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American Airlines v. Ulen

Citation. 186 F.2d 529 (D.C. Cir. 1949).
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Brief Fact Summary.

The district court awarded summary judgment in favor of Mrs. Ulen (Plaintiff) and Mr. Ulen (Plaintiff) in their negligence actions against American Airlines (Defendant). 

Synopsis of Rule of Law.

Summary judgment is appropriate when no genuine issue of material fact exists. 


Mrs. Ulen was a passenger on an airplane operated by Defendant. The plane crashed, causing significant injury to Mrs. Ulen. She and her husband separately filed suit against Defendant as a result of these injuries. During the pretrial phase, Plaintiffs served a large number of interrogatories on Defendant and received detailed responses. Plaintiffs then moved for summary judgment in reference to liability, leaving only damages to be determined by trial. Defendant objected, also amending its answer to allege the crashes were subject to the Warsaw Convention, which limits recovery in the absence of willful misconduct. Summary judgment was granted in both suits, and the Ulens were awarded $27,500 in damages by the jury. Defendant appealed, claiming that the grants of summary judgment were in error.  


Is summary judgment appropriate when no genuine issue of material fact exists?


(Clark, J.) Yes. Summary judgment is appropriate when no genuine issue of material fact exists. Defendant claimed that the summary judgment determination should be made solely based upon the complaint and original answer, and not on the interrogatories and answers developed during the discovery phase. However, it is proper to consider interrogatories and their answers when determining whether a genuine issue as to any material fact exists. Here, the extensive interrogatories and answers clearly showed Defendant’s liability and no genuine issue as to material facts concerning liability remained. The interrogatories also revealed willful misconduct, preventing the Warsaw Convention from limiting the recovery.     


Summary judgment should be granted when no genuine issue of material fact exists. Federal Rule of Civil Procedure 12(c) also allows for a motion for judgment on the pleadings. The rule also allows a court to treat this motion as a motion for summary judgment and look beyond the pleadings. Both motions allow a party to end litigation before trial when the other party has no chance of succeeding. 

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