In Beech Aircraft Corp. v. Rainey, 488 U.S. 153 (1988), widows of deceased Navy pilots sued the manufacturer of the airplanes they believed malfunctioned in a Navy training exercise causing their husbands' deaths. Id. at 156. The application of rule 803(8) became a point of contention when the defense sought to introduce an investigative report of the crash that had been ordered by the commanding officer of the training squadron in which the deceased pilots served. Justice Brennan's majority opinion tracked closely our methodology and result. It relied on the "traditional tools of statutory construction"--plain language meaning--to interpret rule 803(8)(C). Id. at 161-70. Justice Brennan first turned away an attempt to rein in the application of rule 803 (as the State seeks to in this case) by exploiting a "perceived dichotomy between 'fact' and 'opinion' in arguing for the limited scope of the phrase 'factual finding.'" Id. at 163. He reasoned that "it is not apparent that the term 'factual findings' should be read to mean simply 'facts.'" Id. at 163-64. Justice Brennan, too, looked to Black's definition of "finding of fact" as "[a conclusion by way of reasonable inference from the evidence." Id. (citing Black's Law Dictionary 569 (5th ed. 1979)). Drawing on this definition, Justice Brennan reasoned that "the language of the Rule does not compel us to reject the interpretation that 'factual findings' includes conclusions or opinions that flow from a factual investigation." Id. at 164. Based on a plain review of the text, he felt that it is clear "the language of the Rule does not state that 'factual findings' are admissible, but that 'reports . . . setting forth . . . factual findings are admissible.'" Id. The Court held that this common-law rule survived the enactment of the Federal Rules of Evidence. The Court declared it "obvious" that "when one party has made use of a portion of a document, such that misunderstanding or distortion can be averted only through presentation of another portion, the material required for completeness is ipso facto relevant and therefore admissible under Federal Evidence Rules 401 and 402" (Beech Aircraft, 488 U.S. at 172.)