Summary Judgment for American Airlines Affirmed in False Imprisonment Case, and Education Matter

By FindLaw Staff on July 02, 2010 | Last updated on March 21, 2019

Ray v. Am. Airlines, Inc., No. 09-2317, concerned a purported class action lawsuit against American Airlines alleging claims for false imprisonment and negligence arising from a nine hour tarmac delay.  The court of appeals affirmed summary judgment for defendant, on the grounds that 1) plaintiff failed to present sufficient evidence to show that her detention on American's plane was "without authority of law"; and 2) plaintiff's allegations of an upset stomach and mild claustrophobia did not rise to the level necessary to support a negligence claim under Texas law.

Lathrop R-II Sch. Dist. v. Gray, No. 09-3428, involved plaintiff's appeal from the district court's reversal of the decision of an administrative panel in an Individuals with Disabilities in Education Act (IDEA) action.  The court of appeals affirmed, holding that 1) since plaintiff's son's individualized education plans (IEPs) did contain detailed behavioral interventions, and the IDEA did not require behavioral improvement, the panel erred in basing its conclusion on behavioral deficiencies; and 2) even if there were a technical violation regarding the requirement to schedule a meeting at a "mutually agreed upon" location, 34 C.F.R. section 300.345(a)(2), it did not affect the IEPs or otherwise deprive the child of educational benefit.

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