Court rules American Airlines not liable for passenger death despite alleged equipment malfunction

Quick summary

A US federal court has ruled that an alleged defibrillator malfunction aboard American Airlines Flight 614 did not legally cause the death of a 14-year-old passenger on a June 4, 2022 flight from San Pedro Sula, Honduras to Miami. Judge Mark T. Pittman found that the family’s expert evidence — showing survival-to-hospital-discharge odds below 25% — failed to meet the causation threshold required under Article 17 of the Montreal Convention, blocking their damages claim even though the device’s performance remained disputed.

The Fifth Circuit Court of Appeals had already allowed the equipment-failure theory to proceed in May 2026, finding a genuine factual dispute over whether the AED delivered a shock. The district court’s subsequent causation ruling is the development that closes the family’s path to recovery.

On a flight that diverted toward Cancún after a teenage passenger collapsed, an automated external defibrillator either failed to deliver a shock or delivered one that witnesses never saw — and a federal court has now ruled that the distinction, however real, cannot carry a wrongful-death claim across the finish line. US District Judge Mark T. Pittman issued the causation ruling on September 28, 2026 in Arzu v. American Airlines, Inc., case No. 4:24-CV-433 out of the Northern District of Texas.

The passenger, a 14-year-old boy with asthma, high blood pressure, Type II diabetes, and sleep apnea, boarded American Airlines Flight 614 at San Pedro Sula’s Ramón Villeda Morales International Airport bound for Miami. After a lengthy weather delay on the ground, he began struggling to breathe. His condition deteriorated sharply after takeoff, and he lost consciousness before the crew could complete an emergency diversion to Cancún International Airport.

An off-duty nurse and a surgical resident performed CPR while flight attendants retrieved the onboard AED. The device initially detected asystole — a flatline rhythm that cannot be treated with a shock — but after roughly eight minutes of CPR it identified a shockable rhythm and instructed the crew to act. The AED’s internal records logged a shock as delivered. Four witnesses, including both medical professionals on scene, said they saw no shock occur.

That factual dispute was enough for the Fifth Circuit to keep the case alive. The appeals court’s May 14, 2026 opinion in appeal No. 25-10606 held that evidence of a possible delivery failure could qualify the malfunction as an unexpected or unusual event under Article 17 — the threshold for an “accident” — and sent the causation question back to the district court. What the family then had to prove was whether a functioning device would probably have saved the boy’s life. That is where the claim ended.

Why the causation bar proved insurmountable

The family’s expert, a pediatrician, testified that the passenger likely would have survived had the AED worked. Judge Pittman examined the medical literature underpinning that opinion and found a critical gap: the studies tracked survival to hospital admission following successful defibrillation, not survival to hospital discharge. Longer-term outcomes in the underlying data were substantially worse. The court concluded that the probability of the boy surviving to discharge was below 25%, meaning the family had not shown — on the balance of probabilities — that a functioning AED would probably have prevented the death.

The ruling does not touch the airline’s regulatory obligations. Under FAA Advisory Circular AC 121-33B, Part 121 carriers operating aircraft above 7,500 pounds maximum payload capacity with at least one flight attendant must carry an AED approved for US medical use. The FAA classifies AEDs as no-go items under the applicable minimum-equipment framework — an operator generally cannot dispatch without satisfying the requirement. That obligation survives this ruling intact.

The Fifth Circuit’s May 2026 opinion is publicly available in the court record. Inside Flyer and Paddle Your Own Kanoo both reported the district court’s causation ruling on or around the date of publication.

Two questions, not one — and why the distinction matters

Most passengers assume that if an airline’s emergency equipment fails, the airline is liable. This case illustrates why that assumption is legally incomplete on international routes.

Under Article 17 of the Montreal Convention, a carrier’s liability for death or injury depends on two separate findings: first, that an “accident” occurred on board — meaning an unexpected or unusual event external to the passenger — and second, that the accident caused the harm. Courts have sometimes treated these as a single inquiry, but the Fifth Circuit’s handling of this case kept them distinct. The AED dispute cleared the accident hurdle. It could not clear the causation hurdle.

That separation has real consequences for how these claims are built and defended. Proving that a device malfunctioned requires witness testimony and equipment logs. Proving that the malfunction changed the medical outcome requires epidemiological evidence strong enough to establish probable — not merely possible — survival. Those are different disciplines, and the evidentiary standards are not the same.

For travelers, the practical takeaway is narrower than the legal one. An AED on a covered flight is a regulatory requirement, not a guarantee of successful resuscitation — cardiac arrest survival rates in any setting depend heavily on rhythm type, time to shock, and underlying health. What this ruling adds is a reminder that if an onboard medical emergency later becomes legally contested, the evidentiary record matters: retain any documentation of treatment received, diversion details, and the names of medical personnel who assisted.

What travelers and families should know now

The causation standard applied here is not unique to this case — it reflects how Article 17 claims work across all Montreal Convention jurisdictions, including routes departing from Europe, Australia, and Canada.

• Document everything during an onboard medical event. If emergency equipment is used or alleged to have failed, note the names of any medical professionals who assisted, the time of events, and what crew members did. This documentation becomes the evidentiary record if a claim is ever filed.
• Understand what “accident” means under Article 17. Not every onboard medical deterioration qualifies. Courts look for an unexpected or unusual event external to the passenger — a device malfunction may qualify, but a passenger’s pre-existing condition worsening in flight generally does not.
• Expert evidence must address the right question. In causation disputes, survival-to-discharge data carries more weight than survival-to-admission data. Families pursuing claims should ensure their medical experts engage the specific counterfactual the court will apply.
• Carry prescribed medication in hand luggage. The onboard emergency kit is a regulatory baseline, not a substitute for personal medication management — particularly for passengers with complex medical histories on long international routes.
• Check whether an appeal is filed. Judge Pittman’s ruling is a district court decision. The family retains the option to return to the Fifth Circuit on the causation question, and any appellate outcome could refine the standard further.

Watch: Whether the family files a Fifth Circuit appeal on the causation ruling — and whether the appeals court addresses what survival-probability threshold satisfies Article 17’s “caused by” requirement — will determine whether this case produces binding precedent on medical-evidence standards in onboard equipment claims.

Questions? Answers.