Beech Aircraft Corp. v. Rainey

Beech Aircraft Corporation v. Rainey, 488 U.S. 153 (1988), was a United States Supreme Court case that addressed a longstanding conflict among the Federal Courts of Appeals over whether Federal Rule of Evidence 803(8)(C), which provides an exception to the hearsay rule for public investigatory reports containing "factual findings," extends to conclusions and opinions contained in such reports.

[1] On July 13, 1982, U.S. Navy Lieutenant Commander Barbara Allen Rainey and her trainee Ensign Donald Bruce Knowlton were practicing touch-and-go landings at Middleton Field near Evergreen, Alabama, when the aircraft banked sharply, lost altitude, and crashed.

The plaintiffs alleged that the crash had been caused by a loss of engine power, known as "rollback," due to some defect in the aircraft's fuel control system.

This "JAG Report," completed during the six weeks following the accident, was organized into sections labeled "finding of fact," "opinions," and "recommendations," and was supported by some 60 attachments.

Among his "opinions" Lieutenant Commander Morgan stated that due to the deaths of the two pilots and the destruction of the aircraft "it is almost impossible to determine exactly what happened to Navy 3E955 from the time it left the runway on its last touch and go until it impacted the ground."

[1] Five or six months after the accident, plaintiff John Rainey, husband of the deceased pilot and himself a Navy flight instructor, sent a detailed letter to Lieutenant Commander Morgan.

Based on Rainey's own investigation, the letter took issue with some of the JAG Report's findings and outlined Rainey's theory that "[t]he most probable primary cause factor of this aircraft mishap is a loss of useful power (or rollback) caused by some form of pneumatic sensing/fuel flow malfunction, probably in the fuel control unit."

The first was to the effect that his wife had unsuccessfully attempted to cancel the ill-fated training flight because of a variety of adverse factors including her student's fatigue.

The panel also held, citing Federal Rule of Evidence 106, that it was reversible error for the trial court to have prohibited cross-examination about additional portions of Rainey's letter which would have put in context the admissions elicited from him on direct.