FEDERAL JUDGE GRANTS UNITED’S MOTION FOR SUMMARY JUDGMENT IN NEGLIGENCE LAWSUIT
November 25, 2024
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On October 15, 2024, the United States District Court for the Northern District of California issued an opinion granting summary judgment for Defendant United Airlines after finding that plaintiffs had failed to produce evidence linking United’s alleged breach to the passenger’s death. During a cross-country United Airlines flight, a wheelchair belonging to a passenger with quadriplegia was damaged and the passenger elected to rent a temporary replacement wheelchair from her longtime supplier rather than obtain a replacement wheelchair through United’s vendor. The passenger’s chronic open sore worsened several months after the cross-country flight, and she passed away after several hospitalizations. Her successor in interest sued United alleging that the airline negligently damaged the passenger’s wheelchair and that her use of an ill-fitting temporary replacement wheelchair caused her preexisting pressure sore to widen and become fatally infected.
United conceded during oral arguments that it breached a duty to return the passenger’s wheelchair in its original condition as required by federal regulations. The disputed issue in the case turned on whether a reasonable jury could conclude that the damaged caused to the wheelchair by United was the direct and proximate cause of the passenger’s death. The Court pointed out that it was the passenger, not United, who picked the ill-fitting replacement wheelchair, and that the passenger never alerted United of her preexisting condition. The Court found it “difficult to understand how United could foresee that [the passenger] might select—and continue to use—a replacement wheelchair that would worsen her pre-existing injury.” The Court reasoned that the passenger’s actions broke the causal chain following United’s breach and therefore granted the airline’s motion for summary judgment.
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