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McAuliffe v. Robinson Helicopter Co. — GARA Rolling Provision Interpretation

The Ninth Circuit affirmed in part and reversed in part the District of Hawaii's summary judgment in McAuliffe v. Robinson Helicopter Co., a wrongful death action arising from a 2019 helicopter sightseeing crash. The panel held the district court erred in requiring plaintiffs to show that replacement main rotor hub and blades were substantively altered from the original parts to trigger GARA's rolling provision—finding the statute requires no substantive alteration. The panel remanded for the district court to reassess causation and affirmed the dismissal of the fraud exception claim.