Liaw v. United Airlines, Inc.

CourtDistrict Court, N.D. California
DecidedNovember 22, 2019
Docket3:19-cv-00396
StatusUnknown

This text of Liaw v. United Airlines, Inc. (Liaw v. United Airlines, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Liaw v. United Airlines, Inc., (N.D. Cal. 2019).

Opinion

1 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE NORTHERN DISTRICT OF CALIFORNIA 8 9 10 THEODORE LIAW, No. C 19-00396 WHA 11 Plaintiff, ORDER ON MOTIONS FOR 12 v. SUMMARY JUDGMENT AND TO EXCLUDE 13 UNITED AIRLINES, INC., 14 Defendant. / 15 16 INTRODUCTION 17 In this action arising under the Montreal Convention, both parties move for summary 18 judgment and to exclude evidence. In order to collect emotional distress damages under the 19 Montreal Convention, plaintiff must prove bodily injury as a predicate, a showing he fails to 20 make. To the extent stated below, therefore, defendant’s motions are GRANTED and plaintiff’s 21 motions are DENIED. 22 STATEMENT 23 Due to a crack in an outer layer of a cockpit windshield, an airliner made an 24 unscheduled descent and landing. All were delayed but no one claimed injury save and except 25 for plaintiff Theodore Liaw, who allegedly suffered back injury and terrifying distress as the 26 plane descended. Now follow the details. 27 28 1 Liaw is the CEO of NexRep. He is a frequent flyer and a United Million Miler. In the 2 five weeks prior to the subject flight, Liaw had been on twenty-five different flights. He got 3 into a scooter accident about six months before the subject flight, where he went over a pothole 4 and landed with his left hand outstretched (Dkt. Nos. 49-3 at 225:15–17, 267:15–269:7; 50-1 at 5 10; 54-2 at 3). 6 On October 27, 2018, Liaw boarded United Airlines Flight 931 heading from Chicago to 7 London as a business class passenger. About three hours into the flight, the outer layer of the 8 cockpit windshield cracked (but not the inner layer). The pilot announced that the plane would 9 make an unscheduled landing, then landed in Goose Bay (Dkt. No. 24-1 ¶¶ 12–14, 16). 10 The plane remained on the tarmac for eight hours. Once on the rescue flight, Liaw flew 11 from Goose Bay to London, then to Addis Ababa, then to Zanzibar to meet his then-fiancee. 12 They then traveled to Kenya for several days for a safari trip. Once in Kenya, he took a small 13 passenger plane to reach the safari location. Liaw and his fiancee then flew to Rome, where 14 they visited various cathedrals, the Coliseum, Vatican City, and other tourist spots, all requiring 15 significant walking. He has continued to fly since this vacation (Dkt. Nos. 49-3 at 48:3–13, 16 50:12–53:25, 55:24–56:15, 58:4–11, 70:20–72:15; 45-1 ¶ 5). 17 Liaw alleges that the descent during the unscheduled landing was faster than usual and 18 that he suffered a “minor” injury within his lower back as a result of the incident. He further 19 alleges emotional distress stemming from the incident, such as vivid nightmares and other 20 mental injuries. Liaw first sought treatment regarding the incident at issue with Dr. Janie Hong, 21 a therapist, to treat his alleged emotional distress stemming from the subject flight. Liaw 22 alleges feeling a new back “soreness” and “discomfort” after the flight — an injury even he 23 readily describes as de minimis. He was the first (and only) passenger to complain of any injury 24 from the emergency landing. Liaw did not seek medical attention for his alleged back injuries 25 until August 2019 at the advice of his lawyer — approximately ten months after the subject 26 flight and four days before his deposition. In September 2019, Liaw received an MRI scan of 27 his lumbar spine, which showed an annular fissure and disc bulge. He does not have current 28 1 plans to seek further medical attention for his back issue (Dkt. Nos. 45 at 1, 3, 9; 47-1 at 7; 49-3 2 at 89:3–9, 92:6–8, 199:21–201:11). 3 Liaw filed the instant action, alleging that he suffered back injuries and emotional 4 distress due to the unscheduled landing. Both parties now move for summary judgment on 5 United’s liability for these alleged injuries and further move to exclude the other side’s 6 evidence (Dkt. Nos. 45, 50, 51). This order follows full briefing and oral argument. 7 ANALYSIS 8 The Montreal Convention governs “all international carriage of persons, baggage or 9 cargo performed by aircraft for reward” and “provides the exclusive remedy for international 10 passengers seeking damages against airline carriers.” Narayanan v. British Airways, 747 F.3d 11 1125, 1127 (9th Cir. 2014). Article 17 of the Montreal Convention provides as follows: 12 The carrier is liable for damage sustained in case of death or bodily injury of a passenger upon condition only that the accident which caused the 13 death or injury took place on board the aircraft or in the course of any of the operations of embarking or disembarking. 14 “The Montreal Convention is the successor to the Warsaw Convention of 1929[, and] 15 was the product of a United Nations effort to reform the Warsaw Convention so as to harmonize 16 the hodgepodge of supplementary amendments and intercarrier agreements of which the Warsaw 17 Convention system of liability consist[ed].” Narayanan, 747 F.3d at 1127 n. 2. “Although 18 designed to replace the Warsaw Convention, the Montreal Convention incorporates many of its 19 substantive provisions.” Ibid. “Accordingly, in interpreting the Montreal Convention, courts 20 have routinely relied upon Warsaw Convention precedent where the equivalent provision in the 21 Montreal Convention is substantively the same.” Ibid.; see also Phifer v. Icelandair, 652 F.3d 22 1222, 1224 n.1 (9th Cir. 2011) (applying precedent under Article 17 of the Warsaw Convention 23 to a case involving Article 17 of the Montreal Convention because “any differences between the 24 provisions are immaterial”). 25 An “accident” for purposes of Article 17 is “an unexpected or unusual event or 26 happening that is external to the passenger.” Air France v. Saks, 470 U.S. 392, 405 (1985). But 27 “when the injury indisputably results from the passenger’s own internal reaction to the usual, 28 normal, and expected operation of the aircraft, it has not been caused by an accident, and Article 1 17 . . . cannot apply.” Id. at 406. Courts must focus on the “accident which caused the 2 passenger’s injury, and not to [the] accident which is the passenger’s injury.” Phifer v. 3 Icelandair, 652 F.3d 1222, 1224 (9th Cir. 2011) (quoting Saks, 470 U.S. at 398). In other words, 4 a defendant “is only liable to [a plaintiff] if her injury was caused by an accident.” Ibid. “Any 5 injury is the product of a chain of causes, and [the Supreme Court] require[s] only that the 6 passenger be able to prove that some link in the chain was an unusual or unexpected event 7 external to the passenger.” Saks, 470 U.S. at 406. And, Article 17 under the Warsaw 8 Convention did not allow recovery for “purely mental injuries.” Eastern Airlines, Inc. v. Floyd, 9 499 U.S. 530, 534 (1991). 10 Both sides agree that the Montreal Convention governs plaintiff’s sole claim. They 11 further agree that the cracked windshield, which occurred “on board the aircraft,” constituted “an 12 unexpected or unusual event or happening that is external to” Liaw (Dkt. No. 24 ¶ 3). The issue 13 then is whether Liaw has sufficiently shown that the cracked windshield caused his back 14 soreness. He has not. 15 1. UNITED’S MOTION TO EXCLUDE. 16 Liaw contends that the subject flight’s purported “rapid descent” hurt his back. Ten 17 months after the subject flight and four days before his deposition, Liaw finally saw a medical 18 doctor — his expert witness Dr. Moshe Lewis in the instant action — for his alleged back injury 19 (Dkt. No. 46-1 at 88:14–22). Dr.

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Liaw v. United Airlines, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/liaw-v-united-airlines-inc-cand-2019.