Posted: September 30th, 2022

Source: Catherine Ray v. American Airlines, 609 F.3d 917 (8th Cir. 2010).

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Catherine Ray and her husband were flying from Oakland, California, to Dallas, Texas, when the American Airlines plane was rerouted to Austin, Texas, because of bad weather in Dallas. Their flight landed in Austin around noon, refueled, and began to depart, but the weather problems had then closed the Dallas airport. After an hour on the ground, a bus took some passengers to the terminal, but Ray and her husband chose not to deplane because, as Ray later testified, the pilot said the flight would likely resume in about an hour and anyone who left the plane “would be on their own.” Ray, therefore, believed that departing passengers would need to fund their further transportation, which the Rays could not afford. Approximately three hours later, another bus arrived and passengers were told that the bus offered their last chance for departure. The Rays decided to remain on the plane despite apparently deteriorating conditions on the plane, including little food and drink, agitated passengers, and some nonfunctioning lavatories. Lightning in Austin delayed ground crew work, but after another three hours, at 9 PM, the plane was taken to a gate where Ray and all other passengers deplaned. Sometime after deplaning, food and lodging vouchers were provided. Ray and her husband decided to spend the night in the terminal. They flew from Austin the following morning. Ray subsequently filed a civil action for false imprisonment, among other claims.
Requirement: Ray subsequently filed a civil action for false imprisonment, among other claims. How would you rule on that claim? Explain using the elements of false imprisonment as support to your response.
Source: Catherine Ray v. American Airlines, 609 F.3d 917 (8th Cir. 2010).

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