Moreover, our review of cases from other jurisdictions reflects consistency in the principle that airplanes are not dangerous instrumentalities and that aviation is not an ultrahazardous activity. See , e.g ., Garland v. Sybaris Clubs Int'l, Inc ., 2019 IL App (1st) 180682, ¶ 31, 435 Ill.Dec. 921, 141 N.E.3d 730, 748 ("an airplane is not an inherently dangerous article, [although] it may become so if operated by a pilot who is incompetent, inexperienced, or reckless"); Wilson v. Greg Williams Farm, Inc ., 2014 Ark. App. 334, 5-6, 436 S.W.3d 485, 489 (2014) (quoting Little v. McGraw , 250 Ark. 766, 769, 467 S.W.2d 163 (1971) ("[a]viation is now so commonplace that it cannot be considered to be either inherently dangerous or ultrahazardous"); Joshi v. United States , 2009 WL 2449234, at *5 (N.D. Ind. Aug. 6, 2009) ("an aircraft does not qualify as a dangerous instrumentality"); Lange v. Nelson-Ryan Flight Serv., Inc. , 263 Minn. 152, 157, 116 N.W.2d 266, 270 (1962) ("Technical progress in the art of flying has reached a point where an airplane cannot be regarded as a dangerous instrumentality per se"); Wood v. United Air Lines, Inc ., 32 Misc. 2d 955, 960, 223 N.Y.S.2d 692, 697 (Sup. Ct. 1961) ("flying should no longer be deemed to be an ultrahazardous activity, requiring the imposition of absolute liability for any damage or injury caused in the course thereof.

As a general rule of appellate procedure, however, a denial of a motion for summary judgment is not subject to review on appeal, even after a trial on the merits. See Wilson v. Greg Williams Farm, Inc., 2014 Ark. App. 334, 436 S.W.3d 485 (citing Get Rid of It Ark., Inc. v. Hughes, 368 Ark. 535, 247 S.W.3d 838 (2007) ). Thus, to the extent J.C. contends that the circuit court should have treated his dismissal motion as one for summary judgment and granted it in his favor, we do not address his argument.