Air France v. Saks
Headline: Court limits airline liability by ruling that only unexpected, external events count as "accidents" under the Warsaw Convention, making routine pressurization injuries harder for passengers to win against airlines.
Holding: The Court held that under Article 17 of the Warsaw Convention, airlines are liable only when a passenger's injury is caused by an unexpected or unusual external event, not by normal operation of the aircraft.
- Makes it harder for passengers to win claims for routine pressure-related injuries.
- Limits airline liability to injuries from unexpected, external events.
- Leaves state-law negligence claims for lower courts to consider on remand.
Summary
Background
Valerie Saks, a passenger on an Air France flight, lost hearing in one ear after the plane descended to Los Angeles. She sued Air France in state court, saying negligent maintenance or operation of the plane’s pressurization system caused her permanent hearing loss. Air France argued the injury resulted from normal pressurization and therefore was not an "accident" under Article 17 of the Warsaw Convention. A federal district court granted summary judgment for the airline; a divided Ninth Circuit reversed, adopting a broader definition of "accident." The Supreme Court granted review to resolve that disagreement.
Reasoning
The Court addressed whether an injury caused by normal aircraft operation qualifies as an "accident" under Article 17. Relying on the treaty text (including the French original), the drafting history, and how other signatory nations interpret the term, the Court concluded Article 17 requires that the injury be caused by an unexpected or unusual event external to the passenger. The Court explained that the Convention’s separate wording for baggage ("occurrence") and passengers ("accident") shows a deliberate distinction. Because routine pressurization is the plane’s normal operation and the injury arose from the passenger’s internal reaction, it did not meet the Court’s accident test. The Court reversed the Ninth Circuit and returned the case for further proceedings.
Real world impact
The ruling narrows when airlines can be held liable under Article 17: liability requires proof of an external, unusual event causing the harm. The Montreal Agreement did not remove this "accident" requirement. The Court left open a state-law negligence claim for the lower courts to consider on remand.
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