US Court: American Airlines AED Not Cause of 2022 Passenger Death

Court Rules Against Causation in Flight Fatality

A United States District Court recently determined that a faulty automated external defibrillator (AED) on an American Airlines flight was not the direct cause of a 14-year-old passenger's death in June 2022.

This ruling, published by US District Judge Mark T. Pittman in Texas, prevents the family of the deceased, Kevin Greenidge, from pursuing damages of at least US$215,000 against the carrier. The legal action was initiated under Article 17 of the Montreal Convention, which holds airlines responsible for passenger death or injury resulting from an "accident".

The court's decision specifically addresses the causal link between the allegedly broken AED and the passenger's passing, clarifying the scope of airline liability in such tragic circumstances.

Incident Details Aboard Flight AA-614

The incident occurred on 4 June 2022, aboard American Airlines flight AA-614, travelling from San Pedro Sula, Honduras, to Miami. Kevin Greenidge, who suffered from multiple pre-existing health conditions including obesity, asthma, high blood pressure, Type II diabetes, and sleep apnea, began struggling to breathe shortly after take-off following a weather delay.

He later lost consciousness from an apparent heart attack. Despite efforts by off-duty medical professionals and the use of the aircraft's AED, Kevin died before an emergency diversion to Cancun, Mexico, could be completed.

The family's lawsuit centred on whether a flight attendant's alleged inadequate response and the broken AED constituted an "accident" causing the death under the Montreal Convention.

Judicial Reasoning on Equipment and Survival Probability

Prior rulings had established that the flight crew's response, while potentially imperfect, did not qualify as an "accident" under the Montreal Convention. The case then returned to the district court to assess the role of the malfunctioning AED.

Judge Pittman's memorandum opinion focused on establishing causation, requiring proof that the broken device not only constituted an accident but also directly caused Kevin's death. The judge reviewed expert testimony, including that of Dr. Corwin Warmink, who suggested Kevin might have survived with a working AED.

However, Judge Pittman concluded that the studies relied upon by the expert indicated a low probability of survival to hospital discharge, especially given Kevin's medical history and the AED's initial inability to detect a shockable rhythm.

Implications for Airline Liability and Onboard Equipment

Judge Pittman clarified that while the ruling does not absolve airlines of the responsibility to maintain working equipment – noting that the Federal Aviation Administration (FAA) can penalise carriers for equipment lapses without proving a death resulted – it reinforces that plaintiffs seeking damages for death must prove causation under Article 17 of the Montreal Convention.

This means carriers are liable for harm their accidents cause, not for harm their accidents did not cause. While this US District Court ruling specifically addresses American Airlines' liability, its interpretation of the Montreal Convention's Article 17 holds relevance for Asian carriers and regulators.

Airlines such as Singapore Airlines, Cathay Pacific, and ANA, which operate extensive international networks, are also signatories to this convention and carry similar medical equipment.

The decision underscores the critical distinction between regulatory compliance for equipment maintenance and the burden of proof required for a plaintiff to claim damages for death, which could influence how Asian courts interpret liability in future incidents involving onboard medical emergencies.