US Airways v. Sabre Holdings Corporation
US Airways, Inc., for American Airlines, Inc. as Successor and Real Party in Interest v. Sabre Holdings Corporation
- Lorna Schofield
- 1:11-cv-02725
- U.S. District Court · Southern District of New York
- 1
In US Airways v. Sabre Holdings, Judge Schofield granted US Airways’ motion to bar evidence about Sabre’s listed defenses at trial.
US Airways and Sabre Holdings Corp.; the ruling limits Sabre’s ability to present evidence or argument about the specified defenses at trial.
What happened
In US Airways, Inc. v. Sabre Holdings Corp., US Airways asked the court to prevent Sabre from presenting evidence or arguments about four defenses: in pari delicto, unclean hands, waiver, and estoppel.
The court granted the motion. It relied on an earlier ruling that declined to give the jury instructions about “equal participation” and related defenses, and said Sabre had not shown a legal change requiring a different result. The court also said adding the monopoly claim did not change the analysis because that claim concerns harm to market participants, not only to US Airways as a contract counterparty.
Judge Lorna G. Schofield directed the Clerk of Court to close the motion. The order addressed what evidence and arguments could be presented at trial; it did not decide the ultimate claims in the case.
The detailed version
- US Airways v. Sabre Holdings Corporation · No. 1:11-cv-02725
- Lorna Schofield
- Apr. 1, 2022
Motion and Requested Relief
US Airways moved in limine, meaning it asked the court to rule before trial on the admissibility of evidence and arguments. Specifically, US Airways sought to preclude Sabre from presenting evidence or argument concerning Sabre’s affirmative defenses of in pari delicto, unclean hands, waiver, and estoppel.
Court’s Reasoning
The court granted the motion because its earlier ruling had declined to instruct the jury on “equal participation” and related defenses. The court treated that earlier ruling as the law of the case, meaning the court’s prior decision generally governed the same issue in the continuing litigation. The court cited Perma Life Mufflers, Inc. v. International Parts Corp., Gatt Communications, Inc. v. PMC Associates, LLC, a December 12, 2016, trial transcript, and an earlier docket entry.
The court stated that Sabre had not identified an intervening change in the law that required a different result. It also rejected the argument that adding the monopoly claim changed the result. The court explained that the monopoly claim concerns competitive harm to all participants in the market allegedly subjected to Sabre’s monopoly power, rather than only harm to US Airways as a contractual counterparty.
Disposition
The court granted US Airways’s motion in limine. The Clerk of Court was directed to close the motion at Docket No. 1102. The opinion does not state that the court entered judgment on the underlying claims.
Classification
This is a procedural order because it resolves an evidentiary and trial-management motion rather than deciding the parties’ underlying legal claims.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.