Lexplug logoLexplug

Witty v. Delta Air Lines, Inc.

Court of Appeals for the Fifth Circuit
2004 WL 771357, 366 F.3d 380, 2004 U.S. App. LEXIS 7103 (2004)
ELI5:

Rule of Law:

State law personal injury claims against airlines are preempted by federal law when they relate to airline prices, such as seating space, under the Airline Deregulation Act, or when they seek to impose safety warning standards beyond those mandated by the Federal Aviation Administration's pervasive regulatory scheme.


Facts:

  • Milton Witty flew as a passenger on a Delta Air Lines flight from Monroe, Louisiana, to Hartford, Connecticut.
  • During or after the flight, Witty developed Deep Vein Thrombosis (DVT), a medical condition where a blood clot forms in a deep vein.
  • Witty alleged that Delta's negligence caused his DVT.
  • Specifically, Witty claimed Delta was negligent for failing to provide adequate leg room to prevent DVT.
  • Witty also claimed Delta was negligent for failing to warn passengers about the risks of developing DVT in pressurized cabins on long flights and for failing to allow passengers to exercise their legs.

Procedural Posture:

  • Milton Witty filed a diversity suit against Delta Air Lines, Inc. in the U.S. District Court for Louisiana, a court of first instance.
  • Delta filed a motion to dismiss, arguing Witty's state law claims were preempted by federal law.
  • The district court denied Delta's motion to dismiss, concluding the claims arose from the operation of the aircraft and were not preempted.
  • The district court certified its order denying the motion for an interlocutory appeal.
  • The U.S. Court of Appeals for the Fifth Circuit permitted the appeal, with Delta as the appellant and Witty as the appellee.

Locked

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Does federal law, specifically the Airline Deregulation Act and the Federal Aviation Act, preempt state law negligence claims against an airline alleging failure to provide adequate leg room and failure to warn passengers about the risk of Deep Vein Thrombosis (DVT)?


Opinions:

Majority - Reavley, Circuit Judge

Yes. Federal law preempts state law personal injury claims against an airline based on inadequate leg room and failure to give warnings not required by federal regulations. The claim regarding inadequate leg room is expressly preempted by the Airline Deregulation Act (ADA) because mandating more leg room would reduce seating capacity and thus have a significant economic effect on airline prices, which states are forbidden from regulating. The claim regarding failure to warn is impliedly preempted by the Federal Aviation Act (FAA), which created a pervasive and exclusive federal regulatory scheme for air safety, including passenger warnings. Allowing states to impose their own warning requirements would conflict with this uniform federal system and interfere with federal objectives. Since federal regulations do not require a DVT warning, Delta cannot be held liable under state law for failing to provide one.



Analysis:

This decision solidifies the broad preemptive power of federal law over state tort claims in the airline industry. It clearly bifurcates the preemption analysis between economic regulations under the ADA and safety regulations under the FAA. By finding that claims relating to leg room are preempted as price regulations, the court significantly limits passenger lawsuits concerning seating comfort and configuration. Furthermore, by holding that the FAA's safety regulations occupy the entire field of passenger warnings, the court establishes that an airline's duty to warn is defined exclusively by federal standards, effectively shielding airlines from state negligence claims for failing to provide warnings not mandated by the FAA.

G

Gunnerbot

AI-powered case assistant

Loaded: Witty v. Delta Air Lines, Inc. (2004)

Try: "What was the holding?" or "Explain the dissent"