Tavantzis v. American Airlines, Inc.
- Wise
- 5:23-cv-05607
- U.S. District Court · Northern District of California
- 2
In Tavantzis v. American Airlines, Judge Wise denied American Airlines’ motion for judgment as a matter of law, leaving the Montreal Convention dispute for the jury.
The ruling directly affects Plaintiffs Tavantzis and Plasencia and American Airlines, Inc. It allows the jury to consider whether the evidence showed that American Airlines violated its policies during Flight 68.
What happened
In Tavantzis v. American Airlines, the court was presiding over a jury trial involving Plaintiffs Tavantzis and Plasencia and American Airlines. After the Plaintiffs presented their evidence, American Airlines asked the court to end the case before the jury decided it.
American Airlines argued that the Plaintiffs had not shown that the airline violated its policies during Flight 68. It contended that failing to provide adequate medical assistance, without a substantial departure from airline policies or industry standards, was not an “accident” under Article 17 of the Montreal Convention. The court found evidence that flight attendants were expected to recognize stroke symptoms and that witnesses gave conflicting testimony about whether a flight attendant failed to respond properly.
Judge Wise denied American Airlines’ motion for judgment as a matter of law. The court concluded that a reasonable jury could find that American Airlines violated its policies, so it would not remove the issue from the jury’s consideration.
The detailed version
- Tavantzis v. American Airlines, Inc. · No. 5:23-cv-05607
- Wise
- Sept. 15, 2025
Background
The court was presiding over a jury trial that began on September 8, 2025. Plaintiffs Tavantzis and Plasencia rested their case on September 10, after which American Airlines moved for judgment as a matter of law under Federal Rule of Civil Procedure 50(a). The opinion says that the allegations and legal questions were already known to the court and the parties and therefore does not describe them in full.
American Airlines’ Argument
American Airlines argued that the Plaintiffs had not shown that the airline acted in violation of its manual during Flight 68. It relied on the position that a failure to provide adequate medical assistance, without more—such as a substantial departure from the airline’s policies and procedures or from industry standards—does not constitute an “accident” under Article 17 of the Montreal Convention.
Legal Standard
A motion for judgment as a matter of law asks the court to decide that the opposing party lacks legally sufficient evidence to support its claim or defense. When a jury is deciding the facts, the court may grant the motion only if no reasonable jury could find for the opposing party. The court must view reasonable inferences in favor of that party and may not decide witness credibility or weigh competing evidence, because those tasks belong to the jury.
Court’s Analysis
The court said that, even assuming American Airlines’ interpretation of the Montreal Convention was correct, it was not convinced that the Plaintiffs lacked evidence that the airline acted outside the scope of its policies and procedures. The airline’s in-flight manual included stroke symptoms that flight attendants were expected to know. Witnesses gave conflicting testimony about whether Flight Attendant Eccles failed to act properly on that knowledge, either at the beginning of the flight or about an hour and a half later. The court concluded that this testimony could allow a reasonable jury to find that American Airlines violated its policies.
Disposition
Judge Wise denied American Airlines’ Rule 50(a) motion for judgment as a matter of law. The court therefore did not remove the issue from the jury’s consideration on the grounds presented in the motion.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.