Eastern Airlines, Inc. v. Floyd
113 L. Ed. 2d 569, 1991 U.S. LEXIS 2222, 499 U.S. 530 (1991)
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Rule of Law:
Article 17 of the Warsaw Convention does not allow recovery for purely mental or psychic injuries that are unaccompanied by physical injury or a physical manifestation of injury.
Facts:
- On May 5, 1983, an Eastern Airlines flight departed from Miami for the Bahamas.
- Shortly after takeoff, one of the plane's three jet engines failed due to loss of oil pressure.
- The crew turned the plane around to return to Miami, but soon after, the remaining two engines also failed.
- As the plane descended rapidly without power, passengers were informed that the plane would have to ditch in the Atlantic Ocean.
- The crew managed to restart one engine and land the plane safely at Miami International Airport.
- A group of passengers on the flight, the respondents, experienced severe mental and emotional distress from the incident but suffered no physical injuries.
Procedural Posture:
- A group of passengers (respondents) filed complaints against Eastern Airlines, Inc. (petitioner) in the U.S. District Court for the Southern District of Florida.
- The District Court consolidated the cases and concluded that mental anguish alone is not a compensable injury under Article 17, dismissing the passengers' claims.
- The passengers (now appellants) appealed to the U.S. Court of Appeals for the Eleventh Circuit.
- The Eleventh Circuit reversed the District Court, holding that the French phrase 'lésion corporelle' in Article 17 encompasses purely emotional distress.
- Eastern Airlines, Inc. (petitioner) petitioned the U.S. Supreme Court for a writ of certiorari, which was granted to resolve a conflict among the courts.
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Issue:
Does Article 17 of the Warsaw Convention allow recovery for purely mental or psychic injuries that are not accompanied by physical injury or a physical manifestation of injury?
Opinions:
Majority - Justice Marshall
No, Article 17 of the Warsaw Convention does not allow recovery for purely mental or psychic injuries unaccompanied by physical injury. The analysis begins with the authentic French text of the Convention, which makes a carrier liable for "dommage survenu en cas de mort, de blessure ou de toute autre lésion corporelle." The Court determined that the term "lésion corporelle" is properly translated as "bodily injury." This interpretation is supported by French-English dictionaries, the contemporary legal meaning of the term in 1929, and the official translations used by both the United States and the United Kingdom. The Court's review of the treaty's negotiating history reveals that the drafters replaced a broader liability provision from an earlier draft with the more specific language of Article 17, suggesting an intent to narrow the scope of recoverable injuries. Furthermore, the primary purpose of the Warsaw Convention was to limit air carriers' liability to foster the growth of the nascent aviation industry, a goal consistent with a narrow reading of "lésion corporelle." Finally, subsequent interpretations and conduct by signatory nations, as well as the need for uniformity in international air law, support the conclusion that purely psychic injuries are not compensable under Article 17.
Analysis:
This decision established a definitive and uniform rule for a frequently litigated issue under the Warsaw Convention, resolving a circuit split. The Court's holding solidifies a textualist and originalist approach to treaty interpretation, prioritizing the original shared understanding of the signatories over evolving legal norms or contemporary policy arguments for compensating mental harm. By limiting carrier liability to physical injuries, the ruling significantly impacts passengers' ability to recover for emotional trauma in incidents like hijackings or near-miss accidents where no physical harm occurs. The decision left open the question of whether mental injuries that are accompanied by physical injuries are recoverable, a question later addressed by the Court.
