Stagl v. Delta Air Lines

Eleanor Stagl (plaintiff) was a passenger on a flight operated by Delta Air Lines, Inc. (Delta) (defendant). In the baggage-claim area, the flight’s passengers were pushing and shoving to retrieve bags. Delta did not provide any signs or personnel to discourage this behavior. In the chaos, a bag was bumped into Stagl, knocking her down and breaking her hip. Stagl sued Delta for negligence. The trial court found that Delta did not owe Stagl a duty to maintain a safe baggage-retrieval area and granted summary judgment to Delta. Stagl appealed. The appellate court found that Delta did owe Stagl a duty, and the case was remanded for trial. At trial, the court excluded Stagl’s evidence about the airport conditions around the baggage carousel as irrelevant. The trial court also excluded testimony from Stagl’s expert mechanical-engineer witness because, although the witness had expertise in human-machine interactions, he did not have specific experience with airline-baggage systems. At the end of the trial, the trial court directed a verdict for Delta on the grounds that Stagl had not presented any evidence of similar, prior accidents. The trial court believed that prior-accident evidence was necessary to show that the accident was foreseeable, which was an element of Stagl’s negligence claim. Stagl appealed the evidentiary rulings and the directed verdict.