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San Rafael Aviation Accident Attorney

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Attorney Michael Rehm — (800) 978-0754

Aviation Accidents at San Rafael Airport

San Rafael Airport (CA35) is a small general aviation airstrip in Marin County serving personal aviation and light aircraft operations. Unlike most Bay Area airports, San Rafael Airport does not have a dedicated government operator website — it is a privately operated or minimally staffed facility. The airport sits near the shores of San Pablo Bay and is subject to the marine layer, coastal fog, and low ceilings that affect Marin County aviation conditions generally. The NTSB has investigated one fatal accident and three serious-injury accidents at San Rafael Airport since 1982.

Attorney Michael Rehm represents people injured in aviation accidents at San Rafael Airport and throughout Marin County.

NTSB Accident Record at San Rafael Airport

The following is drawn from the NTSB's CAROL accident database and represents historical investigation records only.

In July 2023, a Cessna 172N returning to San Rafael Airport from Nevada lost engine power on approach after carburetor ice accumulated during a prolonged descent without carburetor heat application (NTSB Accident Report No. WPR23FA258). The aircraft struck a powerline and impacted a water canal near the runway, killing one passenger and seriously injuring the pilot. The NTSB found the total loss of engine power was due to carburetor icing as a result of the pilot's failure to activate the carburetor heat during the descent. Carburetor heat application is a required pilot technique documented in the aircraft's operating handbook for conditions conducive to carburetor ice. Failure to apply it when conditions require is a failure to follow the aircraft manufacturer's own published procedures — direct evidence of pilot negligence.

The powerline struck during the forced landing raises an additional question: whether the powerline was properly marked or lit in a manner consistent with FAA obstruction marking standards applicable to structures in the approach path of a certificated airport. If the powerline was inadequately marked, the owner or utility company responsible for the powerline and the airport operator may bear concurrent liability alongside the pilot.

Three additional serious-injury accidents appear in the San Rafael record: a 2003 Piper PA-28-180 fuel exhaustion accident (LAX04LA004) and two 1986 accidents (LAX86LA189 and LAX86LA259) with causes not stated in the available CAROL records.

Liability at San Rafael Airport

Pilot Negligence — Carburetor Icing

The July 2023 accident (WPR23FA258) is a pilot negligence case. Carburetor icing is a well-documented, well-understood hazard in piston aviation. The conditions conducive to carburetor ice — specific combinations of temperature and humidity — are published in FAA advisory materials and in each carburetor-equipped aircraft's operating handbook. A pilot who descends through conditions that the handbook identifies as requiring carburetor heat application, without applying carburetor heat, has failed to operate the aircraft in accordance with its published procedures. Civil Code § 1714 imposes a duty of ordinary care on the pilot. Passengers aboard the aircraft have direct claims against the pilot and the aircraft owner.

Powerline Obstruction Liability

The powerline struck during the forced landing in the July 2023 accident raises separate liability questions. FAA Advisory Circular AC 70/7460-1 sets standards for obstruction marking and lighting for structures that penetrate navigable airspace near airports. An unmarked or inadequately lit powerline in the approach corridor of a certificated airport may constitute a dangerous condition. The utility company that owns the powerline and the airport operator both bear potential responsibility depending on the facts, the location of the powerline relative to the airport boundary, and whether prior notification of the obstruction had been provided to the airport or to the FAA.

Filing Deadlines for San Rafael Aviation Claims

The personal injury statute of limitations is two years under Code of Civil Procedure § 335.1. If claims are asserted against a public entity — including any county or city with responsibility for airport oversight or powerline permitting — a government tort claim under Government Code § 911.2 is required within six months. Missing this deadline can potentially bar a claim against any public entity defendant. Tolling may apply depending on the facts.

Related Pages

Attorney Michael Rehm represents aviation accident victims in San Rafael and throughout California on a contingency fee basis. No fee without a recovery. Call (800) 978-0754 to arrange a free consultation.

The information on this page is general legal information, not legal advice, and does not create an attorney-client relationship. Every case turns on its own facts. The law can change — statutes are amended, cases are decided, and regulations are revised; nothing on this page should be relied upon as a statement of current law without verification. Deadlines and legal bars discussed on this page are general guides — whether a particular deadline applies, has run, or is subject to tolling, and whether a particular doctrine bars or limits recovery in your case, requires individual analysis. Contact Attorney Michael Rehm to discuss the specific facts of your situation.

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