Missouri Court of Appeals, Eastern District / Jun 29, 2018
Karen D. Spencer, Appellant, vs. American Airlines, Inc., et al., Respondents.
Karen D. Spencer sued American Airlines (AA) and Jimmy Lee for negligence after Lee allegedly injured her knee by forcibly reclining his seat on an AA flight. The trial court granted summary judgment for both defendants. The appellate court affirmed summary judgment for AA, finding no foreseeable duty to protect Spencer from Lee's actions. However, the court reversed summary judgment for Lee, concluding that a genuine issue of material fact existed regarding his duty of care and causation-in-fact, and remanded the cause for further proceedings against Lee.