In a previous post, we wrote about a lawsuit arising from the 2003 crash of a Cirrus SR-22 in low visibility near Hill City, Minnesota. In the lawsuit, the next of kin of the pilot and passenger claimed that Cirrus and a university failed to provide the pilot with adequate flight training on the subject aircraft.
The appeal court found that the claim for inadequate training could not succeed as Cirrus did not owe a duty to the pilot to provide training. In addition, the claims were barred by the “educational malpractice doctrine”. The policy behind this doctrine is that courts are considered to be inadequately suited to determine the standard or quality of education provided by an institution. In addition, calculating damages for these types of claims (such as loss of income) would be extremely difficult, if not impossible.
On July 18, 2012, the Minnesota Supreme Court issued its ruling after a further review of the appeal court decision. In its ruling, the Court confirmed that the duty to warn has never before required a supplier or manufacturer to provide training, only accurate and thorough instructions on the safe use of the product, as Cirrus had done in this case.
As there was no requirement to provide training, the Supreme Court did not have to consider the appeal court’s application of the “educational malpractice doctrine” to flight training.