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45 CONCLUSION This digest presents basic principles and sample cases concerning an airport proprietorâs duty and standard of care in an aircraft accident setting. The issues in any given case can vary significantly due to differences in state law and among federal circuit courts on a wide range of issues. However, this digest provides a starting point to assist proprietors as they consider proactive measures or review issues after an accident occurs. where the trees were located. The plaintiff passen- ger also sued the landowner.369 The court considered state laws discussing aircraft and tree heights but did not consider them to establish a duty of care for the landowner. The court also determined that the landowner did not have a duty of reasonable care to trim the trees under Maryland law and that when pilots fly at low altitudes over anotherâs property, the pilot is invading the ownerâs property, making the pilot a trespasser. The landownerâs common law duty to trespassers only requires the landowner to refrain from willful and wanton conduct. 369 Walsh v. Avalon Aviation, Inc., 31 F. Appâx 818 (4th Cir. 2002) (unpublished).