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Ehrlich v. American Airlines

360 F.3d 366 (2004)

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Ehrlich v. American Airlines

United States Court of Appeals for the Second Circuit

360 F.3d 366 (2004)

Facts

In 1999, Gary and Maryanne Ehrlich (plaintiffs) were passengers on a flight operated by American Eagle Airlines, Inc. (American Eagle) (defendant) to New York, where the couple planned to take a connecting flight operated by American Airlines, Inc. (American) (defendant) to London. However, while landing, the aircraft overshot the runway and was dragged to a stop by an arrestor bed as the aircraft headed toward the waters of an adjoining bay. The passengers then had to jump out of the aircraft’s doorway to the ground six to eight feet below. Both Ehrlichs suffered physical injuries as a result of the landing and the evacuation jump. In addition, both Ehrlichs suffered mental distress as a result of fear caused by the abnormal landing. The Ehrlichs sued American, American Eagle, and a third airline under the Warsaw Convention, seeking damages for their physical and mental injuries. The district court granted partial summary judgment to the airlines on the Ehrlichs’ mental-injury damages, finding that (1) the Ehrlichs’ mental injuries were not caused by their physical injuries and (2) the Warsaw Convention did not allow damages for mental injuries that were not caused by covered physical injuries. The Ehrlichs appealed the dismissal of their mental-injury damages.

Rule of Law

Issue

Holding and Reasoning (Meskill, J.)

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