In re Air Crash Disaster Near Chicago, Illinois on May 25, 1979
United States Court of Appeals for the Seventh Circuit
644 F.2d 594 (1981)
After American Airlines (AA) (defendant) Flight 191, manufactured by McDonnell Douglas (MDC) (defendant), crashed in Illinois killing 273 people, 118 wrongful death suits were filed across six jurisdictions (Illinois, California, New York, Michigan, Hawaii, and Puerto Rico) and consolidated for pretrial proceedings in Illinois; plaintiffs sought both compensatory and punitive damages against AA (headquartered in New York, maintained the plane in Oklahoma) and MDC (headquartered in Missouri, designed and built the plane in California). The district court struck the punitive damages claims against AA but let those against MDC proceed, and both plaintiffs and MDC appealed.
Whether, in a mass tort with actions filed across multiple jurisdictions implicating several states' laws, the transferee court should apply each original forum state's own choice-of-law principles separately to determine which state's law governs the specific issue of punitive damages.