Janesch v. Frontier Airlines, Inc.

2024 Ohio 3370
CourtOhio Court of Appeals
DecidedSeptember 3, 2024
Docket2024-P-0024
StatusPublished

This text of 2024 Ohio 3370 (Janesch v. Frontier Airlines, Inc.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Janesch v. Frontier Airlines, Inc., 2024 Ohio 3370 (Ohio Ct. App. 2024).

Opinion

[Cite as Janesch v. Frontier Airlines, Inc., 2024-Ohio-3370.]

IN THE COURT OF APPEALS OF OHIO ELEVENTH APPELLATE DISTRICT PORTAGE COUNTY

MICHAEL JANESCH, CASE NO. 2024-P-0024

Plaintiff-Appellant, Civil Appeal from the - vs - Municipal Court, Kent Division

FRONTIER AIRLINES, INC., Trial Court No. 2023 CVF 00575 K Defendant-Appellee.

OPINION

Decided: September 3, 2024 Judgment: Affirmed

Stewart D. Roll, 2020 East Swan Lake Circle, Kent, OH 44240 (For Plaintiff-Appellant).

Geoffrey A. Belzer, Wilson Elser Moskowitz Edelman & Dicker, LLP, 55 West Monroe, Suite 3800, Chicago, IL 60603 (For Defendant-Appellee).

JOHN J. EKLUND, J.

{¶1} Appellant, Michael Janesch, appeals the judgment of the Portage County

Municipal Court, Kent Division, granting summary judgment in favor of Appellee, Frontier

Airlines, Inc. (Frontier). Appellant’s First Amended Complaint alleged three counts

against Frontier: Breach of Contract, Misrepresentation, and a violation of Ohio’s

Consumer Sales Practices Act because Frontier cancelled Appellant’s flight from Fort

Myers, Florida to Cleveland, Ohio, which caused Appellant damages. {¶2} Appellant has raised one assignment of error arguing that the trial court

erred by granting summary judgment on each of the counts in his complaint in favor of

Appellee.

{¶3} Having reviewed the record and the applicable caselaw, we find Appellant’s

assignment of error is without merit. The trial court did not err in granting summary

judgment in favor of Frontier. First, Frontier’s Contract of Carriage provided that if a flight

is cancelled, the ticket holder can request a refund of the full ticket price, and when

someone requests a refund, it “shall be the limit of Frontier’s liability for the matters

covered by this provision.” Appellant requested and received a full refund of his ticket.

Second, there is no question of fact supporting his claim that Frontier misrepresented

anything to Appellant about his flight, its cancellation, or the options available to him

should his flight be cancelled. Third, Appellant’s claim under Ohio’s Consumer Sales

Practices Act fails because the Airline Deregulation Act (ADA) preempts state law with

respect to the application of state consumer sales practices statutes.

{¶4} Therefore, we affirm the judgment of the Portage County Municipal Court,

Kent Division.

Substantive and Procedural History

{¶5} On April 17, 2023, Appellant filed a three-count complaint in the small claims

division of the Portage County Municipal Court.

{¶6} On May 9, 2023, Appellant filed a motion to transfer the matter to the court’s

regular docket in accordance with R.C. 1925.10(B) because Frontier asserted it had good

defenses to Appellant’s claims. The trial court granted the motion and transferred the

matter to the regular docket of the Portage County Municipal Court, Kent Division.

Case No. 2024-P-0024 {¶7} Appellant filed a First Amended Complaint on July 10, 2023, alleging breach

of contract, misrepresentation, and a violation of the Ohio Consumer Sales Practices Act.

Frontier filed its Answer to the First Amended Complaint on July 21, 2023.

{¶8} Appellant filed a Motion to Compel Production of Documents and for

Sanctions on September 13, 2023.

{¶9} On September 22, 2023, Frontier filed a Motion for Summary Judgment

which included an Affidavit of Myriah Monteneri, a Claims Specialist for Frontier, Frontier’s

Contract of Carriage, Frontier’s Customer Service Plan, and a copy of Appellant’s flight

details.

{¶10} According to Frontier, on December 30, 2022, Appellant purchased a ticket

for a March 24, 2023, 8:12 p.m. return flight from Fort Meyers, Florida to Cleveland, Ohio.

Anyone purchasing a ticket through Frontier must first acknowledge Frontier’s Contract

of Carriage.

{¶11} The Contract of Carriage provides in relevant part:

A. Liability Limited – Frontier will use reasonable efforts to transport passengers and baggage to the purchased destination, but published schedules, flight times, aircraft types, seat assignments, and similar details set forth in the ticket or Frontier’s published schedules are not guaranteed and form no part of this Contract of Carriage. Frontier may substitute alternate aircraft, change schedules, delay or cancel flights, change seat assignments, and alter or omit stopping places shown on the ticket as required by its operations in Frontier’s sole discretion. Frontier’s obligations for failure to operate any flight, failure to operate a flight according to its schedule, or for changing the schedule or type of equipment used on any flight, with or without notice to the passenger are set forth below.

...

C. Delay, Misconnection, or Cancellation – In the event (i) a passenger’s flight is canceled . . . Frontier will provide transportation on its own flights at no additional charge to the passenger’s original destination or equivalent destination as provided herein. Frontier will have no obligation to provide 3

Case No. 2024-P-0024 transportation on another carrier. If Frontier cannot provide the foregoing transportation, Frontier shall, if requested, provide a refund for the unused portion of the passenger’s ticket in lieu of the transportation under the foregoing. The foregoing shall be the limit of Frontier’s liability for the matters covered by this provision. (Bold added).

{¶12} Frontier also included its Customer Service Plan, which it is required to

adopt under Federal law. The Customer Service Plan states in relevant part:

Controllable Situations are defined as delays, diversions, cancellations or service delivery failures considered within Frontier’s control (such as delayed bagged or flight delays and cancelations caused by some types of aircraft damage, mechanical issues, etc.) If your flight is delayed, canceled, diverted, or if you miss a connecting flight due to controllable situations, we’ll place you on the next available Frontier flight at no additional cost. In addition, Frontier will provide meal vouchers for . . . cancellations that result in a Frontier rebooking that departs 3 hours or greater after the originally scheduled departure time. Alternatively, if your flight is canceled or delayed in excess of 3 hours, we’ll provide you, upon request, a full refund of any unused portion of your ticket. (Bold added).

{¶13} On March 24, 2023, Frontier notified Appellant the flight had been cancelled

119 minutes before flight was scheduled to depart.

{¶14} Appellant accessed Frontier’s self-service portal. The portal provided

Appellant with an option to either rebook his flight or to request a refund.

{¶15} Frontier offered rebooking options including a flight on March 25, 2023, at

9:44 a.m. and a flight on March 25, 2023, at 10:12 p.m.

{¶16} Appellant did not choose to rebook his flight and instead requested a refund.

Frontier issued a refund to Appellant in the amount of $231.94 ($181.94 refunded to a

credit card and $50.00 refunded as a voucher).

{¶17} As to Count 1, Breach of Contract, Frontier’s Motion for Summary Judgment

argued that upon Appellant choosing to receive a refund, its contractual obligations to

Appellant were concluded, citing its Contract of Carriage. Appellant also noted that the

Case No. 2024-P-0024 Contract of Carriage contains a choice of law provision that provides for Colorado law to

apply to claims for breach of contract.

{¶18} As to Count 2, Misrepresentation, Frontier argued that Appellant had not

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2024 Ohio 3370, Counsel Stack Legal Research, https://law.counselstack.com/opinion/janesch-v-frontier-airlines-inc-ohioctapp-2024.