Michael Lowe v. American Airlines, Inc. and Tamika Barkers

CourtCourt of Appeals of Texas
DecidedAugust 22, 2024
Docket02-23-00370-CV
StatusPublished

This text of Michael Lowe v. American Airlines, Inc. and Tamika Barkers (Michael Lowe v. American Airlines, Inc. and Tamika Barkers) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Michael Lowe v. American Airlines, Inc. and Tamika Barkers, (Tex. Ct. App. 2024).

Opinion

In the Court of Appeals Second Appellate District of Texas at Fort Worth ___________________________ No. 02-23-00370-CV ___________________________

MICHAEL LOWE, Appellant

V.

AMERICAN AIRLINES, INC. AND TAMIKA BARKERS, Appellees

On Appeal from the 352nd District Court Tarrant County, Texas Trial Court No. 352-333908-22

Before Sudderth, C.J.; Womack and Walker, JJ. Memorandum Opinion by Justice Walker MEMORANDUM OPINION

This case arises from the misidentification of Appellant Michael Lowe as the

suspect in a burglary that occurred at DFW Airport (the Airport). Lowe was arrested

for the burglary and spent seventeen days in a New Mexico jail before law

enforcement determined that he was not the proper suspect and dropped the charges

against him. Lowe sued Appellants American Airlines, Inc. (AA) and Tamika Barkers,

a former AA security employee, for their alleged involvement in his misidentification,

pleading various negligence claims and claims for false arrest and imprisonment and

ratification. AA and Barkers moved for traditional and no-evidence summary

judgment, and the trial court granted their motion. Lowe appeals from that judgment.

We will affirm.

I. BACKGROUND

A. FACTUAL BACKGROUND

The material facts of this case are unfortunate and largely undisputed.1 In

May 2020, an unknown male burglarized a store inside the Airport. Airport police

officer Juan Torres investigated the burglary and viewed video-surveillance footage in

an attempt to identify the suspect. Based on timestamps from the footage, Torres

concluded that the suspect had boarded an AA flight to Reno, Nevada, at 6:29 p.m.

Lowe also boarded the flight at that time.

We derive all background facts from the summary-judgment evidence 1

submitted by the parties.

2 Torres then spoke with Barkers—a security specialist with AA’s Security

Department and a former police officer—and asked her for “identifying information”

for the passenger who had scanned his boarding pass at 6:29 p.m. He also sent

Barkers screenshots of the alleged suspect as he boarded the flight and informed her

that the suspect had been traveling with a companion. Barkers told Torres that she

had the information he was seeking but that she could not release it to him unless she

was provided a valid subpoena or warrant.2

Torres submitted a probable-cause affidavit and search-warrant request, in

which he attested that AA had information related to the burglary, namely passenger

identification and other records from the flight in question. He described the burglary

suspect as a “tall, thin, White or Hispanic male with a short military[-]style haircut,

black polo shirt[,] and blue jeans” and stated that the suspect had boarded the flight at

6:29 p.m.

A search warrant issued that broadly commanded law enforcement to search

for and seize passenger records, “driver[’s] license or identification number[s], dates of

birth, telephone number(s), and email address[es]” from AA’s premises. Though it

2 AA had adopted internal policies related to the protection of customer information that instructed its employees to keep this information confidential because its disclosure could lead to customer harm. Employees were instructed to follow all relevant data protection laws, provide law enforcement immediate access to data when they presented a subpoena, and to disclose only the minimum amount of data needed to achieve a particular purpose.

3 referenced Torres’s affidavit, the warrant itself was not limited to a specific passenger,

boarding time, or flight.

Torres provided the warrant to Barkers and again asked her specifically for the

identity of the passenger who had scanned his boarding pass at 6:29 p.m. He did not

ask for or obtain a more comprehensive set of passenger records, such as a flight

manifest or the identification of roughly the ten other passengers who had boarded

the plane at or around the same time. In response to this request, Barkers identified

Lowe as the passenger in question. She also offered to provide Torres with the name

of a companion whom she believed to have been travelling with Lowe, but Torres

declined that information.3 Torres testified at a deposition that AA and Barkers had

fully complied with the search warrant.

Torres searched for Lowe in law enforcement databases and obtained

additional information about him, including a picture from his 2009 driver’s license.

He compared this picture to the picture of the burglary suspect from the Airport

surveillance footage. Though Lowe’s picture did not closely resemble the person

from the Airport footage, Torres reasoned that a person’s appearance can change

over time.

An arrest warrant was issued for Lowe, and he was eventually arrested in New

Mexico and jailed for seventeen days. Lowe was then released from jail and, after

3 The record suggests that Lowe had not been travelling with a companion.

4 hiring an attorney and convincing Torres that he had been misidentified as the

burglary suspect, his charges were dismissed.

B. PROCEDURAL BACKGROUND

Lowe sued AA and Barkers, alleging that the conditions in the jail had been so

deplorable that they caused him lasting physical and mental injuries. He brought

claims for negligence, negligent undertaking, gross negligence, false arrest and

imprisonment, and “respondeat superior, agency[,] and ratification.” As to the

negligence claim, Lowe alleged that Appellees owed him a duty to protect his personal

identifying information from disclosure; that Appellees had breached their duty of

care by failing to properly comply with the search warrant and by wrongfully

producing only Lowe’s identifying information in response to the warrant; and that

these breaches proximately caused his damages.

As to the negligent-undertaking claim, Lowe alleged that, “to the extent there

[was] no duty otherwise recognized under common law,” Appellees undertook duties

to protect AA’s passengers’ personal information and to perform law enforcement

tasks beyond what was ordinarily required of an airline; that Appellees had developed

policies for interacting with law enforcement and protecting AA’s passengers’

personal information; that Appellees had failed to exercise ordinary care in

performing these duties and adhering to these policies; that Lowe had relied upon

Appellees’ performance of these duties to his detriment; or alternatively, that these

5 failures increased the risks of foreseeable harm to Lowe; and that these breaches had

caused his damages.

As to the gross-negligence claim, Lowe alleged that Appellees’ acts or

omissions in providing only Lowe’s name in response to the search warrant involved

an extreme risk that he would be arrested or imprisoned; that Appellees knew of those

risks and still did not fully comply with the search warrant and its own internal

policies; and that these failures led to Lowe’s foreseeable harm.

As to the false-arrest-and-imprisonment claim, Lowe alleged that Appellees

“willfully participated in acts that would foreseeably result in” his arrest and that

Lowe’s arrest and detention were without his consent and without legal authority or

justification.

Finally, as to the respondeat superior, agency, and ratification claim, Lowe

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