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Quill v. Trans World Airlines

Court of Appeals of Minnesota
361 N.W.2d 438 (1985)


Facts

Dean Abrahamson (plaintiff) was a non-practicing medical doctor who flew regularly for his work as a teacher and consultant. On April 4, 1979, Abrahamson took a flight from New York to Minneapolis operated by Trans World Airlines (TWA) (defendant). While cruising at 39,000 feet, the plane suddenly went into a tailspin. For 40 seconds, the plane plunged toward earth at just below the speed of sound. The passengers experienced the force of 6 Gs. Abrahamson was unable to lift his arms to grab his oxygen mask. The pilots regained control of the plane five seconds before it would have crashed into the ground and made a safe emergency landing in Michigan. After this experience, Abrahamson continued to travel regularly for business. However, he experienced anxiety on many of his flights, causing physical symptoms of adrenaline surges, sweaty hands, and an elevated pulse and blood pressure. Abrahamson, together with three other passengers, sued TWA for the negligent infliction of emotional distress. A jury found in favor of Abrahamson, awarding him $50,000 in damages. TWA moved for judgment notwithstanding the verdict. TWA argued, in part, that Abrahamson’s physical symptoms were insufficiently severe to recover for the negligent infliction of emotional distress. The trial court denied this motion, and TWA appealed.

Rule of Law

Issue

Holding and Reasoning (Leslie, J.)

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