Garner v. Phoenix Air Group, Inc.

Background

Phoenix Air Group, Inc. provided aircraft and flight crews to the U.S. Navy under a contract with the U.S. Department of the Interior. In 2023, one aircraft crashed off California’s coast during naval training exercises, killing all three crew members. The exercises took place entirely over navigable Pacific Ocean waters and were intended to improve the defensive capabilities of U.S. naval vessels.

The crew members’ families sued Phoenix Air for wrongful death and survival damages under general maritime law. Phoenix Air moved to dismiss, arguing that the court lacked admiralty jurisdiction and that state workers’ compensation laws supplied the exclusive remedy.

Admiralty jurisdiction

Admiralty jurisdiction is federal court authority over certain maritime matters. The court applied a three-part test for airplane crashes: the crash must occur in navigable waters, have the potential to disrupt maritime commerce, and bear a substantial relationship to traditional maritime activity.

Phoenix Air conceded the first two requirements for purposes of its motion but argued that the flight was essentially a land-based trip between two points and had only an incidental connection to the water. The court distinguished that situation from a prior case involving a plane that crashed into Lake Erie after striking birds during takeoff. Here, the crash occurred during exercises conducted entirely over navigable waters, making a crash in those waters predictable.

The court also held that the flight had a substantial relationship to traditional maritime activity. The aircraft supported Navy operations and participated in exercises designed to protect naval vessels. Relying on Ninth Circuit precedent, the court concluded that an aircraft serving the Navy’s sea operations is maritime by nature. The court therefore held that admiralty jurisdiction applied.

Effect of Georgia workers’ compensation law

Phoenix Air argued that Georgia’s workers’ compensation statute barred the families from pursuing other remedies. The statute provides remedies for dependents of workers who die on the job and makes those remedies exclusive against other common-law or other claims.

The court held that general maritime law gives survivors of non-seamen who die in state territorial waters the right to bring wrongful-death and survival actions. States may supplement federal maritime law, but they may not take away substantial maritime rights. The court agreed with decisions holding that state workers’ compensation exclusivity provisions cannot prevent non-seamen’s survivors from pursuing general maritime wrongful-death claims.

The court rejected Phoenix Air’s reliance on a decision applying an interest-balancing approach to a state workers’ compensation law. That decision involved a personal-injury claim, while the case before the court involved wrongful death; the cited decision itself recognized that general maritime law would control a wrongful-death claim. The court further held that when state law conflicts with federal maritime law, the Supremacy Clause requires state law to yield rather than requiring a balancing of competing interests.

Disposition

The court granted Phoenix Air’s request for judicial notice of a preliminary National Transportation Safety Board accident report. Magistrate Judge Alex G. Tse denied Phoenix Air’s motion to dismiss. The court held that admiralty jurisdiction applied and that Georgia workers’ compensation law did not displace general maritime law, so the plaintiffs’ wrongful-death and survival claims could proceed. The court also set an initial case-management conference for August 8, 2025, and required a joint case-management statement by August 1, 2025.