Matthews v. United Airlines, Inc.
2017 Ohio 5558
| Ohio Ct. App. | 2017Background
- Matthews flew to Birmingham and, on return, was rebooked onto a United Airlines flight from Chicago to Akron where her checked luggage did not arrive.
- She attempted to report the missing luggage at the airport after midnight but the United office was closed; she later called United and claimed to have faxed notice earlier that morning—United said it never received the fax.
- Matthews pursued follow-up contacts over subsequent days; United ultimately declined responsibility for the loss.
- Matthews sued in Akron Municipal Court (small claims) for the value of the lost luggage and produced receipts for some items; United relied on its Contract of Carriage, asserting she failed to timely file required notices and the written claim form within 45 days.
- A magistrate awarded Matthews partial judgment ($2,038.97); the trial court sustained United’s objections, rejected the magistrate’s decision, and entered judgment for United based on noncompliance with the Contract of Carriage notice provisions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Matthews complied with United’s 45‑day written claim requirement | Matthews mailed the written claim to United on Jan. 5, 2015 (within 45 days) and faxed notice on Dec. 1 | United produced testimony/file showing it did not receive a written claim until Jan. 21, 2015 (outside 45 days); Contract of Carriage bars claims not timely submitted | Trial court found Matthews failed to prove timely submission; judgment for United affirmed |
| Whether the magistrate’s award should stand despite alleged Contract noncompliance | Magistrate correctly found loss occurred and awarded recoverable items supported by receipts | Contract of Carriage notice provisions control and were not addressed by magistrate | Trial court properly rejected magistrate for failing to consider Contract provisions; appellate court found no abuse of discretion |
Key Cases Cited
- Blakemore v. Blakemore, 5 Ohio St.3d 217 (Ohio 1983) (standard for finding abuse of discretion)
- Pons v. Ohio State Medical Board, 66 Ohio St.3d 619 (Ohio 1993) (reviewing court should not substitute its judgment for trial court under abuse-of-discretion standard)
- State v. Otten, 33 Ohio App.3d 339 (9th Dist.) (weighing evidence and manifest-weight standard)
- State v. Ishmail, 54 Ohio St.2d 402 (Ohio 1978) (appellate review limited to the trial court record)