Eastern Airlines, Inc. v. Floyd

Background

A group of passengers sued Eastern Airlines after a May 5, 1983 flight experienced engine failures and nearly had to ditch in the Atlantic before landing safely. The passengers sought money only for the mental distress they suffered during the incident. Lower courts split on the question. The Eleventh Circuit allowed recovery for purely psychic injury, while other courts had rejected such claims. The Supreme Court took the case to resolve that conflict.

Reasoning

The Court asked whether Article 17 of the Warsaw Convention covers mental or psychic injuries when no physical injury or physical sign appears. The Justices started with the French text of the treaty and relied on dictionaries, French legal sources, the Convention’s negotiating history, and later international practice. The Court found that the term used in French, lésion corporelle, is best read as “bodily injury.” The Court also noted many countries in 1929 did not recognize compensation for purely mental harms and that the Convention aimed to limit carrier liability to promote aviation. For those reasons, the Court concluded Article 17 does not permit recovery for purely mental injuries.

Real world impact

The decision means passengers on international flights cannot recover under Article 17 for fear, shock, or other purely emotional harms unless there is physical injury or a physical sign of injury. The Court left open claims tied to physical injury and did not decide whether the Warsaw Convention is the exclusive remedy. The judgment reverses the Eleventh Circuit and narrows treaty-based recovery for emotional-distress claims.