Vreeland v. Ferrer

Ferrer (defendant) leased an airplane from Aerolease; the plane crashed, killing the pilot and a passenger, Martinez. Vreeland (plaintiff), as Martinez's estate representative, sued under Florida's dangerous-instrumentality doctrine, which imposes strict vicarious liability on an owner who lets another operate a vehicle or aircraft negligently. The defendants argued this state tort claim was preempted by 49 U.S.C. section 44112, a federal statute limiting aircraft lessors' liability.

Whether federal law preempts a conflicting state-law tort claim where Congress explicitly intends preemption in the statute's language, or where Congress implicitly expressed intent to occupy the field.