An aviation client received a civil penalty enforcement action from the Federal Aviation Administration (FAA) totaling nearly $250,000. Husch Blackwell conducted an in-depth review of the client’s historical records and identified multiple instances in which the FAA had effectively ratified the same conduct that was the basis for its penalty.
Working closely with the client’s ownership team, our attorneys conducted an informal settlement conference with the FAA’s legal department at which the agency’s historical role in the conduct was addressed. Based on our knowledge of the FAA’s regulations and supplemental compliance documents, the FAA agreed to reduce the penalty by 79 percent, resulting in savings for the company’s bottom line while avoiding unfavorable media coverage.
Husch Blackwell Team: David C. Agee and Erik Dullea