First Nat. Bank of Chicago v. United Air Lines, Inc.

Background

An Illinois bank, acting as the executor for a man killed in a Utah airplane crash, sued United Air Lines in a federal court in Illinois seeking $200,000 under Utah’s wrongful-death law. The parties satisfied federal diversity and amount requirements, but Illinois law then in force barred suits in Illinois for deaths that happened elsewhere if the defendant could be served in the state where the death occurred.

Reasoning

The main question was whether Illinois could refuse to enforce a wrongful-death claim that arose in another state. The Court relied on its recent decision about a similar Wisconsin law and held that Illinois’ statute violated the Constitution’s requirement that states respect and give effect to other states’ laws. Because Illinois’ exclusion of these out-of-state death claims was forbidden, the lower courts should not have dismissed the case, and the matter was sent back for further proceedings.

Real world impact

The ruling means states may not shut their courts against wrongful-death claims simply because the death occurred elsewhere when the defendant could be sued in that other state. Practically, families hurt by out-of-state deaths can bring claims in states that would otherwise try to exclude them, and federal courts hearing diversity cases cannot apply a state rule that completely bars such suits. The decision lets this specific Utah-crash claim move forward in the Illinois forum.

Dissents or concurrances

A Justice concurred in the result but preferred to ground the outcome on federal jurisdiction law, arguing federal courts have independent power to hear such diversity cases; two Justices dissented, opposing extension of the prior ruling to force states to hear these suits.