Love

MEMORANDUM **

John D. Love, owner and director of several General Motors’ (GM) dealerships (the Dealerships), was killed in a balloon accident in Arizona at a party GM organized for successful Chevrolet dealerships. After his death, the Love Dealerships sued *809 GM on a variety of theories. The Dealerships sought damages for Love’s post-accident medical expenses as well as for the economic harm caused to the Dealerships by Love’s death. The district court rejected the Dealerships’ claims, holding that Arizona law did not allow an employer to recover for damages stemming from the negligent death of an employee. We affirm.

I. Background

John D. Love was dealer and owner of multiple automobile franchises. In 1996, GM hosted an awards event in Arizona for representatives of its top dealerships, which Love attended. One of the attractions at the awards event was hot air balloon rides. The Dealerships allege that the balloon rides were over-booked, causing the balloon company to acquire an additional, defective balloon. Love died when the defective balloon malfunctioned.

GM moved to dismiss the case brought by the Dealerships, arguing, inter alia, that Arizona law did not allow an…