Beech Aircraft Corp. v. Rainey
United States Supreme Court
488 U.S. 153 (1988)
Two Navy pilots died when their training aircraft crashed for unknown reasons. Their spouses sued Beech Aircraft Corp. (defendant), the plane's manufacturer, on a products-liability theory that engine failure caused the crash; Beech countered with pilot error. Beech sought to admit an investigative report ordered by the training squadron's commander, organized into "findings of fact," "opinions," and "recommendations" sections, including an opinion that the crash was "most probably" caused by the pilots' failure to maintain proper interval. The trial judge admitted the opinion statement, but the court of appeals reversed, excluding it as beyond the scope of the public-records hearsay exception. Beech appealed to the Supreme Court.
Whether conclusions and opinions contained in a public agency's investigative report are admissible under the hearsay exception for public records.