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Keywords

contractlawsuitbreach of contractplaintifflitigationnegligencecommon law

contractlitigationliabilityappealcommon law

Related Cases

Miree v. DeKalb County, Ga., 433 U.S. 25, 97 S.Ct. 2490, 53 L.Ed.2d 557

Facts

The case arose from a 1973 Lear Jet crash shortly after takeoff from DeKalb-Peachtree Airport. The plaintiffs, including survivors of deceased passengers and a burn victim, filed separate lawsuits against DeKalb County, alleging negligence, nuisance, and breach of contract. They claimed to be third-party beneficiaries of contracts between the county and the FAA, which required the county to restrict land use near the airport to compatible activities. The plaintiffs argued that the county's operation of a garbage dump adjacent to the airport led to the crash due to birds being ingested into the aircraft's engines.

Petitioners are, respectively, the survivors of deceased passengers, the assignee of the jet aircraft owner, and a burn victim.

Issue

Whether state or federal law should apply to the plaintiffs' breach-of-contract claims against DeKalb County as third-party beneficiaries of contracts with the FAA.

Whether state or federal law should apply to the resolution of petitioners' claim that, as, respectively, survivors of deceased passengers, the assignee of the aircraft owner, and a burn victim, they are the third-party beneficiaries of grant contracts between the county and the Federal Aviation Administration.

Rule

In diversity cases, state law governs unless a significant federal interest is at stake that necessitates the application of federal common law.

Analysis

The Supreme Court determined that the case did not involve substantial rights or duties of the United States, and thus federal common law was not applicable. The court emphasized that the litigation was solely between private parties and that the outcome would not directly affect federal interests. Therefore, Georgia law should govern the plaintiffs' claims.

The litigation before us raises no question regarding the liability of the United States or the responsibilities of the United States under the contracts.

Conclusion

The Supreme Court vacated the judgment of the Fifth Circuit and remanded the case for further proceedings under Georgia law.

The judgment is vacated, and the cases are remanded to the Court of Appeals for further proceedings consistent with this opinion.

Who won?

DeKalb County prevailed as the Supreme Court ruled that state law applied, allowing the county's governmental immunity to stand.

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