SILVA v. UNITED AIRLINES INC.

CourtDistrict Court, D. New Jersey
DecidedMay 1, 2025
Docket2:24-cv-11119
StatusUnknown

This text of SILVA v. UNITED AIRLINES INC. (SILVA v. UNITED AIRLINES INC.) is published on Counsel Stack Legal Research, covering District Court, D. New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
SILVA v. UNITED AIRLINES INC., (D.N.J. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY

ROMULLO TADEU MELO SILVA, Plaintiff, No. 24-cv-11119 v. ras OPINION ON MOTION UNITED AIRLINES, INC., TO DISMISS Defendant.

WILLIAM J. MARTINL U.S.D.J.: Before the Court is defendant United Airlines, Inc.’s motion to dismiss plaintiff Romullo Tadeu Melo Silva’s complaint for defamation. This court has jurisdiction pursuant to 28 U.S.C. § 1332(a)(1). Venue is proper pursuant to 28 U.S.C. § 1391(b)(2). For the reasons set forth herein, defendant’s motion to dismiss is GRANTED. 1 FACTS AS ALLEGED The following facts are derived from the allegations set forth in plaintiff’s complaint and are accepted as true for the purpose of this motion to dismiss. Only the facts necessary to the resolution of the instant motion are included. On February 7, 2023, defendant United Airlines, Inc. hired plaintiff Romullo Tadeu Melo Silva as a pilot serving in the role of “first officer.” Generally, on a United flight, a first officer flies alongside and subject to the authority of a captain, who serves as the “pilot in command” (“PIC”) of the flight. On July 29, 2023, plaintiff served as the first officer on a flight from Newark, New Jersey to Houston, Texas. Plaintiff served alongside PIC Captain Robert Goudon. When the time came to land the plane, Captain Goudon failed to arm the speed brake on the aircraft, leading to a landing in which the nose of the aircraft “went down ‘hard’ on the runway.” Compl. 21. Plaintiff was flying the plane at the time of the landing, but alleges arming the speed brake on the aircraft was Goudon’s responsibility. No injuries occurred. That same day, defendant pulled plaintiff from flight duty until September 30, 2023, at which point plaintiff was required to present the probable cause of the incident. Thereafter plaintiff was sent to a landing-only flight simulator and subsequently was required to perform a “check ride”—a test flight supervised by a more senior pilot prior to returning to full service—on October 2, 2023. Plaintiff failed the check ride and defendant terminated his employment on October 12, 2023.

Plaintiff alleges that, following his termination, defendant filed a report with the FAA in which it stated that plaintiff was the PIC of the July 29, 2023 flight, even though Captain Goudon was the actual PIC of the flight. Plaintiff claims that as a result of this allegedly inaccurate report, plaintiffis unable to obtain employment as a pilot and has lost at least $100,000 in income. On December 13, 2024, plaintiff brought this suit against defendant in a nominally three-count complaint, alleging defamation (Count I) and seeking injunctive relief (Count II) and attorney fees (Count I). ECF No. 1. In effect, this complaint boils down to one claim for defamation, with accompanying requests for injunctive relief and attorney fees.! I. LEGAL STANDARD Federal Rule of Civil Procedure 12(b)(6) provides for the dismissal of a complaint, in whole or in part, if the plaintiff fails to state a claim upon which relief can be granted. The moving party bears the burden of showing that no claim has been stated, Hedges v. United States, 404 F.3d 744, 750 (3d Cir. 2005), and dismissal is appropriate only if accepting all of the facts alleged in the complaint as true, the plaintiff has failed to plead “enough facts to state a claim to relief that is plausible on its face.” Bell Atl Corp. v. Twombly, 550 U.S. 544, 570 (2007); see also Umland vy. PLANCO Fin, Serv., Inc., 542 F.3d 59, 64 (3d Cir. 2008). This assumption of truth is inapplicable, however, to legal conclusions couched as factual allegations or to “[t|hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements.” Ashcroft v. Iqbal, 556 U.S, 662 (2009). That is, although a complaint need not contain detailed factual allegations, “a plaintiffs obligation to provide the ‘grounds’ □□ □□□ ‘entitlement to relief requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do.” Twombly, 550 U.S. at 555. Thus, the factual allegations must be sufficient to raise a plaintiff's right to relief above a speculative level, see id. at 570, such that the court may “draw the reasonable inference that the defendant is liable for the misconduct alleged.” Igbal, 556 U.S. at 678 (citing Twombly, 550 U.S. at 556). While “[t]he plausibility standard is not akin to a probability requirement’ ... it asks for more than a sheer possibility that a defendant has acted unlawfully.” □□□ TIE DISCUSSION As a threshold matter, because defamation is a state law claim before this Court via diversity jurisdiction, the Court must determine which state’s law of defamation applies. Neither party briefed the issue, and both appear to assume that New Jersey law applies.

' Jeclaratory and injunctive relief are remedies rather than causes of action.” Kabbaj v. Google, 592 Fed. Appx. 74, 75 n.2 Gd Cir. 2015). Similarly, unless otherwise set forth by statute, a claim for attorney fees is a remedy sought in connection with a substantive claim, not its own cause of action. See Marrin v. Capital Health Systems, Ine., 2015 WL 404783, at *10 (D.N.J. Jan. 29, 2015) (“[A]ttorney fees .,. [is a] remed[y] for certain causes of action, and not [a] substantive count{] in [its] own right[]’) (citing Hassoun v. Cimmino, 126 F. Supp. 2d 353, 372 (D.N.J, 2000)).

See Mot. at 4 (identifying elements to state a claim “under New Jersey law”); Opp. at 2-4 (applying same standard). “The Third Circuit has held that when the parties agree to apply the law of a particular state, and that state has an obvious interest in the litigation, a court need not examine the choice of law sua sponte.” Skeen vy. BMW of North America, LLC, 2014 WL 283628 (D.N.J. Jan. 24, 2014) (quoting Lamonaco v. CBS, inc., 1993 WL 556536, at *2 (D.N.J. July 29, 1993)); see also Schiavone Construction Co, v. Time, Inc., 735 F.2d 94, 96 (3d Cir. 1984) (“The parties implicitly agree that New Jersey law governs, and the district court applied New Jersey law. Inasmuch as New Jersey has an interest in the outcome of this litigation ... we have no cause sua sponte to challenge that choice of law”); J.B. Hunt Transport, Inc. y. USF Distrib. Servs., 83 Fed. Appx. 476, 478 n.2 Gd Cir. Dec. 18, 2003) (“Because the parties implicitly agree that New Jersey law applies to this dispute and since New Jersey has a substantial interest... we will not revisit the District Court’s decision to apply New Jersey law.”). Here, because the plaintiff is a New Jersey resident and would experience the alleged harm in his employment prospects in New Jersey, and because New Jersey has an interest in protecting its residents and in-state employees from defamation, New Jersey has a substantial interest in the litigation and this Court will apply New Jersey law. New Jersey courts “have defined defamation consistently with section 559 of the Restatement (Second) of Torts (1977).” DeAngelis v. Hill, 180 NJ. 1, 12 (2004); accord Sciore v. Phung, 2022 WL 950261, *5 (D.N.J. Mar. 30, 2022).

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SILVA v. UNITED AIRLINES INC., Counsel Stack Legal Research, https://law.counselstack.com/opinion/silva-v-united-airlines-inc-njd-2025.