Kristi Vuksanovich and Mark Vuksanovich v. Airbus Americas, Inc. and Airbus S.A.S.

CourtDistrict Court, S.D. New York
DecidedSeptember 30, 2025
Docket1:21-cv-03454
StatusUnknown

This text of Kristi Vuksanovich and Mark Vuksanovich v. Airbus Americas, Inc. and Airbus S.A.S. (Kristi Vuksanovich and Mark Vuksanovich v. Airbus Americas, Inc. and Airbus S.A.S.) 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
Kristi Vuksanovich and Mark Vuksanovich v. Airbus Americas, Inc. and Airbus S.A.S., (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK KRISTI VUKSANOVICH and MARK VUKSANOVICH, Plaintiffs, No. 21-CV-3454-LTS-VF -against- AIRBUS AMERICAS, INC. and AIRBUS S.A.S., Defendants.

MEMORANDUM OPINION & ORDER Plaintiff Kristi Vuksanovich and her spouse, Plaintiff Mark Vuksanovich (“Plaintiffs”),1 bring this action against Defendants Airbus Americas, Inc. and Airbus S.A.S. (collectively, “Airbus” or “Defendants”). Ms. Vuksanovich asserts causes of action for strict products liability, negligence, and breach of implied warranty of merchantability. She alleges that she has suffered short-term and long-term health effects arising from “‘fume’ events which occur[red] as a result of the defective design and manufacture of Defendants’ aircraft,” exposing Ms. Vuksanovich to toxic cabin fumes while she served as a JetBlue flight attendant aboard Airbus’s aircraft. (Docket entry no. 49 (“SAC”) ¶¶ 25, 87-89.) Mr. Vuksanovich asserts derivative claims against Defendants for damages based on loss of consortium. Pending before the court are Defendants’ motions, pursuant to Federal Rule of Civil Procedure 56, for summary judgment dismissing all of Plaintiffs’ claims on statute of limitations grounds (docket entry no. 124), and for failure to state a claim upon which relief may be granted (docket entry no. 194). Also pending are five motions to preclude testimony brought

1 One June 23, 2022, Judge Katherine Polk Failla dismissed all claims brought by plaintiffs Amysue Salvatore and Michael F. Salvatore as time-barred. (Docket entry no. 79.) by Defendants pursuant to Rules 702 and 705 of the Federal Rules of Evidence. (Docket entry nos. 189, 190, 191, 192, 193.) The Court has jurisdiction of this action pursuant to 28 U.S.C. section 1332. The Court has considered the parties’ submissions and arguments carefully. For the reasons explained below, Defendants’ first motion for summary judgment is granted.

Because all of Plaintiffs’ claims are time-barred, the Court does not rule on Defendants’ second motion for summary judgment or on Defendants’ motions to preclude. There is also no need for oral argument, and Defendants’ motion for argument (docket entry no. 204) is therefore denied.

BACKGROUND The following facts are undisputed unless otherwise indicated.2 Defendants’ A320 family of aircraft utilizes a “bleed air” system to pressurize and condition cabin air; this type of system is used in 97 percent of the world’s commercial passenger jet fleet. (Docket entry no. 224-1 (“Def. Reply to Pl. Second 56.1 Resp.”) ¶ 4). The bleed air system draws compressed air from an aircraft’s engine and pumps it into the passenger cabin. (Id. ¶ 6). Air is ingested from the environment into the Auxiliary Power Unit (“APU”) inlet; in the Airbus A320 aircraft,

the APU inlet is located at the bottom of the aircraft’s fuselage, downstream of the jet engines. (Docket entry no. 224-2 (“Def. Reply to Pl. 56.1 St. of Addt’l Facts”) ¶¶ 108-109.) This location

2 Facts characterized as undisputed are identified as such in the parties’ statements pursuant to S.D.N.Y. Local Civil Rule 56.1, or drawn from evidence as to which there has been no contrary, non-conclusory factual proffer. Citations to Local Civil Rule 56.1 Statements (docket entry nos. 126 (“Def. 56.1 St.”), 142 (“Pl. 56.1 Resp.”), 192 (“Def. Second 56.1 St.”), 210-1 (“Pl. Second 56.1 Resp.”), 210-2 (“Pl. 56.1 St. of Addt’l Facts”), 224-1 (“Def. Reply to Pl. Second 56.1 Resp.”), 224-2 (“Def. Reply to Pl. 56.1 St. of Addt’l Facts.”)) incorporate by reference the parties’ citations to the underlying evidentiary submissions. can allow oil leaks and drainage from the APU, as well as hydraulic fluids from forward areas of the aircraft, to enter the APU air intake and contaminate breathing air supply on the aircraft. (Id. ¶ 116.) Bleed air can be contaminated with jet engine oil, hydraulic fluids, and deicing agents, including neurotoxic jet engine oil decomposition products such as tricresyl phosphate

(“TCP”), tri-ortho-cresyl phosphate (“TOCP”), and other neurotoxic isomers that are present in jet engine oil vapors. (Id. ¶¶ 101-102.) While Defendants dispute whether these contaminants are ever present in high enough concentrations in bleed air to be harmful to human health (id. ¶¶ 99, 101), it is undisputed that bleed air contamination can lead to health effects for crew such as headaches, dizziness, and eye nose or throat irritation (id. ¶ 158 (admitting the authenticity of an internal Airbus report from 2011 that “concluded that bleed air contamination in the cabin can lead to several health effects for crew . . . [that] should be considered major” but disputing “any characterization suggesting that these physiological effects are harmful to ‘health.’”).) The parties also dispute whether bleed air is filtered before entering the cabin on A320 aircraft. (Id.

¶ 109.) Fume events, where higher concentrations of contaminants are present in bleed air, occur on Airbus aircraft, often accompanied by odors similar to those of dirty socks or smoke. (Id. ¶¶ 104, 106.) Consequently, fume events are sometimes also described as cabin odor events. Airbus has identified external and internal oil leakages and the APU’s ingestion of external fumes, external pollutants, hydraulic leaks, air conditioning fluid, and deicing fluid as sources of cabin odor events on A320 aircraft. (Id. ¶¶ 122, 135.) According to Airbus’s internal tracking, oil leaks emanating from the APU were the main cause of cabin odors and related “out of service” events for Airbus aircraft in JetBlue’s fleet in 2017 and Delta Airlines’ fleet in 2018. (Id. ¶ 134, 145.) Airbus A320F aircraft experience more cabin odor events traceable to the APU than other comparable aircraft except the MD80, a McDonnell-Douglass aircraft. (Id. ¶ 140.) An expert witness retained by Defendants testified that it would be reasonable to conclude that every airline utilizing an A320 aircraft has reported to Airbus that, at least once, a crew member’s injury or a service disruption was allegedly a result of a contaminated cabin air event.

(Id. ¶ 148.) Ms. Vuksanovich, a former JetBlue flight attendant, has flown on several A320 aircraft designed, manufactured, and assembled by Defendants. (SAC ¶¶ 10-14; docket entry no. 142 (“Pl. 56.1 Resp.”) ¶ 1.) Beginning on June 16, 2017, she experienced myriad short-term and long-term symptoms of illness, some coinciding with alleged fume events she experienced while on Defendants’ aircraft (Pl. 56.1 Resp. ¶¶ 10-11, 16, 18, 20, 22, 26-27, 30-31, 40, 42, 46, 48, 51-52, 77), while others arose without any apparent connection to a fume event (id. ¶¶ 84-85). Prior to June 16, 2017, Ms. Vuksanovich knew of a JetBlue pilot who had become ill as a result of cabin odors. (Docket entry no. 127-1 (“Vuksanovich Deposition”) at 47:5-21).)

Ms. Vuksanovich’s earliest symptoms manifested on June 16, 2017, during a round-trip flight between Boston and Dallas-Fort Worth. (Pl. 56.1 Resp. ¶¶ 5-12, 16-17.) During the pre-flight safety briefing, she and the crew were “informed that the aircraft ha[d] experienced issues with severe ‘cabin odors,’ in reality being toxic fumes, of the stinky sock; wet dog smell” and that the aircraft was delayed due to maintenance issues. (Docket entry no. 197-14 (“Howard Report”) 3 at 4-6 (quoting Ms. Vuksanovich’s testimony).) Upon boarding

3 While parties contest the admissibility of the Howard Report, because their contentions focus on what expert opinions Dr. Howard may offer, the Court relies on Ms.

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Kristi Vuksanovich and Mark Vuksanovich v. Airbus Americas, Inc. and Airbus S.A.S., Counsel Stack Legal Research, https://law.counselstack.com/opinion/kristi-vuksanovich-and-mark-vuksanovich-v-airbus-americas-inc-and-airbus-nysd-2025.