Mary-Caitlin Ray

Partner | She/Her/Hers

Overview

A former attorney for the Federal Aviation Administration, Mary-Caitlin represents aircraft owners, operators, and manufacturers as well as investors into aviation related businesses, advising on regulatory and transactional matters. Her clients come to her for practical and strategic advice on navigating complex aviation challenges. She has significant experience advising clients on the impacts of and solutions for emerging technologies in the aviation sector, including uncrewed aircraft systems (UAS or drones) and electric vertical takeoff and landing (eVTOL) aircraft.

Mary-Caitlin’s practice spans the crewed and uncrewed side of the aviation world.

She has advised Fortune 500 flight departments, high net worth individuals, and manufacturers and suppliers on regulatory concerns related to the operation and production of aircraft, including complex issues related to permitted compensation, pilot licensing, operating structures such as dry leasing, timesharing and fractional ownership agreements, and emergency and Letter of Investigation response related to quality escapes and incidents. She also represents clients in the acquisition and sale of business aircraft, including cross-border transactions requiring the export or import of aircraft.

Mary-Caitlin counsels drone and eVTOL manufacturers, operators, and owners on all aspects of FAA regulatory compliance, including the business impacts of the evolving global regulatory framework for emerging aviation technologies. She also advises drone manufacturers and operators developing internal aviation-related corporate policies and best practices.

Mary-Caitlin has significant experience advising investors on the regulatory implications of investment into a wide array of aviation-related businesses, including MROs, manufacturers (including eVTOL manufacturers), and businesses that own and/or operate aircraft.

Career & Education

    • Department of Veterans Affairs
      Attorney-Advisor, 20132014
    • Federal Aviation Administration
      Attorney, Office of the Chief Counsel, 20142018
    • Department of Veterans Affairs
      Attorney-Advisor, 20132014
    • Federal Aviation Administration
      Attorney, Office of the Chief Counsel, 20142018
    • Washington and Lee University School of Law, J.D., 2012
    • Washington and Lee University, B.A., cum laude, 2009
    • Washington and Lee University School of Law, J.D., 2012
    • Washington and Lee University, B.A., cum laude, 2009
    • District of Columbia
    • Massachusetts
    • New York
    • Supreme Court of the United States
    • District of Columbia
    • Massachusetts
    • New York
    • Supreme Court of the United States
  • Professional Activities and Memberships

    • Chair, Young Lawyers Committee of the American Bar Association Forum on Air and Space Law
    • Young Lawyer Liaison to the American Bar Association Forum on Air and Space Law
    • Member, International Society of Transport Aircraft Trading
    • Member, Women in Aviation International
    • Vice Chair, ABA Section of Public Contract Law Young Lawyers Committee, 2017–2018

    Professional Activities and Memberships

    • Chair, Young Lawyers Committee of the American Bar Association Forum on Air and Space Law
    • Young Lawyer Liaison to the American Bar Association Forum on Air and Space Law
    • Member, International Society of Transport Aircraft Trading
    • Member, Women in Aviation International
    • Vice Chair, ABA Section of Public Contract Law Young Lawyers Committee, 2017–2018
    • Mandarin
    • Mandarin

Mary-Caitlin's Insights

Client Alert | 5 min read | 01.29.26

FAA Invites Fresh Input on Expansive Drone Rule

On January 28, 2026, the Federal Aviation Administration (FAA) announced that it would reopen the comment period for the Notice of Proposed Rulemaking (NPRM) titled “Normalizing Unmanned Aircraft Systems Beyond Visual Line of Sight Operations” for fourteen days. This NPRM, jointly published with the Transportation Security Administration (TSA) on August 7, 2025, introduces performance-based regulations for beyond visual line of sight (BVLOS) unmanned aircraft systems (UAS) operations and the third-party services that support them. Although the NPRM’s initial comment period closed on October 6, 2025, the FAA is now accepting additional feedback through February 11, 2026, with a particular focus on the proposed rule’s right-of-way and detect-and-avoid requirements. The FAA previously rejected formal requests to extend the initial comment period, citing the deadline imposed by Executive Order 14307....

Representative Matters

  • Advised small UAS operators on FAA operating and registration rules, including counseling on new and upcoming FAA rulemakings affecting sUAS operations.
  • Advised UAS manufacturers on compliance with remote identification regulations.
  • Drafted internal UAS use and remote identification policies for commercial UAS operators and manufacturers.
  • Represented buyers and sellers in numerous aircraft purchase and sale transactions.
  • Advised clients on negotiated lease documents related to Part 91 operations.
  • Represented numerous private equity funds in conducting transactional due diligence and counseling related to the acquisition and sale of aviation related businesses, including Maintenance and Repair Organizations, manufacturers, aircraft owners and operators, and UAS and eVTOL manufacturers and operators.
  • Counseled numerous FAA certificate holders, including PMA and Part 145 Repair Station Certificate holders, on responses to FAA investigations and audits.

Mary-Caitlin's Insights

Client Alert | 5 min read | 01.29.26

FAA Invites Fresh Input on Expansive Drone Rule

On January 28, 2026, the Federal Aviation Administration (FAA) announced that it would reopen the comment period for the Notice of Proposed Rulemaking (NPRM) titled “Normalizing Unmanned Aircraft Systems Beyond Visual Line of Sight Operations” for fourteen days. This NPRM, jointly published with the Transportation Security Administration (TSA) on August 7, 2025, introduces performance-based regulations for beyond visual line of sight (BVLOS) unmanned aircraft systems (UAS) operations and the third-party services that support them. Although the NPRM’s initial comment period closed on October 6, 2025, the FAA is now accepting additional feedback through February 11, 2026, with a particular focus on the proposed rule’s right-of-way and detect-and-avoid requirements. The FAA previously rejected formal requests to extend the initial comment period, citing the deadline imposed by Executive Order 14307....

Recognition

  • Chambers USA: Up and Coming, Transportation: Aviation: Regulatory - Nationwide, 2025
  • Lexology Index: Transport, 2023-2026
  • National Business Aviation Association (NBAA): Business Aviation Top 40 Under 40 Award, 2023

Mary-Caitlin's Insights

Client Alert | 5 min read | 01.29.26

FAA Invites Fresh Input on Expansive Drone Rule

On January 28, 2026, the Federal Aviation Administration (FAA) announced that it would reopen the comment period for the Notice of Proposed Rulemaking (NPRM) titled “Normalizing Unmanned Aircraft Systems Beyond Visual Line of Sight Operations” for fourteen days. This NPRM, jointly published with the Transportation Security Administration (TSA) on August 7, 2025, introduces performance-based regulations for beyond visual line of sight (BVLOS) unmanned aircraft systems (UAS) operations and the third-party services that support them. Although the NPRM’s initial comment period closed on October 6, 2025, the FAA is now accepting additional feedback through February 11, 2026, with a particular focus on the proposed rule’s right-of-way and detect-and-avoid requirements. The FAA previously rejected formal requests to extend the initial comment period, citing the deadline imposed by Executive Order 14307....

Mary-Caitlin's Insights

Client Alert | 5 min read | 01.29.26

FAA Invites Fresh Input on Expansive Drone Rule

On January 28, 2026, the Federal Aviation Administration (FAA) announced that it would reopen the comment period for the Notice of Proposed Rulemaking (NPRM) titled “Normalizing Unmanned Aircraft Systems Beyond Visual Line of Sight Operations” for fourteen days. This NPRM, jointly published with the Transportation Security Administration (TSA) on August 7, 2025, introduces performance-based regulations for beyond visual line of sight (BVLOS) unmanned aircraft systems (UAS) operations and the third-party services that support them. Although the NPRM’s initial comment period closed on October 6, 2025, the FAA is now accepting additional feedback through February 11, 2026, with a particular focus on the proposed rule’s right-of-way and detect-and-avoid requirements. The FAA previously rejected formal requests to extend the initial comment period, citing the deadline imposed by Executive Order 14307....