Beech Aircraft Corp. v. Rainey

A Navy training aircraft crashed, killing the pilot and co-pilot. Their spouses sued Beech Aircraft, the manufacturer. A Navy JAG investigation concluded that the most probable cause of the crash was pilot error, not a mechanical defect. The surviving spouses sought to exclude the JAG report's opinion on the cause of the crash, arguing that Rule 803(8)(C) only permits admission of 'factual findings' and not opinions or conclusions.

Justice Brennan, writing for the majority, reasoned that the language of Rule 803(8)(C) and its legislative history did not support a narrow reading limited to bare facts. Investigative reports necessarily involve conclusions drawn from underlying data; to admit the data but exclude the conclusions would make the exception largely meaningless. The Court looked to the Advisory Committee Notes, which identified factors for assessing the trustworthiness of investigative reports: the timeliness of the investigation, the investigator's skill and experience, whether a hearing was held, and possible motivation problems. The Court also addressed Rule 106, the rule of completeness, holding that when part of a document is introduced, the opponent may require introduction of other parts that in fairness ought to be considered contemporaneously.

Beech Aircraft significantly expanded the practical utility of the public records exception by allowing admission of the conclusions and opinions contained in government investigative reports. The decision is routinely cited when parties dispute whether a government report's conclusions are admissible. It also clarified the operation of Rule 106, the rule of completeness. The broad reading of 'factual findings' has been applied to police reports, OSHA investigations, NTSB findings, and numerous other government investigative documents.