In Re: LATAM Airlines Group S.A.

CourtDistrict Court, S.D. New York
DecidedJuly 25, 2023
Docket1:22-cv-08068
StatusUnknown

This text of In Re: LATAM Airlines Group S.A. (In Re: LATAM Airlines Group S.A.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re: LATAM Airlines Group S.A., (S.D.N.Y. 2023).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

In re:

LATAM AIRLINES GROUP S.A., et al.,

Debtors. OPINION AND ORDER TM SOLUTIONS USA LLC, 22-cv-8068 (ER) Plaintiff-Appellant,

– against –

LATAM AIRLINES GROUP S.A.,

Defendant-Appellee.

Ramos, D.J.: This is an appeal from an August 31, 2022, Order of the Bankruptcy Court (Garrity, J), which granted the motion of LATAM Airlines Group S.A. (“LATAM”) to dismiss the adversary proceeding filed by TM Solutions USA LLC (“TM Solutions”), and denied its motion to amend the complaint with prejudice. See generally Doc. 1; see also Bankr.Doc. 1; Bankr.Doc. 33.1 In short, the complaint alleged that LATAM improperly “cancel[ed] tickets for flights that customers already paid for, without their consent, in order to resell them and enrich itself—all at the expense of stranded consumers.” Bankr.Doc. 1 at 2. For the reasons set forth below, the Order of the Bankruptcy Court is AFFIRMED.

1 References to “Bankr.Doc.” refer to documents filed in the underlying adversary bankruptcy proceeding, In Re LATAM Airlines Group, S.A., et al., No. 20-01207 (JLG), (Bankr. S.D.N.Y. 2020). References to “Doc.” refer to documents filed in the instant appeal. I. BACKGROUND A. Factual Background2 Pedro Egusquiza (“Egusquiza”), the owner and manager of TM Solutions, and his colleague, Andres Guerrero (“Guerrero”), were scheduled to travel from Lima, Peru, to Miami, Florida for business meetings on February 19, 2020.3 Bankr.Doc. 1 ¶¶ 1, 9, 11.

Egusquiza’s assistant, Talia Peschiera (“Peschiera”), purchased roundtrip tickets for both of them on February 14, 2020, which totaled $2,280. Id. ¶¶ 11, 12. �e tickets were purchased through BudgetAir.com (“BudgetAir”), an online retailer through which LATAM sells its flights. Id. ¶ 13. However, Peschiera inadvertently purchased the outbound4 flights—those from Lima, Peru, to Miami—for the wrong date. Id. ¶ 11. To address the error, Peschiera contacted the customer service center of BudgetAir. Id. ¶ 13. �e BudgetAir representative told Peschiera that replacement tickets for the flights were an additional $1,800, and that she could call LATAM to solve the problem. Id. When Peschiera called

LATAM, however, she was instructed to call BudgetAir to resolve the problem. Id. ¶ 14. “Given the useless back-and-forth from one entity to the other, and after multiple calls, Peschiera proceeded to look for flights on the internet to replace the mistakenly

2 �e Federal Rules of Civil Procedure apply to the instant case pursuant to Rule 7012(b) of the Federal Rules of Bankruptcy Procedure. In reviewing dismissal of a complaint pursuant to Rule 12(b)(6), the Court takes as true all of the allegations contained in the complaint and draws all inferences in favor of the plaintiff. Weixel v. Bd. of Educ. of City of New York, 287 F.3d 138, 145 (2d Cir. 2002). When considering a motion to dismiss for failure to state a claim, the Court may consider documents attached to the complaint as exhibits, as well as documents incorporated by reference in the complaint. DiFolco v. MSNBC Cable L.L.C., 622 F.3d 104, 111 (2d Cir. 2010) (citing Chambers v. Time Warner, Inc., 282 F.3d 147, 153 (2d Cir. 2002)). 3 �ey were scheduled to return on February 21, 2023. Bankr.Doc. 1 ¶ 11. 4 While the complaint calls these flights the “inbound” flights, the airline policies make clear that the first segment in the itinerary is called the “outbound” flight.” Compare Bankr.Doc. 1 ¶¶ 11, 21 with Bankr.Doc. 9-1 at 5 (stating that the first segment of a specified itinerary is understood to be the “outbound” flight). purchased [] flights [from Lima to Miami],” with the presumption that Egusquiza and Guerrero could nevertheless utilize the tickets for the return trip originally booked through LATAM. Id. ¶ 15. Peschiera found replacement flights through American Airlines for $420 each, and she purchased them with Egusquiza’s approval. Id. ¶ 16.

When Peschiera informed LATAM and BudgetAir of the changes, id. ¶¶ 17, 19, she was not told “that this would be a problem, or that it would have any impact on the existing reservation,” id. ¶ 18. However, when Peschiera attempted to complete the check-in for Egusquiza and Guerrero’s LATAM return flight from Miami to Lima, “there was no available reservation with the original LATAM reservation code.” Id. ¶ 20. �ereafter, Peschiera contacted both LATAM and BudgetAir, which both informed her that “it is the policy of LATAM to cancel complete reservations ([i.e.,]the entire roundtrip) once a passenger does not board the [out]bound flight (a so-called ‘no-show’ policy).”5 Id. ¶ 21. Peschiera asked to speak with supervisors at LATAM, but “they would not speak to her.” Id. Neither TM

5 �e policy states as follows: �e passenger must fly the flights or segments that make up the itinerary in consecutive order. Based on the terms and conditions in the applicable legislation, the Carrier may deny boarding to a passenger who does not follow the order of the previously mentioned itinerary or if the passenger has not flown any of the segments indicated in the itinerary. �e passenger understands that by not flying any segments indicated in the itinerary, the entire [t]icket will be cancelled without any warning and the passenger will not have any right whatsoever to a refund unless the fare conditions of the [t]icket allow it. As an example, and without this condition being limited to this specific case, if the passenger does not fly on the first segment that is specified in the itinerary (understood as the outbound flight), this passenger may not travel on any other segment (understood as the stopover flight or the inbound flight). Doc. 9-1 at 4–5. Additionally, the terms and conditions set forth by BudgetAir indicate that when customers “reserve or purchase Travel Products via our Services, additional terms and conditions from the [s]uppliers [] may apply.” Doc. 9-3 at 4. LATAM attached these documents to its brief, see generally Doc. 9, and the Bankruptcy Court also discussed the policies in its Order, Bankr.Doc. 33 at 7–8. Solutions nor its agents “t[old] LATAM that it could resell the return flights that had already been paid for by TM Solutions.” Id. ¶ 25. �ereafter, Peschiera proceeded to purchase new flights for Egusquiza and Guerrero. Id. ¶ 22. Unable to find direct flights, Peschiera purchased return tickets

through Avianca—a separate airline—which connected through Bogota, Colombia, and added additional time to the trip. Id. ¶ 23. �e cost of the new tickets from Miami to Lima was $1,526. Id. TM Solutions sought to certify the action as a class action pursuant to Rule 23 of the Federal Rules of Civil Procedure, and it proposed the following classes: All residents of the States of California, Florida, Massachusetts, New York, and the District of Columbia who purchased a roundtrip ticket with LATAM whose flights were cancelled by LATAM without their consent within the applicable limitations period.

All residents of the State of Florida who purchased a roundtrip ticket with LATAM whose flights were cancelled by LATAM without their consent within the applicable limitations period.

Id. ¶¶ 29–30; see also id. ¶¶ 31–40.

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In Re: LATAM Airlines Group S.A., Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-latam-airlines-group-sa-nysd-2023.