Boyle v. United Technologies Corporation

Supreme Court of the United States · 1988 · Civil Procedure

487 U.S. 500 (1988)

Updated July 29, 2026

Civil Proceduremilitary contractor defensefederal common lawuniquely federal interestssignificant conflictdiscretionary functionstate tort lawdesign defect

Facts

David Boyle, a Marine helicopter copilot, died after a CH-53D helicopter crashed off Virginia Beach during a training exercise. He survived the impact but could not escape and drowned; the plaintiff alleged the copilot's emergency escape system was defectively designed because the hatch opened outward and access to the handle was obstructed. The helicopter had been built by Sikorsky for the United States. The jury returned a general verdict for the plaintiff on theories including defective design under Virginia tort law.

Issue

When may a contractor supplying military equipment to the Federal Government be held liable under state tort law for a design defect? More specifically, does federal law displace state tort law in some military equipment design-defect cases, and if so, under what conditions?

Rule

State law imposing liability for design defects in military equipment is displaced by federal law when there is a significant conflict between that state law and federal interests. Liability cannot be imposed pursuant to state law when (1) the United States approved reasonably precise specifications, (2) the equipment conformed to those specifications, and (3) the supplier warned the United States about dangers in the equipment's use that were known to the supplier but not to the United States.

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Lena Ortiz, a National Guard mechanic in Arizona, was injured when a military transport vehicle’s battery compartment ignited during maintenance. She sues Desert Forge Systems, the contractor that built the vehicles, under Arizona design-defect law, alleging the compartment should have included a heat shield. The evidence shows the Army purchased the vehicle by catalog model number and never reviewed or approved the battery-compartment design in particular.

Is Desert Forge Systems most likely protected from state-law design-defect liability?

Explanation. The defense applies only when the United States approved reasonably precise specifications for the particular challenged design feature, the equipment conformed to them, and the contractor warned of dangers known to it but not to the United States. A mere purchase by model number, without meaningful Government approval of the specific feature, does not establish the significant conflict needed to displace state law.