--- title: "Aviation Maintenance Expert Was Not Allowed to Opine on Agency Relationship" meta: "og:description": "While the aviation maintenance expert may testify about the documents he reviewed as a basis for his report, his opinions regarding any agency relationship between parties were struck" "og:title": "Aviation Maintenance Expert Was Not Allowed to Opine on Agency Relationship " author: "Shuva Guha Thakurta" description: "While the aviation maintenance expert may testify about the documents he reviewed as a basis for his report, his opinions regarding any agency relationship between parties were struck" --- # Aviation Maintenance Expert Was Not Allowed to Opine on Agency Relationship Posted on July 30, 2026 by Shuva Guha Thakurta This case arises from a ground collision between two aircraft at the Deming Municipal Airport on December 15, 2022. Plaintiff's parked Valmet A-90 Raider ("Valmet") was struck by an Aeronca 65CA Super Chief ("Aeronca"), and Plaintiff alleged that Defendants' negligence is to blame. On the day of the collision, Defendant Collin Hadley landed the Aeronca, a plane owned by Defendant Jones, at the Deming Municipal Airport to refuel. At the time, Defendant Desert Aviation, LLC ("Desert") was the operator of the Deming Municipal Airport. After refueling, Defendant Hadley asked Defendant Tony Jayne, an airport employee, to help him "hand-prop" the Aeronca. To do this, Defendant Jayne sat in the pilot's seat while Defendant Hadley spun the propeller by hand. Once the Aeronca's engine started, Defendant Jayne lost control of the aircraft despite Defendant Jayne's attempts to steer and apply the brakes. As a result, the Aeronca collided with Plaintiff's parked Valmet. Desert and Defendant Jayne retained [Steve Magginetti](https://expertwitnessprofiler.com/expert-witness/Steven-Magginetti/1577996) as an expert on airplane mechanics and accident reconstruction and investigation. Defendant William Cody Jones sought to strikes Magginetti's opinions, arguing that "they are unreliable, irrelevant, and completely steeped in baseless conjecture." ![Aviation Maintenance Expert Was Not Allowed to Opine on Agency Relationship ](https://media.jurimatic.com/images/blog_pic_640X480_2026_07_30T195621_2651.webp) ## **Aviation Maintenance Expert Witness** [Steve J. Magginetti](https://expertwitnessprofiler.com/expert-witness/Steven-Magginetti/1577996) is a graduate of the University of Southern California's Viterbi School of Engineering and has been "involved in aviation maintenance for over 50 years." He specializes in airplane "accident reconstruction and investigation," has investigated "over 400 accidents or incidents," and has hand-propped "an estimated 150 to 200 different aircraft." He has also served as an expert "in Federal, State, and county courts." [Want to know more about the challenges Steve Magginetti has faced? Get the full details with our Challenge Study report](https://expertwitnessprofiler.com/order/add?eId=1577996&pId=3). ## **Discussion by the Court** ### **A. Magginetti is qualified to serve as an expert** As an initial matter, the Court concluded that Magginetti is qualified to serve as an expert witness in this case. Indeed, no party argued that Magginetti is not qualified to render an opinion as an aircraft maintenance and compliance expert. ### **B. Magginetti's opinions are generally reliable** Here, Magginetti provided seventeen opinions at the conclusion of his report. Namely, that the Aeronca was in an "un-airworthy condition on December 15, 2022," and that that condition was "the responsibility of Jones." In addition, Magginetti opined that the "root cause of the accident was a human factor: failure of [Hadley] to utilize wheel chock and tie down the tail contrary to FAA-published procedures" and that "Hadley had a historic practice of using careless and reckless practices in starting the engine." To prepare his report, Magginetti "compared aircraft operations as prescribed by the FAA, 14 CFR part 91, and 61 regulations and his empirical knowledge" "to the events that occurred on or around December 15, 2022, in Deming, NM." Magginetti reviewed more than thirty documents for his report, including "FAA Aeronca Airworthiness and Registration files," "disclosures" from the parties involved in the accident, including Desert and Defendant Jayne, the "NTSB report," and the "state of New Mexico Incident Report." He additionally reviewed Defendant Hadley's "flight logs" and the Aeronca's "Pilot Operations Handbook" as well as disclosures and interrogatories from all parties. The Court is satisfied that Magginetti's methodology is generally grounded in his "professional experience, education, training, and observations." There is no analytical gap between his methods and his conclusions about the events that took place on the day of the collision. The Court concluded that Magginetti's opinions are generally reliable. ### **C. Defendant Jones' request to bar certain testimony is granted in part and denied in part** Defendant Jones also sought to limit seven of Magginetti's specific opinions. First, he sought to preclude "opinions regarding the legal status of Defendant Jones as the 'operator' of the aircraft." The Court agreed and struck those opinions from the report. The Court previously granted summary judgment in this case. The crux of that Order was a determination that Defendant Jones was not in "operational control" of the Aeronca for purposes of liability. Further testimony on whether Defendant Jones was the "operator" of the Aeronca is irrelevant to the trier of fact and is also unhelpful. Second, Defendant Jones sought to limit testimony about "the existence of any agency relationship between Defendant Jones and Defendant Hadley." The Court agreed. Magginetti's expertise in airplane maintenance did not extend to concluding whether agency relationships exist between parties. Such testimony is not relevant. While Magginetti may testify as to the documents he reviewed as a basis for his report, his opinions regarding any agency relationship between Defendants Jones and Hadley are struck from the report. Third, Defendant Jones sought to prohibit testimony that he had "any obligation...to incorporate Supplemental Type Certificates (STC's) through the installation of aftermarket systems, or that such systems could have decreased the likelihood that this incident could have occurred." The Court agreed in part. While Magginetti may not testify to the issue of causation in this case, which is for the jury to decide, he may provide his technical opinion on the use of Supplemental Type Certificates and their general effect on reducing collisions. Fourth, Defendant Jones sought to bar any testimony on "the airworthiness of the [Aeronca] or the alleged irrelevant service and reporting failures identified in his report." The Court disagreed. Questions about the Aeronca's airworthiness on the date of the accident are relevant, and Magginetti's qualifications permit his testimony on the topic. Fifth, Defendant Jones sought to prohibit "opinions regarding the existence of a mechanical defect in the throttle or brakes of the aircraft." He argued that Magginetti's opinion of a defect "ignores contradictory statements" made by others and should be prohibited. The Court disagreed. The "focus" of a [_Daubert_](https://www.law.cornell.edu/wex/daubert_standard) inquiry "must solely be on principles and methodology, not on the conclusions that they generate." Arguments regarding the basis of Magginetti's conclusions go to the weight of the evidence, not its admissibility. Sixth, Defendant Jones sought to prohibit "opinions regarding the existence of a prior runaway event or its purported cause." He argued that Defendant Hadley "denies having any other runaway incidents" and that to "suggest that Defendant Hadley was careless or reckless because of an alleged previous runaway incident...is disingenuous." The Court agreed. Magginetti lacked a proper foundation—his opinion is not based on any mechanics reports but relies on "personal information of a hearsay nature" to form his opinion. Finally, Defendant Jones sought to bar "opinions regarding the 'root cause' of the accident being a failure to utilize wheel chocks and tie downs contrary to FAA-published procedures." The Court disagreed. Magginetti's expertise includes compliance and best practices in line with FAA regulations. His opinion that the accident resulted from Defendant Hadley's failure to follow those procedures is grounded in his specialized knowledge of aircraft maintenance and experience with accident investigation. ## **Held** The Court granted in part and denied in part Jones' motion to strike the testimony of Steve Magginetti. ## **Key Takeaway** [Rule 702](https://www.law.cornell.edu/rules/fre/rule_702#:~:text=Rule%20702%20sets%20forth%20the,is%20a%20relatively%20narrow%20inquiry.) and _Daubert_ do not require an expert to have firsthand knowledge, they only require that the evidence be relevant and reliable. ## **Case Details:** | Case Caption: | Blue Air Training Corporation V. Hadley | | --- | --- | | Docket Number: | 2:23cv734 | | Court Name: | United States District Court, New Mexico | | Order Date: | July 28, 2026 | --- ## **You Might Also Like** ![Aviation Maintenance Expert Was Not Allowed to Opine on Agency Relationship ](https://media.jurimatic.com/images/blog_pic_640X480_2026_07_30T195621_2651.webp) [**Aviation Maintenance Expert Was Not Allowed to Opine on Agency Relationship **](https://expertwitnessprofiler.com/aviation-maintenance-expert-was-not-allowed-to-opine-on-agency-relationship-/aviation-maintenance-expert-was-not-allowed-to-opine-on-agency-relationship-)![Insurance Expert Partly Allowed to Opine on Insurer's Conduct](https://media.jurimatic.com/images/blog_pic_640X480_2026_07_30T174321_361.webp) [**Insurance Expert Partly Allowed to Opine on Insurer's Conduct**](https://expertwitnessprofiler.com/aviation-maintenance-expert-was-not-allowed-to-opine-on-agency-relationship-/insurance-expert-partly-allowed-to-opine-on-insurers-conduct)![Radiation Oncology Expert Not Allowed to Opine on the Risks of Alleged Exposure](https://media.jurimatic.com/images/blog_pic_640X480_2026_07_29T200732_639.webp) [**Radiation Oncology Expert Not Allowed to Opine on the Risks of Alleged Exposure**](https://expertwitnessprofiler.com/aviation-maintenance-expert-was-not-allowed-to-opine-on-agency-relationship-/radiation-oncology-expert-not-allowed-to-opine-on-the-risks-of-alleged-exposure)![Sexual Abuse Expert Allowed to Opine on Culpability](https://media.jurimatic.com/images/blog_pic_640X480_2026_07_29T180748_5521.webp) [**Sexual Abuse Expert Allowed to Opine on Culpability**](https://expertwitnessprofiler.com/aviation-maintenance-expert-was-not-allowed-to-opine-on-agency-relationship-/sexual-abuse-expert-allowed-to-opine-on-culpability)![Transportation Safety Expert Not Allowed to Opine on the Non-Preventability of the Crash](https://media.jurimatic.com/images/blog_pic_640X480_2026_07_28T202402_4131.webp) [**Transportation Safety Expert Not Allowed to Opine on the Non-Preventability of the Crash**](https://expertwitnessprofiler.com/aviation-maintenance-expert-was-not-allowed-to-opine-on-agency-relationship-/transportation-safety-expert-not-allowed-to-opine-on-the-non-preventability-of-the-crash)