Arzu v. American Airlines, Inc.

Background

Melissa Arzu sued American Airlines individually and as administrator of the estate of Kevin Ismael Greenidge. The lawsuit arose from Greenidge’s death during American Airlines Flight No. AA614 from Honduras to Miami International Airport on June 4, 2022. The complaint alleged that Greenidge suffered cardiac arrest and became unconscious during the flight, and that American Airlines’ negligence in failing to maintain a working defibrillator caused, permitted, or hastened his death.

American Airlines moved to dismiss under Federal Rules of Civil Procedure 12(b)(2) and 12(b)(6), arguing that the court lacked personal jurisdiction over it and that the complaint failed to state a claim. The plaintiffs moved under Rule 15(a) to amend the complaint to add specific jurisdiction and additional arguments under New York’s long-arm statute.

General Personal Jurisdiction

The court explained that general personal jurisdiction allows a defendant to be sued on all claims. The plaintiffs appeared to rely on American Airlines’ registration as a foreign corporation and its substantial business in New York. However, the plaintiffs did not address general jurisdiction in their opposition to the motion to dismiss, so the court treated that assertion as abandoned.

The court also ruled that general jurisdiction would not satisfy constitutional due process. American Airlines was incorporated in Delaware and had its principal place of business in Fort Worth, Texas—not New York. The court found nothing indicating that this was an exceptional case in which American Airlines could nevertheless be treated as being essentially at home in New York.

Specific Personal Jurisdiction and Proposed Amendment

The plaintiffs proposed adding specific personal jurisdiction based on three alleged connections to New York: the purchase of Greenidge’s airline ticket in New York, flight itinerary connections involving New York, and American Airlines’ alleged failure to inspect and maintain the defibrillator in New York or elsewhere.

The court rejected jurisdiction under New York Civil Practice Law and Rules § 302(a)(1), which concerns claims arising from a defendant’s transaction of business in New York. The court held that the claims arose from Greenidge’s death during the Honduras-to-Miami flight, not from business American Airlines transacted in New York. It further held that purchasing the ticket in New York and having travel originate or end in New York were insufficient when the injury occurred elsewhere. The alleged failure to inspect or maintain the defibrillator also was not a transaction of business in New York.

The court rejected jurisdiction under § 302(a)(2) because that provision requires the alleged tortious act to occur in New York. The proposed complaint alleged a failure to inspect and maintain the defibrillator “in any jurisdiction, including New York, at any time,” and the court concluded that the alleged conduct did not occur in New York.

The court also rejected jurisdiction under § 302(a)(3), which can apply to an out-of-state tort causing injury in New York when additional statutory requirements are met. The court explained that the relevant injury location is the place of the original event causing the injury, not where later effects are felt. It concluded that specific jurisdiction was unavailable under that provision as well.

Because American Airlines was not subject to specific jurisdiction, the court found that the proposed amendment would be futile. The court therefore denied the motion to amend. Because it granted dismissal based on personal jurisdiction, it did not address American Airlines’ separate argument that the complaint failed to state a claim.

Disposition

Magistrate Judge Stewart D. Aaron granted American Airlines’ motion to dismiss and denied the plaintiffs’ motion to amend. The court requested that the Clerk of Court close the case.