract claims. Dkt. #15. 9 Accordingly, Smartwings’ first and second claims are not addressed. Additionally, Boeing’s 10 motion for a protective order seeks to limit discovery on Smartwings’ non-contract claims until 11 after the Court has ruled on its motion to dismiss those claims. Having considered the issues, the 12 Court grants the motion to dismiss in part and denies Boeing’s motion for a protective order as 13 moot. 14 II. BACKGROUND

15 The Court adopts and sets forth Smartwings’ statement of the relevant factual 16 allegations:1 17 A. Commercial Pressures Push Boeing to Implement Flawed Flight Software on the MAX to Mimic the Handling of the Materially 18 Different 737NG.

19 In July 2011, Boeing found itself outpaced by the product development and commercial success of its archrival aerospace manufacturer, Airbus. (Compl. 20 ¶¶ 36–39.). To catch up, Boeing scrapped its only-recently-trumpeted plans to design a new narrow-body passenger aircraft and announced it would once again 21 update the almost 50-year-old 737 design with new fuel-efficient engines. Boeing

22 1 In considering a motion pursuant to Rule 12(b)(6), “[a]ll allegations of material fact are taken as true and construed in the light most favorable to the nonmoving party.” Sprewell v. Golden 23 State Warriors, 266 F.3d 979, 988 (9th Cir. 2001) (citations omitted). Smartwings has provided clear citations to the allegations of its complaint and Boeing has not objected to Smartwings’ 24 characterization of the complaint’s allegations. 1 branded it the 737 MAX. (Id. ¶ 40.). To save time and money and to reduce FAA scrutiny, Boeing decided to certify the MAX under the 1967 737 Type Certificate. 2 (Id. ¶¶ 41–42.) Boeing was also determined to avoid any regulatory requirement for significant pilot “differences” training for existing 737 pilots. This required 3 Boeing to convince the FAA that the MAX handled like a 737NG. (Id. ¶¶ 43–47).

4 But MAX’s new engines were too large to fit the airframe unless they were moved forward and up. Boeing’s engineers anticipated that this change would 5 create a new and unacceptable handling issue that could cause the MAX to pitch up, losing airspeed and risking a stall, in some unusual flight regimes. (Id. ¶¶ 48– 6 54.) Boeing could have applied well-understood (but more expensive and time- consuming) aerodynamic engineering principles to fix the problem. Instead, it 7 chose a software fix called MCAS.

8 As originally conceived, MCAS would activate under high-G, near-stall conditions and automatically apply downward stabilizer trim. From the pilot’s 9 perspective, the MAX would handle like the 737NG, with MCAS smoothing out the differences. (Id. ¶¶ 55–57.) But in flight testing the MAX exhibited an 10 unanticipated problem—the aircraft also pitched up during low-speed maneuvers. (Id. ¶ 58.) Again opting for the quicker, cheaper fix, Boeing made critical and 11 dangerous changes to MCAS to patch over the problem.

12 Boeing made MCAS four times more powerful than before so that it pushed the aircraft’s nose down much more aggressively. Boeing also eliminated one of 13 the two inputs required to trigger the system, leaving MCAS’s activation entirely reliant on the output of a single Angle of Attack (“AOA”) sensor. If the AOA 14 sensor showed the nose pitched up and nearing a stall, MCAS would aggressively push the nose down. (Id. ¶ 59.) But AOA sensors are prone to malfunction, and 15 despite the MAX having two sensors, Boeing chose to have MCAS rely on the readings of only one while including no self-diagnostic software to test that the 16 AOA was functioning properly. (Id. ¶ 60–61.) Further, Boeing programmed MCAS to reset itself for five seconds after applying downward trim for ten seconds, 17 never stopping so long as the sensor continued to show the aircraft close to stalling. (Id. ¶ 62.) 18 B. Boeing Misrepresents and Conceals MCAS’s Catastrophic Potential to 19 the FAA.

20 Boeing knew MCAS could make the MAX dangerously difficult for pilots to control. In November 2016—seven months before the first MAX delivery—a 21 Boeing test pilot reported MCAS was “running rampant” with the aircraft “trimming itself like cra[z]y” in simulations. (Id. ¶ 67.) In 2015, a Boeing engineer 22 raised concerns about MCAS’s reliance on a single sensor but was ignored. (Id. ¶ 68.) And Boeing’s formal Safety System Analysis of MCAS was deeply flawed. 23 Portions of the analysis evaluated the early MCAS design before Boeing increased its power by a factor of four. It also failed to account for the effect of the cascade 24 of alarms that would follow a false AOA reading. It did not disclose that an MCAS 1 malfunction at normal climb or cruise speeds would be substantially more dangerous than at low speeds or that the aircraft’s 15-second nose down cycle could 2 put the aircraft into an unrecoverable dive. (Id. ¶¶ 69–77.) Relying on this deeply flawed analysis, Boeing falsely told the FAA that an MCAS malfunction would be 3 a “major” failure (defined by regulation as a failure that could cause “physical distress to occupants of aircraft” but not a “catastrophic” failure that could result in 4 multiple fatalities or loss of the aircraft. (Id. ¶¶ 79–80.) Boeing ultimately obtained certification of the MAX by misrepresenting, omitting, and concealing the nature 5 of MCAS from the FAA. At the same time Boeing successfully lobbied the FAA to waive requirements for other cockpit alert and indicator updates because they 6 were too “costly” and “impractical” to implement on the aged 737. (Id. ¶ 81.)

7 Boeing also needed to convince the FAA that existing 737NG pilots should be allowed to fly the MAX with minimal, computer-based training that Boeing 8 knew would not be allowed if pilots were to be properly trained on MCAS. (Id. ¶¶ 81–84.) Boeing’s solution was simply to pretend that MCAS did not exist. 9 Thus, Boeing falsely told the FAA that MCAS failures would be rare and would mimic a condition called “runaway trim” that pilots were already trained to 10 diagnose and address. (Id.

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Smartwings AS v. The Boeing Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smartwings-as-v-the-boeing-company-wawd-2022.